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Linda S. Goldberg

Financial Sector FDI
and Host Countries:
New and Old Lessons
• The financial sectors of many developing
countries are being reshaped dramatically by
the rise in foreign direct investment, or FDI.

• The growth in financial sector FDI, in which
banks in industrialized countries establish
branches and facilities in emerging markets,
has drawn attention to the consequences of
foreign ownership of banking resources.

• An analysis of research on “real-side” FDI—
investment into manufacturing and primary
resource industries—suggests that lessons in
these industries also apply to the financial
sectors of host countries.

• Real-side and financial sector FDI can
heighten the host country’s integration into
world business cycles through improved
allocative efficiency, higher technology
transfer rates, and greater wages. In banking
and finance, financial sector FDI can
potentially strengthen institutional
development in the host country through
improved regulation and supervision.

Linda S. Goldberg is a vice president at the Federal Reserve Bank of New York.
<linda.goldberg@ny.frb.org>

1. Introduction

I

n the 1990s, foreign direct investment (FDI) became
the largest single source of external finance for many
developing countries.1 Most discussions on the causes and
effects of FDI have focused on flows into manufacturing and
real production sectors, where this type of investment has
traditionally been concentrated. More recently, however, FDI
into the financial sector has soared, and the sector is being
reshaped dramatically.
Financial sector FDI, a relatively new phenomenon,
typically takes the form of banks in industrialized countries
establishing branches and facilities in developing countries.
Following the dissolution of the Soviet Union, bank entry into
Central and Eastern Europe in the early 1990s led to foreign
ownership in local banking systems; today, such ownership
often exceeds 80 percent of local banking assets. In addition,
the liberalization of financial sectors in Latin America was
likely spurred in part by foreign direct investment, especially
in countries facing potential competitive losses to Asian
economies. Within Latin America, the financial crises of the
mid-to-late 1990s provided additional opportunities for
foreign entry, as countries sought to recapitalize their banks
and improve the efficiency of their financial systems.
1

Other sources of external finance include bank flows, revenues from bond
sales, and foreign portfolio inflows. For more information, see International
Monetary Fund (2006).

The author thanks Don Morgan, two anonymous referees, participants in the
Bank for International Settlements Committee on Global Financial Stability in
Basle, in the 2004 Allied Social Science Associations meetings in San Diego,
and in the Trinity College of Dublin Conference on Micro and Macro
Perspectives on FDI. The views expressed are those of the author and do not
necessarily reflect the position of the Federal Reserve Bank of New York or
the Federal Reserve System.
FRBNY Economic Policy Review / March 2007

1

Chart 1

Value and Number of Acquisitions of Banks
in Developing Countries by Source Country,
1990-2003
Value (billions of U.S. dollars)
25 74
68

20
15
10

38
21
22 23

5

32 34 20 16

7

14

7 14

8

4

te

ni

U

U

ni

te

d

St
at
e
d Sp s
Ki ai
N ng n
et d
he om
rla
nd
s
Ita
Au ly
st
Fr ria
a
G nc
er e
m
C any
a
Ire
n
la B ada
nd el
-R giu
ep m
ub
Ja lic
Po pa
rtu n
Sw ga
ed l
e
G
Sw re n
itz ec
er e
la
nd

0

Sources: Bank of England; Thompson Financial.

it typically ignores the lessons documented in the research on
real-side investment that also apply to the financial sector.
The stylized facts derived from the literature on the causes
and consequences of real-side FDI are usually based on
theoretical arguments supplemented by case studies.3 Within
the economic research on this theme, the data studied are often
from individual countries or from manufacturing industries
within countries. Yet one limitation of real-side research is that
conclusions seldom distinguish between FDI in the form of
mergers and acquisitions and FDI in the form of greenfield
(referred to as de novo in the financial services industry)
investments. This limitation is relevant for understanding
and interpreting the employment, growth, and efficiency
consequences of FDI.
The emerging body of literature on financial sector FDI
addresses some issues that have not received much attention in
real-side studies. This research directly explores the crossborder flows of products and the consequences of ownership in
the financial services industry. It generally focuses on the
implications of foreign entry into local banking systems, either

Note: The figures above the bars are the number of acquisitions.

Banks in the United States, Spain, the United Kingdom, and
other countries with highly developed financial systems are the
main sources of financial sector FDI (Chart 1). Parent banks
based in industrialized countries have assumed substantial,
if not majority, control of assets in host-country financial
systems. This growing trend is illustrated in Chart 2, which
shows the evolution of foreign control of emerging market
financial assets between 1994 and 2004. Whereas foreign
control was typically below 10 percent of assets in 1990, it more
often surpassed 40 percent by the late 1990s. Acquisitions of
local banks continued through the early 2000s, significantly
expanding foreign bank presence into majority ownership in
many countries. From 1999 to 2004, the largest change in
structure occurred in Central Europe, where the foreign
ownership share rose to 77 percent.2
As one might expect, these dramatic shifts in investment
into foreign financial sectors have raised concerns about the
consequences of ownership of banking resources. In this
article, we emphasize that some of the consequences are already
well established in studies of foreign investment, although that
work does not focus specifically on the financial sector. In the
broad literature on FDI, the authors draw their results
primarily from “real-side” investment—that is, activity in
manufacturing and primary resource industries. And although
a new line of inquiry is concentrating on financial sector FDI,
2

The history of and context for these developments are discussed in Bank for
International Settlements (2006).

2

Financial Sector FDI

This article attempts to bridge some of
the gap between research on real-side
FDI and work on financial sector FDI
by presenting a selective survey of
the literature.

from the perspective of the investing firms and parents making
risk management decisions or from the vantage point of the
host markets that are sometimes skeptical of foreign entry.4
This article attempts to bridge some of the gap between
research on real-side FDI and work on financial sector FDI by
presenting a selective survey of the literature. We argue that
real-side and financial sector FDI share many features.
Accordingly, there are many lessons in the research that can
benefit both fields of study. Moreover, because research on
financial sector FDI is growing, attention could be focused
on areas where real-side lessons are lacking or inapplicable,
in which case real-side lessons need not be reinvented. In
addition, we point to specific areas where financial sector FDI
3

The case studies employ distinct “definitions” of FDI, sometimes using a flow
definition such as one covering the foreign investment that took place within
a particular time period, or a stock definition meant to represent the total
cumulative value of all foreign investment up to some point in time.
Data availability often drives the type of analysis conducted.
4
The insurance industry has also received significant foreign investment flows,
but less research attention. For example, see Skipper (2001).

Chart 2

Commercial Banks by Type of Ownership

State-owned
Foreign-owned
Private domestic

Percentage share of total bank assets
100
80
60
40
20
0
1994

1999
Latin America

2004

1999

2004

China and India

1994

1999

2004

Other Asia

1994

1999

2004

1994

Other emerging markets

1999

2004

Central Europe

Source: Mihaljek (2006).

has broader consequences—some that are quite policyrelevant—and argue that these consequences need to be
understood more fully.
Our review takes as its primary focus the host-country
implications of FDI, especially for emerging markets.
The implications span evidence on technology transfers,
productivity spillovers, wage effects, macroeconomic growth,
institutional development, and fiscal and tax concerns. One
intention of the review is to emphasize the findings that have
been presented independently in real-side FDI research and
more recently in studies of financial sector FDI. While the
language of these two distinct areas of analysis is subtly
different (see box), we show that many conclusions drawn
from them are strikingly similar. We also examine research
in which no overlap exists between the two lines of inquiry
and present conclusions from real-side FDI likely to apply
to financial sector FDI. In addition, we comment on how
both types of FDI may have different implications for host
countries.
Our main conclusions are that real-side and financial sector
FDI can induce limited technology transfers and productivity
gains as well as have wage implications in the host country.
Both types of investment can heighten the host country’s
integration into world business cycles. Moreover, in banking
and finance, financial sector FDI has the potential to strengthen
institutional development through improvements to
regulation and supervision. Banks provide key financial
intermediation services, and their activities have externalities
for bank regulation and supervision that cannot be overlooked

(and certainly have come to the attention of host countries).
These differences between real-side and financial sector FDI,
more so than the similarities, warrant further attention from
the research and policy communities. If the balance of evidence
weighs in favor of making host-country financial systems
healthier and improving intermediation—which seems to be
true when robust and well-regulated foreign banks enter
emerging markets—the governments of the host countries
may wish to consider looking more closely at options for
encouraging the benefits of financial sector FDI.

2. Does FDI Lead to Technology
Transfer and Productivity
Spillovers?
Economists argue that multinationals, through FDI, can help
to fill an “idea gap” between developed and developing, or host,
countries and provide greater opportunities for growth in the
host markets (Romer 1993). According to this view, producers
in the developed country have access to productive knowledge
that is not otherwise readily available to producers in the host
country. However potent, such productive knowledge may
be intangible, taking the form of technological expertise,
marketing and managing skills, export contacts, coordinated
relationships with suppliers and customers, and reputation
(Markusen 1995). Technology transfers from FDI, economists
contend, can stimulate growth in developing countries.

FRBNY Economic Policy Review / March 2007

3

The “Language” of FDI
To understand why “real-side” and financial sector foreign direct
investment (FDI) are so similar, first consider an FDI decision
process. In each case, a foreign producer of goods or services makes
a two-step decision. The producer begins by determining whether
to serve a particular market and then determining whether the
market should be served through exports or through the
establishment of a local production facility requiring FDI.
While manufacturers/real-side producers use the language of
exports or production by multinationals as a means to satisfy
customer needs, financial services firms use a different language for
a similar decision process. In the financial services industry (in
particular, banking), the bank first decides whether to provide
lending, deposit-taking, and other services to a market. It then
determines whether to serve the market through cross-border
activities (arm’s-length transactions) or through foreign direct
investment in the form of setting up branches or subsidiaries to
engage in local lending. Banks produce services, not goods, so
“export” transactions are sometimes not practical, especially when
the information intensity of the transaction requires proximity to
the client. Some banks specialize in screening and monitoring
more opaque borrowers, making cross-border transactions—that
is, exports—more costly than operating through a branch or
subsidiary in the host country. Financial sector FDI thus entails
either a de novo operation of introducing a new, licensed bank in
the host country or the acquisition of an existing bank.
Although the language used to describe transactions is different
for real-side and financial sector FDI, the decision process is
similar. In both contexts, FDI is an activity that occurs as part of a
multinational’s broader strategic plan. Flows can respond both to
microeconomic stimuli, such as tax incentives,a and to macroeconomic stimuli, such as fluctuations in exchange rates and
business cycles. The sometimes lumpy reallocation of capital across
borders can occur when governments reduce their protection of
inefficient or corrupt local industries.b Opportunities to gain local
market share and exploit sales or production networks also trigger
entry. These features are common to manufacturing industries and
extractive resource industries as well as to financial services
providers.

a

See Feldstein, Hines, and Hubbard (1995) for analyses of tax and FDI
issues.
b

4

Dixit and Kyle (1985) provide an elegant conceptual exposition.

Financial Sector FDI

This concept of technology transfer between countries has
a long and rich research history.5 Nonetheless, studies of
technology transfer reach mixed conclusions on the extent to
which the transfers and productivity spillovers have occurred
as a result of foreign direct investment in manufacturing and
extractive resource industries. Some conclude that domestic
firms in sectors with greater foreign ownership are more
productive than firms in sectors with less foreign participation.6 Others dispute the spillover benefits of FDI into local
markets.7 Part of the disagreement among researchers stems
from methodological disputes, particularly the extent to which
the studies properly control for the conditions in a country or
sector that existed prior to the entry of the foreign investors.
Sometimes foreign investment enters sectors where firms are
ex ante more productive. Observations of ex post high levels
of productivity in these sectors therefore offer no proof that
foreign entry contributed to enhanced productivity via
technology transfer or some other channel.
On balance, research on real-side FDI supports the finding
of positive productivity and technology spillovers into host
markets. However, the level of these benefits depends on

Economists argue that multinationals,
through FDI, can help to fill an “idea gap”
between developed and developing,
or host, countries and provide greater
opportunities for growth in the host
markets.
preexisting conditions among the host-country producers.8
Small plants may have the largest productivity gains from
foreign entry. Some local plants may lose workers and
experience productivity declines. In some cases, the gains from
foreign investment appear to be captured entirely by the joint
ventures.9
Technology transfers also flow into local industries that are
not themselves direct recipients of foreign capital. Indeed, the
view that a new plant will stimulate the local development of
5

See Horstmann and Markusen (1989) for an early discussion and formalization of this concept.
6
See, for example, Blomstrom (1989) on Mexico.
7
See Germidis (1977) for an early discussion of spillovers in the Organization
for Economic Co-operation and Development countries.
8
Gorg and Greenaway (2004) provide a rich and more exhaustive review of the
evidence on this point. They are more skeptical that the balance of evidence is
positive, but also emphasize that methodological issues need to be addressed
better.
9
Aitken and Harrison (1999) and Harrison and Aitken (1994) provide evidence
for Venezuela and preliminary results for Indonesia.

services and attract related producers is occasionally offered as
a justification for (possibly excessive) incentive packages
offered to foreign investors.10 Such positive “externalities”
have been observed. For example, Javorcik (2004) shows that

Financial sector FDI typically is found to
enhance the efficiency of banks that
remain in business in the host markets.

among Lithuanian firms, productivity spillovers from FDI took
place through contact between the foreign affiliates and their
local suppliers in upstream sectors, that is, through vertical
linkages. This careful study finds no support for the claim of
spillovers taking place within the same industry, sometimes
referred to as horizontal linkages.
This same logic should apply to the financial services
industries. Instead of using the language of productivity, recent
research on financial sector FDI considers whether foreign
bank entry alters the efficiency of foreign-owned and
domestically owned banks. Financial sector FDI typically is
found to enhance the efficiency of banks that remain in
business in the host markets. Efficiency calculations are
performed by using data on overhead costs (the ratio of bank
overhead costs to bank total assets) and bank net interest
margin (bank interest income minus interest expense divided
by bank total assets). Foreign banks operating in developing
countries appear to be more efficient than their domestic
counterparts, whether those counterparts are privately or
government-owned. Domestic banks are forced to become
more efficient after foreign entry, especially in the business
lines in which foreign banks choose to compete. Among the
relevant studies is Claessens, Demirguc-Kunt, and Huizinga
(2001), who use data from a sample of eighty countries to show
that foreign entry reduces the profitability of domestic banks
but enhances their efficiency. Country-specific studies that
mainly use bank balance-sheet data reach similar conclusions,
such as work on Latin America by Crystal, Dages, and Goldberg
(2001), on the Philippines by Unite and Sullivan (2001), on
Colombia by Barajas, Steiner, and Salazar (2000), and on
Argentina by Clarke et al. (1999). Turner (2006) argues that the
larger role of foreign-owned banks in Europe and Mexico in
the past decade has made the banking industry more efficient
and improved credit allocation.
These financial sector FDI studies do not identify whether
the productivity enhancements that occur in banking are
10

Such themes are developed in the elegant theoretical analysis of Markusen
and Venables (1999) and in Rodriguez-Clare (1996).

attributable to increased competition among banks or to
technology transfers between foreign and domestic banks. This
distinction is important for assessing whether financial sector
FDI is helping to close a knowledge gap between countries.
The distinction may also help reconcile two potentially
contradictory themes in discussions on financial sector FDI.
One such theme is that financial sector FDI induces efficiency
gains by changing an industry’s competitive structure: foreign
entry reduces the monopolistic excesses of domestic banks.
Bank exit or mergers and acquisitions change local competitive
structures in ways largely unparalleled in other sectors that
have received FDI. Another theme is that the significant
amount of bank consolidation during the past decade has been
fostered by technological change and foreign entry into
emerging markets. Interestingly, Gelos and Roldos (2002)
show that while such consolidation has been associated with
efficiency improvements, it has not reduced competition in
local financial markets. Foreign entry may be enhancing the
productivity of other banks in the host market through the
channel most often explored in real-side FDI research—
technology transfers—instead of exclusively through
competitiveness changes. This issue is interesting from a policy
perspective: If the main channel is technology transfers,
productivity transfers and gains can continue as long as the
parent banks innovate, even if a stable ownership structure
exists in the host-country banking industry.

3. Implications of FDI for
Host-Country Workers
The productivity and technology transfer arguments lead
directly to the question of whether foreign entry benefits local
workers in terms of wages. When the foreign firm has some

The productivity and technology transfer
arguments lead directly to the question
of whether foreign entry benefits local
workers in terms of wages.
intangible productive knowledge, technology transfer and
other training after entry should expand the human capital of
the employees of the foreign firm within the host country. This
expansion of human capital should manifest itself in greater
worker productivity and be rewarded by higher wages.
Studies of manufacturing industries link higher levels of
foreign direct investment to higher wages. In Mexico and

FRBNY Economic Policy Review / March 2007

5

Venezuela, wage growth was experienced by workers in
foreign-owned firms, but it did not spill over more broadly
through the host-country labor markets. In the United States,
the wage effects from foreign investment were smaller and
spilled over more into local labor markets (Aitken, Harrison,
and Lipsey 1996). In Indonesia, wages paid in domestically
owned manufacturing plants taken over by foreign firms
increased sharply relative to wages paid in those plants that
remained in domestic hands (Lipsey and Sjoholm 2003).11
On balance, these studies conclude that some workers in
manufacturing industries benefit directly from FDI through
higher wages. Whether because of the accumulated capital
being firm-specific or because of efforts by foreign firms to
limit outmobility of productive workers, analogous growth in
wages and productivity is generally not observed outside the
sector receiving FDI.
While the same issues are relevant for workers in financial
services industries, the topic has not been studied extensively.
Bank balance-sheet data indicate that foreign bank operating
costs are lower and that domestic bank costs are pushed down
by foreign entry (Crystal, Dages, and Goldberg 2001). In some

Studies of manufacturing industries link
higher levels of foreign direct investment
to higher wages.

cases, wage expenditures also decline. The analysis has not
determined whether these cost reductions are due to decreases
in the number of workers (often a result of acquisitions and
consolidations of banks) without wage declines or to
reductions in employment with higher wages paid to the
remaining workers.
Research on real-side FDI has examined the employment
effects of foreign direct investment. The overall implications
for the host economy are the combination of FDI effects on
employment by the specific firms receiving capital and on
employment changes that FDI induces in the rest of the
economy. Some implications are contingent on whether FDI
takes the form of greenfield (de novo) investments or occurs
via mergers and acquisitions of existing plants (or banking
networks). Greenfield investments, where new plants or
facilities are built, may generate increased host-country
employment. This job growth might be strongest if the new
plant does not compete directly with other local production
facilities that serve thin host-country markets. Net employ11

These results persisted even after the authors controlled for the initial
characteristics of the plants taken over by foreign investors.

6

Financial Sector FDI

ment gains could also be strong if agglomeration externalities
exist, so that the infrastructural improvements associated with
FDI spill over to other local firms and all local producers gain.12
The net employment effects of merger-and-acquisition FDI
are less transparent. Mergers and acquisitions may trigger
consolidation of an inherited bloated infrastructure, leading to
job loss. Fewer individuals may be employed at higher wages

The special role of banks in financial
intermediation means that the
employment consequences of financial
sector FDI may be broader, and more
positive, than the consequences of FDI
to the real economy.

in a plant or banking system that ultimately operates more
efficiently. In the case of financial sector FDI, evidence reported
by the Bank for International Settlements (2006) shows that
this type of investment is often made through acquisitions of
host-country banks. If financial sector FDI is followed by
branch closures and reductions in wage bills after acquisition,
it accords with this scenario. Yet such declines in employment
by a bank do not necessarily imply reductions in total employment in host countries. The special role of banks in financial
intermediation means that the employment consequences of
financial sector FDI may be broader, and more positive, than
the consequences of FDI to the real economy. This could arise
if intermediation is improved and financial capital is allocated
more effectively in the host country.

4. Do FDI Inflows Accelerate
Macroeconomic Growth?
The relationship between FDI and macroeconomic growth,
and the stability of this growth, is a central consideration as
host countries evaluate the trade-offs associated with foreign
entry. One way this topic has been discussed is in the context
of longer term performance, stemming from the argument by
12

Job creation by a single plant is generally not an appropriate welfare metric
for employment calculations. The foreign plant employs workers and pays
higher wages, drawing some workers from other local plants. In a situation
where the foreign investor takes over a local plant, restructuring could
lead to job loss, with only the remaining employees getting higher wages.
The producer potentially generates larger income and tax revenues for
local governments.

Romer (1993) that an idea gap has held back growth in
emerging markets. If an idea gap has impeded growth, the
argument continues, FDI can induce a catch-up process.
Indeed, the most robust evidence on FDI and aggregate
growth is found in studies of developing countries. For
example, analyses of inward investments to Greece, Taiwan,
Indonesia, and Mexico show a significant positive contribution

Studies of financial sector FDI effects
conclude that growth may expand both
through the technology transfer channel
and through improved intermediation of
capital flows between savers and
investment opportunities.
to these countries’ growth.13 Research using detailed industrylevel data finds that growth spillovers across industries depend
on the industries into which FDI flows. The spillovers and
growth ramifications are expected to be strongest when foreign
affiliates and local firms compete most directly with each other,
as may be the case in previously protected industries.14
Borensztein, DeGregorio, and Lee (1998) find positive
threshold effects between FDI and growth, with human capital
accumulation in the host country needing to be sufficiently
large before countries can reap the beneficial growth effects of
the foreign inflows.
Studies of financial sector FDI effects conclude that growth
may expand both through the technology transfer channel and
through improved intermediation of capital flows between
savers and investment opportunities.15 Cross-country growth
regressions reach the broader finding that financial
development improves economic growth.16 Demirguc-Kunt
13

The caveat to these results is that it is difficult to control adequately for
reverse causality problems. More specifically, investors may put their resources
into countries where growth is expected to be higher. See Lipsey (2000) for an
informative overview of the literature.
14
Markusen (1995) was an early advocate of the view that the competitive
structure of an industry is a key driver behind FDI implications.
15
A related area of research looks beyond financial sector FDI and considers the
growth implications of overall financial liberalization. The issue of financial
FDI, as opposed to portfolio investments or other forms of capital inflows, is
not explicitly addressed. In this literature, financial liberalization events are
usually defined in terms of regulatory changes, such as the relaxation of capital
controls or the lifting of interest rate ceilings. Despite the considerable research
undertaken, the extent of the long-term growth benefits of capital account
liberalizations is hotly debated, and a consensus view has not emerged.
Researchers have found sharply contrasting results owing to differences in
country coverage, sample periods, inclusion of crisis controls, and indicators of
financial liberalization. For recent examples and surveys, see Edison et al.
(2002) and Eichengreen and Leblang (2003).

and Maksimovic (2002), however, find no evidence that
country differences in economic growth can be explained by
distinguishing countries by financial structure (that is, bankbased versus market-based structures).
Positive growth effects from financial sector FDI can occur
because of more efficient credit allocation in host markets, with
funds made more available for private sector use. Prior to
financial sector liberalization and reform, some governments
used the local banking system as a tool for providing directed
credit to politically favored constituents or favored but lossincurring sectors of the economy. The banks implicitly play a
role in patronage and “development finance” and subsidize
levels of activities that might not be viable on market terms.
Suggestive evidence of the costliness of such strategies is found
in La Porta, Lopez-de-Silances, and Shleifer (2002). Using
global data, the authors argue that a higher level of government
ownership of banks is associated with lower growth of per
capita income and productivity. Sapienza (2002), in a fascinating study of state-owned banks in Italy, shows that public bank
lending has a pattern of rewarding political supporters.
While serving as a means of fiscal stimulus, this type of
directed lending crowds out intermediation to worthy private
borrowers—a point also made by Mishkin (2005), who
expounds on the principal-agent problems associated with

Research on lending comparisons across
banks differentiated by owner types
supports the conclusion that financial
sector FDI fosters economic growth.

directed lending. If foreign banks operating in host markets are
better regulated and subject to parent bank oversight, these
banks may be able to resist local suasion more effectively.
As such, they may discipline host-country fiscal or monetary
“irresponsibility” better and be less amenable to forced
purchases of government bonds or forced lending to favored
political constituents. Such outcomes are auspicious for
sustainable economic growth.
A related finding by Galindo and Schiantarelli (2003) is that
financial liberalization tends to relax financing constraints on
producers in developing countries and make them less
adversely influenced by financial crises. Foreign banks
sometimes enter as a component of larger scale financial
liberalization or bank privatization efforts and sometimes as
local governments seek to recapitalize their financial systems
16

For example, see Levine, Loayza, and Beck (2000) and Rajan and Zingales
(1998).

FRBNY Economic Policy Review / March 2007

7

in the wake of crises. Outside of crisis periods, foreign banks
might be expected to contribute to growth by providing capital
to worthy but previously credit-constrained borrowers and by
not crowding out credit provision to worthy borrowers that are
outside the scope of their business model. During crises,
foreign-owned banks may be destinations for local flight
capital, preventing this capital from leaving the country and
creating greater opportunities for these funds to continue to
be intermediated locally.
Research on lending comparisons across banks
differentiated by owner types supports the conclusion that
financial sector FDI fosters economic growth. Credit provision
by U.S. banks to Latin American countries grew faster during
the 1990s and was less sensitive to local cycles than credit
provision by domestically owned banks (Crystal, Dages, and
Goldberg 2001). The composition of credit provision is also
important for long-term growth, raising the concern that small
businesses relying on bank credit might have constrained
access with foreign bank entry. In Latin America, foreignowned banks have been providing credit to local constituents
in patterns similar to those of healthy domestically owned
banks (Dages, Goldberg, and Kinney 2000). Detailed evidence
for Latin American countries shows that other than possible
biases in borrower orientation often linked to bank size

Overall, these observations support
the conclusion that financial sector FDI
should foster more rapid growth within
economies. The conclusion is also
supported by arguments based on better
information processing, technology,
and risk management practices.
(large banks lend relatively less to small and medium-size
enterprises), there has been no systematic bias in orientation
specifically associated with foreignness (Clarke, Cull, and Peria
2001). In Eastern Europe (specifically Hungary), in aggregate
foreign entry may even have been associated with expanded
credits to small and medium-size enterprises when the
domestic banks had to search more aggressively for a broader
clientele for lending (Bonin and Abel 2000). Berger, Klapper,
and Udell (2001) find that foreign banks in Argentina behaved
significantly differently from local banks only when decisionmaking remained in foreign headquarters.
Overall, these observations support the conclusion that
financial sector FDI should foster more rapid growth within

8

Financial Sector FDI

economies. The conclusion is also supported by arguments
based on better information processing, technology, and risk
management practices.

5. FDI and Business Cycles
Foreign direct investment can also influence the pattern of
business cycles in host countries, the transmission of cycles
from foreign markets, and crisis contagion across markets.
Analyses of business cycle comovements across countries look
for explanations for changes in synchronization that have
occurred across recent decades. Yet when developing countries

Foreign direct investment can also
influence the pattern of business cycles in
host countries, the transmission of cycles
from foreign markets, and crisis contagion
across markets.
are divided into two broad groups—more financially
integrated and less financially integrated economies—both
groups have low correlations with world macroeconomic
aggregates, with these correlations not statistically higher in
recent decades compared, for example, with the 1960s and the
1970s (Kose, Prasad, and Terrones 2003).17
The independent role of FDI, and specifically of multinational firms, in business cycle integration has not been
explored as thoroughly. While Hanson and Slaughter (2004)
posit a role for multinationals that relies on profit sharing
between parent and affiliate firms, especially through wages,
the strength of this channel has not been widely tested
empirically or assessed relative to other channels.18 As a general
point, the specific contribution of real-side FDI to business
cycle linkages across countries, as opposed to financial
integration more broadly defined, largely remains an open
17

Prasad et al. (2003) provide an extensive review of this evidence, noting the
broad group of papers that look at financial integration and growth. The role
of FDI within financial integration is less well documented. Imbs (2004) finds
that financial integration raises correlations among a sample of industrialized
countries. Kose and Yi (2001) argue that the increased vertical integration of
production in world trade poses a powerful channel for business cycle
transmission. Such vertical production linkages are frequently supported by
patterns of general FDI and suggest that FDI in manufacturing and extractive
resource industries stimulates business cycle comovements.
18
The arguments draw from Budd and Slaughter (2000) on international rent
sharing.

question. Likewise, the relative importance of real-side FDI
compared with financial sector FDI in changing the nature of
local business cycles has not been determined.
In contrast, studies conclude that financial sector FDI
clearly has consequences for local business cycles. This line of
research typically uses bank-level data to relate lending
activities to shock transmission within and across national
borders. In principle, bank lending activity can either be
procyclical or countercyclical with respect to local business
cycles and other shocks. The availability of loanable funds via
the deposit base contributes to procyclicality. However, if
foreign bank entrants are less reliant on host-country funding
sources and more reliant on foreign sources, the procyclicality
of their supply of loanable funds may be reduced. Loan
demand, too, can either be procyclical, as individuals or
businesses borrow more to expand their holdings in
prosperous times, or countercyclical, as individuals try to
smooth consumption intertemporally.
Researchers generally find strong evidence of procyclicality
in bank lending. In addition to the aforementioned points,
other arguments for procyclicality rely on information
asymmetries between borrowers and lenders, as within a

The cyclical lending responses of banks
could differ between foreign- and
domestically owned institutions.
financial accelerator view of credit cycles.19 Or, as Borio,
Furfine, and Lowe (2001) contend, procyclicality may result
from inappropriate responses by financial market participants
to changes in risk over time. These inappropriate responses can
be attributable to market participants underestimating risk in
good times and overestimating it in bad times. Inappropriate
credit cycles can also derive from market participants having
incentives to react to risk, even if correctly measured, in
ways that are socially suboptimal. Related arguments for
procyclicality stem from bank provisioning practices and their
links to rules on regulatory capital (Cavallo and Majnoni
2001).
The cyclical lending responses of banks could differ between
foreign- and domestically owned institutions. Dages,
Goldberg, and Kinney (2000) find that although foreign banks
are procyclical lenders, they do not appear to magnify the
19

The financial accelerator argument maintains that information asymmetries
between lenders and borrowers contribute to the procyclicality of lending.
When economic conditions are subject to an adverse shock, and collateral
values decline, even those borrowers with profitable projects have difficulty
obtaining funding.

boom-bust cycles in emerging markets. Analysis of individual
bank data from Chile, Colombia, and Argentina supports
broad similarities between the lending patterns of private,
domestically owned domestic banks and longer established

A related issue is whether financial sector
FDI can reduce the magnitude of hostcountry cycles if foreign bank involvement
reduces the actual incidence of crises.
foreign banks. The similarities with newer, established foreign
banks are less systematic. While foreign banks had higher
average loan growth, they did not add significant volatility to
local financial systems or act as relatively destabilizing
lenders.20 In a study of the Malaysian experience, Detragiache
and Gupta (2004) find that foreign banks with sufficient
international diversification played a stabilizing role in host
credit markets during the Asian crisis. By contrast, foreign
banks that had a narrower focus on Asia behaved similarly to
domestic banks. Arena, Reinhart, and Vazquez (2006) study
bank behavior across twenty Asian and Latin American
countries from 1989 through 2001 to compare foreign- and
domestically owned bank activities. They find weak evidence
that foreign bank entry into emerging markets contributes to
credit market stability.
A related issue is whether financial sector FDI can reduce the
magnitude of host-country cycles if foreign bank involvement
reduces the actual incidence of crises. The boom-bust cycles in
international capital flows are often derided as wreaking havoc
on economies, with lending booms contributing to financial
crises. Financial liberalization, by giving banks and other
intermediaries more freedom of action and allowing them to
take greater risks, is sometimes argued to increase the financial
fragility of an emerging market. Studies by Demirguc-Kunt and
Detragiache (1998, 2001), as well as work by Rojas-Suarez
(2001), find that financial liberalization (defined as interest rate
liberalization) has costs in terms of increased financial fragility,
especially in developing countries where the institutions
needed to support a well-functioning financial system are
generally not well established.
The transmission of shocks across borders is another issue
that bears on financial crises. Foreign banks may contribute to
contagion through common-lender effects, as documented in
Van Rijckeghem and Weder (2003). These banks could also be
subject to foreign cyclical flows. However, any private bank
20

See also Goldberg (2002), Dages, Goldberg, and Kinney (2000), and Horvath
(2002).

FRBNY Economic Policy Review / March 2007

9

with access to foreign loanable funds can be affected similarly:
foreign cycles have been shown to affect the lending and
deposit bases of domestically and foreign-owned private banks
in emerging markets (Crystal, Dages, and Goldberg 2001).
More evidence is needed on the question of whether foreign
banks can, and do, receive additional capital from their head
offices in times of stress. Accordingly, this topic warrants more
rigorous study.
On the issue of crises, it is worth noting that foreign banks
may contribute to domestic financial stability by operating
within a country’s borders, rather than from abroad. If flight to

Foreign banks may contribute to domestic
financial stability by operating within a
country’s borders, rather than from abroad.

quality occurs in stress periods, it may be better for domestic
depositors to keep their money within the domestic financial
system, to be reintermediated locally, rather than leave the
country through capital flight. Peria and Schmukler (1999)
document that depositors recognize differences in the health
and efficiency of banks and move their assets to better
functioning ones or demand higher deposit rates. Locally
generated claims from foreign-owned banks substitute in part
for cross-border flows, with the latter occasionally being more
volatile.21

6. FDI and Host-Country
Institutional Development
In theory, real-side and financial sector foreign direct
investment can play a causal role in host-country institutional
development. The direct role of real-side FDI in host-country
institutional reform has not been well documented. Financial
21

More evidence is needed on the extent to which substitutability exists
between cross-border flows and locally generated claims by foreign branches
and subsidiaries. There are direct parallels between these questions in financial
FDI and questions long raised in the area of real-side FDI. In manufacturing
industries, there is no clear pattern of substitutability compared with
complementarity in bilateral flows between Latin American countries and the
United States. However, manufacturers in different countries may engage in
distinct FDI strategies. Research shows that FDI from Japan enhanced Japanese
exports to Southeast Asian countries, consistent with intermediate input trade,
while FDI from the United States substituted for exports from the United States
to Southeast Asia. FDI from these two sources did not systematically influence
exports from the United States or Japan to Latin American countries (Goldberg
and Klein 1998, 2001).

10

Financial Sector FDI

sector FDI has been more closely linked to institutional
reforms, but systematic analysis of this response is warranted.
The recent availability of rich institutional databases, such as
the World Bank database on Bank Regulation and Supervision,
may facilitate such testing.22
Nevertheless, institutions in developing countries can
respond positively to financial sector FDI. Crystal, Dages, and
Goldberg (2001) show that foreign-owned banks appear to
contribute to the overall soundness of local banking systems by
screening and treating problem loans more aggressively. If
foreign entry spurs additional regulatory improvements, the
risk of financial crisis declines. Demirguc-Kunt, Levine, and
Min (1998) relate foreign bank entry per se to the probability
of a banking crisis. The foreign bank presence was found to
have a negative and statistically significant coefficient, leading
the authors to conclude that, after they controlled for other
factors likely to produce banking crises, greater foreign bank
participation had a stabilizing effect.
Mishkin (2005) argues that financial globalization should be
an important supporting force behind institutional reform.

The entry into emerging markets of foreign
banks that are healthier than domestic
banks implicitly allows a country to import
stronger prudential regulation and
increase the soundness of the local
banking sector.

He contends that domestic institutions, facing competition
from abroad, will seek new customers to stay in business.
For lending to be profitable, domestic banks will require
information to screen and monitor their customers. Better
accounting standards and disclosure requirements, as well as
a more efficiently managed legal system, will be consistent with
continued domestic bank profitability. Foreign-owned banks
will also be a constituency supporting these positive reforms
because, as outsiders, they would not have access to the same
information as their domestic competitors.
Numerous studies assert that financial sector FDI spurs
improvements in bank supervision, with regulatory spillovers.
The entry into emerging markets of foreign banks that are
healthier than domestic banks implicitly allows a country to
import stronger prudential regulation and increase the
soundness of the local banking sector. In Argentina, Chile, and
22

See Barth, Caprio, and Levine (2002).

Colombia, for example, foreign banks have contributed to
enhanced domestic financial stability by engaging in more
aggressive risk management techniques (Crystal, Dages, and
Goldberg 2001). Calomiris and Powell (2001) argue that

Foreign bank entry also raises issues of
competition policy within host-country
banking systems.

Argentina’s bank regulatory system in the late 1990s was one
of the most successful among emerging market economies.
Reliance on market discipline was viewed as playing an
important role in prudential regulation by strengthening risk
management among banks.
The transition to improved local supervision, however,
might be bumpy. Major international banks may try to build
market share by offering a variety of new financial products,
including over-the-counter derivatives, structured notes, and
equity swaps. These new derivative products can provide
greater opportunities for hedging risks. Yet some new products
may also be used to evade prudential regulations and take on
excess risks, especially in countries with weak financial systems
and underprepared supervisors (Garber 2000). One clear
implication is that local supervisors in emerging markets may
have to invest in upgrading their skills in order to evaluate
more efficiently the use and effects of new products. Other
challenges for supervisors arise in the context of relationships
with parent banks, and may depend on whether the foreign
entry is accomplished through branches or subsidiaries.23
Foreign bank entry also raises issues of competition policy
within host-country banking systems. While the actual
experiences of host countries have been researched extensively
(see Bank for International Settlements [2001] and the
volume’s overview by Hawkins and Mihaljek), on average
consolidation has occurred without deterioration of the
competitiveness of a country’s financial services industry
(Gelos and Roldos 2002).
Another challenge can arise if a country’s financial services
industry becomes highly concentrated, in which case banks
may exert monopolistic pricing tendencies more extensively.
If foreign banks are among the few surviving banks, local
regulators may be tempted to conclude that these banks bear
specific responsibility for adverse outcomes. Yet in many cases,

foreign bank entry is part of a larger scale restructuring and
recapitalization of the emerging market financial system. More
concentrated market power may have occurred regardless of
whether owners were foreign or domestic. Even with
monopolistic pricing, there may be other benefits through scale
economies and improved services that are by-products of
consolidation. These issues challenge regulators to engage in
careful cost-benefit analyses and policy reactions.

7. Fiscal and Tax Questions Raised
by FDI
Public finance decisions concerning multinationals24 and hostcountry governments have received considerable analytical
attention, particularly in terms of real-side FDI. One pertinent
and very important issue is incentives offered to foreign
investors to attract them to a country or a locality within a
country. Such efforts have been extensive. As reported by the
United Nations Conference on Trade and Development (2001,
pp. 6-7), nearly 95 percent of the almost 1,200 changes in
national FDI legislation from 1991 through 2000 were
favorable to foreign investors, sometimes taking the form of
special incentives such as lower income taxes, income tax
holidays, and import duty exemptions for foreign enterprises
as well as subsidies for infrastructure.
Researchers and policymakers correctly ask whether,
quantitatively, the benefits of real-side FDI justify the costs.
When governments compete actively against each other for
FDI, profits from the investments are shifted from the host
country to multinational enterprises (Oman 2000).25 While
debate over this point is ongoing, Blomstrom and Kokko
(2003) provide a compelling argument that the types of longterm benefits generated by FDI may not justify the short-term
costs. These benefits include the positive spillovers between
firms and across sectors that researchers continue to identify.
To compete effectively, governments may make long-term
financial commitments that are excessive when compared with
the employment and political gains received in the short term.
Strong promotion efforts show that the government is
actively doing something to strengthen employment,
productivity, growth, or some other policy objective . . . .
Another reason is that some of the perceived benefits (in
particular, the jobs created by FDI) are easily observable
while some of the costs (particularly related to tax breaks
and fiscal incentives) are distributed over long periods of
time and hard to measure (Blomstrom and Kokko 2003).

23

One recent study considers the stability of cross-border compared with FDI
flows in banking in Central and Eastern Europe (Buch, Kleinert, and Zajc
2003). In preliminary work, the authors argue that FDI should have an
additional stabilizing feature because it should allow banks in these countries
to draw on the liquidity buffer of their headquarters abroad. Branches and
subsidiaries are not distinguished in the conceptual presentation.

24

See Feldstein, Hines, Jr., and Hubbard (1995).
Similar arguments apply to states within countries that compete against each
other to attract new production facilities.

25

FRBNY Economic Policy Review / March 2007

11

The same questions, to date applied almost exclusively to
real-side FDI, are also pertinent to the financial sector. We have
suggested a number of important dimensions along which
financial sector FDI is expected to have implications distinct
from other forms of FDI. These include reduced incidence of
crisis, moderated business cycle magnitudes, and institutional
development. Given the welfare consequences of business
cycles and crises, the calculus of the costs and benefits of
actively promoting and subsidizing such foreign entry is a topic
worthy of further study. Analysis of the extent to which host
markets encourage or tax foreign entrants, given their

To compete effectively, governments may
make long-term financial commitments
that are excessive when compared with
the employment and political gains
received in the short term.

implications for local markets, could be explored for entrants
during unstable as well as normal periods. If such analysis
weighs strongly in favor of encouraging financial sector FDI
from healthy parent banks, the arguments could satisfy some of
the critics concerned about “fire-sale” terms on local market
assets. The quantities that have been implicitly or explicitly put
on the table for attracting financial sector FDI should be
systematically studied for the lessons they can offer.

8. Conclusion
Our selective survey of the literature on foreign direct
investment supports our argument that multinationals and
FDI in emerging markets generally have important effects on
the host countries, with some effects being particularly notable
in financial services industries. These effects take the form of
changes in allocative efficiency, technology transfer and
diffusion, wage spillovers, institution building, altered
macroeconomic cycles, and overall economic stability.
We find that FDI is typically associated with improved
allocative efficiency. This improvement can occur when
foreign investors enter industries with high entry barriers and
then reduce local monopolistic distortions. The presence of
foreign producers may also increase technical efficiency:
heightened competitive pressure or some demonstration effect
may spur local firms to use existing resources more effectively.

12

Financial Sector FDI

FDI is also shown to be associated with higher rates of
technology transfer and diffusion as well as with greater wages.
While there is evidence of technological improvements from
FDI and a presumption that such investment will consequently
stimulate economic growth, the strength of these effects is
disputed. FDI into host countries also induces higher wages,
although these wage effects are sometimes limited to the
foreign-owned production facilities and do not spill over more
broadly.
Institutional change is another potential implication of FDI.
At least in the context of financial services, the outcome is
expected to be in the direction of improved regulation and
supervision, with such improvements potentially sought by the
remaining domestically owned banks as well as by the foreignowned banks. These improvements occasionally occur with a
lag, as supervisors in the host countries at first may not be
prepared to evaluate the new products and processes
introduced by foreign entrants.
FDI can also affect crisis and noncrisis macroeconomic
conditions. Foreign banks are procyclical lenders in emerging
markets. Domestic, privately owned banks also are procyclical
lenders, so the presence of foreign banks does not negatively
affect the boom-bust cycle in lending and international capital
flows. Foreign entrants may introduce a more diversified
supply of funds, in principle making loan supply less
procyclical but also more sensitive to foreign fluctuations.
Foreign bank entry into emerging markets reduces the
incidence of crises, but enhances the potential for greater
contagion through common-lender effects. The contagion
problem is reduced when foreign banks have a stronger
subsidiary presence, as opposed to supporting local markets
through cross-border flows.
The employment and growth effects of financial sector FDI
are more subtle than other effects,26 depending in part on
whether the investment is greenfield or merger and acquisition.
In the latter case, the effects also depend on whether the
acquired institution was financially sound or in need of
restructuring, regardless of the nationality of the new owners.
However, if financial intermediation improves, financial sector
FDI should support greater employment and growth prospects.
The institutional effects of financial sector FDI are
potentially clearer and quite positive. Financial sector FDI from
well-regulated and well-supervised source countries can
support emerging market institutional development and
governance, improve a host country’s mix of financial services
and risk management tools, and potentially reduce the
incidence of sharp crises associated with financial
26

If FDI evidence in manufacturing is a guide, Kokko (1994) shows that the
incidence of spillovers is associated with a host country’s ability to absorb
them.

underdevelopment in emerging markets. Yet this type of
investment can initially pose formidable challenges to local
supervisors, who may need to develop expertise in the practices
and products introduced into their economies.
Finally, whether governments should actively pursue FDI
through subsidies and other incentive programs is a subject of
strong debate. There is some skepticism in the literature on
real-side FDI about whether the benefits of investment to the
host country justify the sometimes large incentives offered to
attract foreign investors. The special features of financial sector
FDI add other dimensions to this debate, and accordingly
warrant further exploration.

These findings will hopefully contribute to discussions
about whether developing countries should open their
financial sectors to foreign entrants. The evidence suggests
that many emerging markets have responded with strong
affirmative statements in the past decade. It also suggests that
the benefits of financial sector FDI can be substantial enough
for a country to encourage and support entry from wellregulated and healthy banks. Careful discussion and further
rigorous analysis will no doubt continue to inform these
important issues.

FRBNY Economic Policy Review / March 2007

13

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Cycles: Is Vertical Specialization the Missing Link?” American
Economic Review 91, no. 2 (May): 371-5.

Lipsey, R. E. 2000. “Inward FDI and Economic Growth in Developing
Countries.” United Nations Conference on Trade and
Development Transnational Corporations 9, no. 1 (April):
67-96. Geneva: The United Nations.
Lipsey, R. E., and F. Sjoholm. 2003. “Foreign Firms and Indonesian
Manufacturing Wages: An Analysis with Panel Data.”
NBER Working Paper no. 9417, December.
Markusen, J. R. 1995. “The Boundaries of Multinational Enterprises
and the Theory of International Trade.” Journal of Economic
Perspectives 9, no. 2 (spring): 169-89.
Markusen, J. R., and A. J. Venables. 1999. “Foreign Direct Investment
as a Catalyst for Industrial Development.” European Economic
Review 43, no. 2 (February): 335-56.
Mihaljek, D. 2006. “Privatisation, Consolidation, and the Increased
Role of Foreign Banks.” In The Banking System in Emerging
Economies: How Much Progress Has Been Made? 41-66.
BIS Papers, no. 28, August. Available at <http://www.bis.org/
publ/bppdf/bispap28c.pdf>.
Mishkin, F. 2005. “Is Financial Globalization Beneficial?”
NBER Working Paper no. 11891, December.
Oman, C. 2000. Policy Competition for Foreign Direct
Investment: A Study of Competition among Governments
to Attract FDI. Paris: Organisation for Economic Co-operation
and Development.
Peria, M. S. M., and S. Schmukler. 1999. “Do Depositors Punish Banks
for ‘Bad’ Behavior? Market Discipline in Argentina, Chile, and
Mexico.” World Bank Policy Research Working Paper no. 2058,
February.
Prasad, E., K. Rogoff, S.-J. Wei, and M. A. Kose. 2003. “Effects of
Financial Globalization on Developing Countries: Some Empirical
Evidence.” IMF Occasional Paper no. 220, September.

La Porta, R., F. Lopez-de-Silances, and A. Shleifer. 2002. “Government
Ownership of Banks.” Journal of Finance 57, no. 1 (February):
265-301.

Rajan, R. G., and L. Zingales. 1998. “Financial Dependence and
Growth.” American Economic Review 88, no. 3 (June): 559-86.

Levine, R., N. Loayza, and T. Beck. 2000. “Financial Intermediation
and Growth: Causality and Causes.” Journal of Monetary
Economics 46, no. 1 (August): 31-77.

Rodriguez-Clare, A. 1996. “Multinational Linkages and Economic
Development.” American Economic Review 86, no. 4
(September): 852-73.

16

Financial Sector FDI

References (Continued)

Rojas-Suarez, L. 2001. “Rating Banks in Emerging Markets: What
Credit Rating Agencies Should Learn from Financial Indicators.”
Institute for International Economics Working Paper no. 01-6,
May.
Romer, P. 1993. “Idea Gaps and Object Gaps in Economic
Development.” Journal of Monetary Economics 32,
no. 3 (December): 543-73.
Sapienza, P. 2002. “Lending Incentives of State-Owned Banks.”
Unpublished paper, Northwestern University.
Skipper, H., Jr. 2001. “Liberalization of Insurance Markets: Issues and
Concerns.” In R. Litan, P. Masson, and M. Pomerleano, eds., Open
Doors: Foreign Participation in Financial Systems in
Developing Countries, 105-56. Washington, D.C.: Brookings
Institution Press.

Turner, P. 2006. “The Banking System in Emerging Economies: How
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publ/bppdf/bispap28a.pdf>.
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Foreign Bank Entry on the Philippine Domestic Banking Market.”
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483-509.

The views expressed are those of the author and do not necessarily reflect the position of the Federal Reserve Bank of New York
or the Federal Reserve System. The Federal Reserve Bank of New York provides no warranty, express or implied, as to the
accuracy, timeliness, completeness, merchantability, or fitness for any particular purpose of any information contained in
documents produced and provided by the Federal Reserve Bank of New York in any form or manner whatsoever.
FRBNY Economic Policy Review / March 2007

17

Warren B. Hrung

An Examination
of Treasury Term
Investment Interest Rates
• The U.S. Treasury, through its Term
Investment Option (TIO) program, lends
excess cash balances to banks at interest
rates determined by single-rate auctions.

• An important issue in TIO auctions is whether
the Treasury receives a market rate of return
on TIO funds.

• An analysis of the spread between rates on
TIO auctions and rates on mortgage-backedsecurity (MBS) repos suggests that for small
auction sizes, TIO rates are comparable to
market rates, except on offerings with term
lengths of fewer than five days.

• The study also finds that a more compressed
auction schedule, in which the Treasury
announces and auctions TIO funds on the
same day, does not adversely affect TIO rates;
thus, banks appear to be indifferent to more
advance notice of auctions.

Warren B. Hrung is a senior financial analyst in the Markets Group
of the Federal Reserve Bank of New York.
<warren.hrung@ny.frb.org>

1. Introduction

T

he Term Investment Option (TIO) program is a cash
management tool of the U.S. Treasury Department.
Through TIO, which is part of the broader Treasury Tax and
Loan (TT&L) program, the Treasury lends funds to depository
institutions for a set number of days. The rate that the Treasury
receives is determined via a single-rate auction format.
An important issue in TIO auctions is whether the interest
rates received by the Treasury are comparable to market rates.
In this article, we compare TIO rates with rates on mortgagebacked-security (MBS) repurchase (repo) agreements. MBS
repo rates are the closest benchmark for TIO rates in several
respects: depository institutions can obtain funds using both
types of transactions, the transactions are collateralized, and
the eligible collateral is similar. We study the 166 auctions held
from November 2003, when TIO first became an official
Treasury cash management facility, to February 2006.1

1

TIO began as a pilot in April 2002. We do not examine the first twenty-seven
auctions from April 2002 to October 2003. The structure of the 166 auctions
we study is similar to the structure of future TIO auctions. During the TIO
pilot, auctions tended to be held in the latter part of the year, so there were
extended periods with no auctions.

The author thanks two anonymous referees, Chris Burke, Seth Carpenter, Chris
Kubeluis, John McGowan, Glen Owens, John Partlan, Ryan Rials, Paul Santoro,
Charles Sims, Barbara Wiss, the Treasury Relations and System Support
staff of the Federal Reserve Bank of St. Louis, the staff of the Office of the Fiscal
Assistant Secretary of the U.S. Treasury Department, and seminar participants at
the Federal Reserve Bank of New York for helpful comments. Geddes Golay,
Peter Hennessy, and Hang Pham provided valuable research assistance.
The views expressed are those of the author and do not necessarily reflect the
position of the Federal Reserve Bank of New York or the Federal Reserve System.
FRBNY Economic Policy Review / March 2007

19

TIO auctions can shed light on bidding behavior in general,
because they vary along more dimensions than traditional
Treasury debt auctions. For example, TIO auctions are not held on
a regular basis and their size and term length vary. Typical
Treasury debt auctions, by comparison, are held on a regular
schedule,2 and the amount auctioned is usually the only variable.
A key finding of our work is that for small auction sizes,
TIO interest rates are fairly comparable to MBS repo rates for
term lengths of five days or more. However, shorter term
lengths result in the Treasury receiving lower TIO rates relative
to market rates. We also observe a negative relationship
between the size of an auction and the spread between the TIO
rate and the MBS repo rate. Finally, a more compressed auction
schedule, in which the Treasury announces and auctions TIO
funds on the same day, does not adversely affect TIO rates. This
finding suggests that banks are indifferent to more advance
notice of TIO auctions.
Our study proceeds as follows. In Section 2, we provide
background information on the TT&L program, term
investments, and repo transactions. Our data and our
regression framework are presented in Section 3, while
regression results can be found in Section 4. In Section 5,
we draw conclusions.

2. Background
2.1 The Treasury Tax and Loan Program
Treasury funds are held either at Federal Reserve Banks (the
Fed balance) or private depository institutions in what is
known as the Treasury Tax and Loan program (see Garbade,
Partlan, and Santoro [2004] for a discussion of recent
innovations in Treasury cash management). The Fed balance
does not earn explicit interest,3 while balances held at private
depository institutions, which can be withdrawn on demand,
earn the TT&L rate, which is the weekly average overnight
federal funds rate less 25 basis points.4 Depository institutions
specify the maximum TT&L balances they are willing to hold,
and the balances must be collateralized. If balances exceed the
lesser of the specified limit or the collateral value of assets

pledged by the institution, the excess is transferred to a
Treasury account at the Federal Reserve Bank of St. Louis.
There are three types of depository institutions in the TT&L
program: collector institutions, which collect tax payments and
transfer them to Treasury accounts at District Federal Reserve
Banks; retainer institutions, which collect and hold funds until
balances exceed their limit or collateral or until the Treasury

The management of Treasury funds
directly affects the conduct of monetary
policy, as the net movement of funds
into and out of the banking sector
generally has to be offset by open
market operations.
withdraws the funds; and investor institutions, which are
similar to retainer institutions but also accept direct
placements of funds from the Treasury.
The management of Treasury funds directly affects the
conduct of monetary policy, as the net movement of funds into
and out of the banking sector generally has to be offset by open
market operations. Payments by the U.S. government are made
from the Fed balance, while some tax receipts flow directly into
the Fed balance. Depository institutions in the TT&L program
collect the bulk of tax receipts. The Fed balance fluctuates daily
as tax payments are received and outlays are paid. An increase
in the Fed balance drains reserves available in the banking
system, while a decrease adds them. The Treasury typically
seeks to maintain a relatively stable Fed balance of $5 billion,
with the remainder of its funds held at private depository
institutions. The target balance is achieved through withdrawals from and deposits to the depository institutions. The
maintenance of a stable Fed balance prevents changes in the
balance from affecting the supply of bank reserves and
minimizes the need for offsetting open market operations.
Assets acceptable as collateral in the TT&L program range
from Treasury securities to insured student loans (Table 1).
A lower collateral value is assigned to less liquid and less
creditworthy assets.5 Collateral must be held either at a Federal
Reserve Bank or at a Treasury-approved third-party

2

For example, four-, thirteen-, and twenty-six-week Treasury bills are
auctioned every week.
3
As funds in the Fed balance reduce the supply of bank reserves, open market
operations to purchase Treasury securities are required to offset this drain. The
interest earned on these securities is included in Federal Reserve earnings,
which are remitted weekly to the Treasury. Thus, implicit interest is earned by
the Treasury on the Fed balance.

20

An Examination of Treasury Term Investment Interest Rates

4

The weekly average rate is computed for a seven-day interval, beginning on a
Thursday and ending the following Wednesday, with the rate for a Saturday,
Sunday, or holiday taken as the rate for the preceding business day. The weekly
average rate less 25 basis points is used to calculate a daily interest factor that is
applied to the daily average amount of TT&L balances for each ThursdayWednesday cycle, and interest is payable on the following Thursday.

Table 1

Acceptable and Unacceptable Collateral in the Treasury Tax and Loan Program
Panel A: Acceptable Collateral
Category 1

Obligations issued and fully insured or guaranteed by the U.S. government or a U.S. government agency. (See Category 4 for insured or
guaranteed educational loans.)

Category 2

Obligations of government-sponsored enterprises and government-sponsored corporations of the United States that under specific statute
may be accepted as security for public funds.

Category 3

Obligations issued or fully guaranteed by international development banks (acceptable only if denominated in U.S. dollars).

Category 4

Insured student loans or notes representing educational loans insured or guaranteed under a program authorized under Title IV of the
Higher Education Act of 1965, as amended, or Title VII of the Public Health Service Act, as amended. (Securities issued by the Student
Loan Marketing Association are included in Category 2.)

Category 5

General obligations issued by the states of the United States and by Puerto Rico.

Category 6

Obligations of counties, cities, or other U.S. government authorities or instrumentalities that are not in default on payments on principal
or interest and that may be purchased by banks as investment securities under the limitations established by appropriate
federal bank regulatory agencies.

Category 7

Obligations of domestic corporations that may be purchased by banks as investment securities under the limitations established
by appropriate federal bank regulatory agencies.

Category 8

Qualifying commercial paper, commercial and agricultural loans, and bankers’ acceptances approved by the Federal Reserve System at the
direction of the Treasury.

Category 9

Qualifying publicly issued asset-backed securities that are Aaa/AAA rated by at least one nationally recognized statistical rating agency
and approved by the Federal Reserve System at the direction of the Treasury.

Panel B: Unacceptable Collateral
Common and preferred stock.
Consumer paper or consumer notes.
Foreign-currency-denominated securities.
Mutual funds.
Construction loans.
Obligations issued by the pledging bank or by affiliates of the pledging bank.
Obligations of foreign countries (that is, sovereign debt).
Collateralized bond obligations, collateralized loan obligations, and collateralized mortgage-backed securities except as otherwise noted.
Real estate mortgage-backed securities (one-to-four-family mortgages are acceptable only if held in a borrower-in-custody arrangement
to secure special direct investments).
Panel C: Stripped and Zero-Coupon Securities
Securities offered in stripped, zero, or residual forms are acceptable only when market prices are available.
U.S. government agency securities may be stripped into their separate components and are acceptable only when market prices are available.
Source: U.S. Treasury Department (<http://www.publicdebt.treas.gov/gsr/gsrttlaccxx0205.pdf>).

custodian.6 During months with heavy tax inflows, balances at
depository institutions can exceed available collateral, resulting

in a transfer of these excess funds to the Fed balance and
potentially causing the balance to exceed the $5 billion target.

5

6

Refer to <http://www.easysaver.gov/instit/statreg/collateral/
collateral_taxandloantablel.pdf> for the margins applied to the
various types of collateral.

Depository institutions can serve as third-party custodians; currently,
the Depository Trust Company is the only non-depository institution
approved by the Treasury.

FRBNY Economic Policy Review / March 2007

21

2.2 The Term Investment Option Program
The TIO program is another option within the TT&L program
for placing Treasury funds with depository institutions.
It began on a pilot basis in April 2002 and was expanded in
November 2003.7 TIO offers greater certainty than the regular
TT&L program about the amount of funds invested and the
length of time funds will be invested.8 Participation is limited
to TT&L depositories that have executed a TIO agreement.9
The only publicly available information on the number of
institutions in the TIO program is as of September 2004; at that
time, forty-three institutions were participating.10 Depository
institutions in the TIO program are not required to bid in TIO
auctions, and the Treasury reserves the right not to place funds.
Depository institutions bid on TIO funds in auctions that
follow a single-rate format. The identity of bidding institutions
is known to the Treasury, but funds are allocated on the basis
of auction bids. Participating institutions submit bids
indicating the maximum rate they would pay on a specified
quantity of funds. Institutions may submit multiple bids for
differing amounts and rates.11 The interest rate that fills the

One of the Treasury’s motivations for
initiating TIO [the Term Investment Option
program] was to try to earn a market rate
of return on its excess cash balances.
auction, known as the stop-out rate, is determined, and this
rate applies to all successful bids (those at or above the stopout rate). Bids at higher rates are filled in full and bids at the
stop-out rate may be prorated. A single institution is limited
to 50 percent of the announced amount.
One of the Treasury’s motivations for initiating TIO was to
try to earn a market rate of return on its excess cash balances.
On average, for the first 193 auctions TIO rates have been
about 16 basis points higher than TT&L rates and 6.5 basis
7

TIO no. 28 was the first TIO auction after the program became an official cash
management tool of the Treasury.
8
The Treasury reserves the right to call back funds placed in the TIO program
before maturity, but it would be assessed a penalty in the form of interest.
Moreover, such a call would likely result in reduced future participation in the
program, and an early call has never occurred.
9
All types of TT&L depositories (collector, retainer, and investor institutions)
are eligible to participate in the TIO program.
10
See <http://www.fms.treas.gov/tip/TIO-Presentation.ppt>. There are approximately 8,000 TT&L depositories.
11
There is a $10 million minimum for bids. There is no limit on the number of
bids that may be submitted by a single institution.

22

An Examination of Treasury Term Investment Interest Rates

points lower than comparable MBS repo rates (the calculation
is described below).
Another motivation was to increase TT&L capacity
following the federal budget surpluses of the late 1990s and
2000-01. The surpluses occasionally resulted in Treasury
balances available for investment with depository institutions
exceeding TT&L collateral. As a result, Fed balances exceeded
the $5 billion target and drained reserves from the banking
system. Open market operations by the Federal Reserve were

After the TIO program became an official
cash management tool, the Treasury
began placing more term investments for
greater cumulative and average amounts.
required to offset this drain. While federal budget surpluses are
currently not an issue, TT&L capacity constraints are still
important during months with large tax inflows, such as April.
TIO collateral requirements are less restrictive than those
for the regular TT&L program in the sense that collateral such
as commercial loans can be held on the premises of the
depository institution (or an affiliate) in a borrower-incustody arrangement instead of at a Federal Reserve Bank.
While collateral held in such an arrangement is acceptable only
on an auction-by-auction basis, these loans typically have been
accepted since June 2002.12
In the regular TT&L program, because commercial loans
must generally be held at a Federal Reserve Bank, depositories
are less likely to pledge these loans as collateral. As a result, even
though depository institutions do not have to bring in new
collateral to back term investments, allowing commercial loans
to be held on depository premises leads institutions to bring in
additional collateral that was previously unpledged. Capacity
for the TT&L system as a whole is therefore increased. Requirements for all other collateral for TIO funds are similar to those
for TT&L collateral: the collateral must be held either at a
Federal Reserve Bank or at a Treasury-approved third-party
custodian.
According to data from the Federal Reserve Bank of
St. Louis, commercial loans comprise around 50 percent of
collateral pledged in the TIO program; Treasury, federal
agency, and corporate securities account for around 25 percent;
mortgage-backed securities represent about 10 percent;
and all other collateral make up the remaining 15 percent.
The corresponding percentages for the regular TT&L program
12

See <http://www.publicdebt.treas.gov/gsr/gsrcltio.htm> for information on
acceptable collateral for the TIO program.

Chart 1

Chart 3

Term Investment Option Auctions, Monthly Totals

Term Investment Option Auctions,
Monthly Average Amounts Placed

Number of auctions
16

Closest billions of dollars
16

14

14

12

12

10

10

8

8

6

6

4

4

2

2

0
2002

03

04

05

06

0
2002

Source: Author’s calculations, based on data from the U.S. Treasury
Department (<http://www.fms.treas.gov/tip>).

03

04

05

06

Source: Author’s calculations, based on data from the U.S. Treasury
Department (<http://www.fms.treas.gov/tip>).

Chart 2

Term Investment Option Auctions,
Monthly Total Amounts Placed
Billions of dollars
80
70
60
50
40
30
20
10
0
2002

03

04

05

06

Source: Author’s calculations, based on data from the U.S. Treasury
Department (<http://www.fms.treas.gov/tip>).

are approximately 3 percent, 10 percent, 60 percent, and
27 percent.
The Treasury sponsored 193 term investments through
February 2006.13 At that point, it faced a debt-limit crisis that

was not resolved until March 20, 2006. No TIO auctions were
held during this period, disrupting the typical schedule for
these auctions.14 Chart 1 displays the number of investments
each month since the program’s inception through February
2006. Term investments generally were relegated to the latter
half of the year for 2002 and 2003. After the TIO program
became an official cash management tool, the Treasury began
placing more term investments for greater cumulative
(Chart 2) and average (Chart 3) amounts. Chart 4 shows
that of the first 193 auctions, the largest single offering was
$18 billion, with most offerings being less than $7 billion. Term
lengths have varied from one day to as many as nineteen, but
very few have been greater than fifteen days (Chart 5).
While the main parameters of a TIO auction are under the
Treasury’s control, in deciding the size and term length of a
TIO auction the Treasury primarily relies on forecasts of future
cash balances, which are dependent on forecasts of tax receipts
and outlays. The Treasury also examines the expected forecast
errors, which are based on historical data. Naturally, forecast
errors for days further out are typically larger than errors over
one or two days. Term investment parameters are chosen so
that the Treasury’s remaining cash balances will likely be
sufficient to maintain the $5 billion Fed balance target during
the length of the term investment. As a result, TIO offering
announcements provide insight into the Treasury’s anticipated

13

The last TIO auctioned in February 2006 was no. 194, but auction no. 173 was
canceled “due to adjustments to cash balance projections” (<http://www
.fms.treas.gov/tip/auctions/HistoricalFinal05.pdf>).

14

Term investments are typically made during the second half of a month
(when receipts are greater) and in the first few days of the following month.

FRBNY Economic Policy Review / March 2007

23

Chart 4

Chart 5

Term Investment Option Auctions,
Distribution of Placement Sizes,
January 2002–February 2006

Term Investment Option Auctions,
Distribution of Term Lengths,
January 2002–February 2006
Number of auctions

Number of auctions
30

50

25

40

20
30
15
20
10
10

5
0

0
1

2

3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Term length (number of days)

4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Placement size (closest billions of dollars)

Source: Author’s calculations, based on data from the U.S. Treasury
Department (<http://www.fms.treas.gov/tip>).

Source: Author’s calculations, based on data from the U.S. Treasury
Department (<http://www.fms.treas.gov/tip>).

cash balances and, by implication, the Treasury’s borrowing
requirements.
If receipts are weaker than anticipated or outlays stronger
than anticipated, the Treasury can reduce the amount of funds
that it auctions from the amount that was announced.15 In the
extreme, the Treasury could auction no funds (that is, cancel
an auction). The Treasury does not reduce auction sizes after

Our analysis would be more complex if the Treasury set the
size and term length of TIO offerings based on rate-of-return
considerations. If the Treasury did exercise this discretion, it
may prefer to hold more (less) funds in regular TT&L balances
when the federal funds rate is trading significantly higher
(lower) than the target set by the Federal Open Market
Committee. This is because a higher effective federal funds rate
increases the TT&L rate. Table 2 presents simple regression
results for 2004-05 relating the percentage of total Treasury
funds held in the regular TT&L program with dummy variables
for cases when, on the previous day, the effective federal funds
rate traded 10 or more basis points higher or lower than the
target.16 The results show that the dummy variable coefficients
are not statistically significant; the Treasury does not hold more
funds in regular TT&L balances (and less in TIO balances)
when the federal funds rate is trading significantly higher
than the target and vice versa. Therefore, even though the
parameters of TIO auctions are under the Treasury’s control,
these results suggest that they are not set based on rate-ofreturn considerations.
Beginning in 2004, movements in term investment balances
began to parallel closely movements in total TT&L balances, as
the Treasury became more active in placing term investments.
Chart 6 shows monthly average total TT&L balances divided into

The Treasury occasionally compressed
the [auction] schedule into two days,
announcing and auctioning on the same day
and placing the funds the following day.
announcement in response to expectations of interest rates.
If receipts are stronger than forecasted or outlays weaker than
forecasted, the Treasury cannot increase the size of a given
auction after announcement. In the analysis below, auction size
amounts are based on the announced auction size, not the
actual amount that the Treasury auctions. The Treasury has
never altered the announced term length of a given auction.
15

Other reasons why amounts placed can be less than amounts announced
include collateral deficiencies and insufficient bids. Of the first 193 auctions,
there were 9 occasions on which the amount placed was less than the amount
announced.

24

An Examination of Treasury Term Investment Interest Rates

16

The effective federal funds rate can be found at <http://www.newyorkfed
.org>. Information on TT&L balances can be found in the Daily Treasury
Statement (<http://www.fms.treas.gov/dts>).

Table 2

Chart 6

Ordinary Least Squares Regression Results

Monthly Average Treasury Tax and Loan (TT&L)
Program Balances

Dependent Variable:
Regular TT&L
Balance/Total Balances
Intercept
1 (effective fed funds rate minus target t-1 > 9 bp)
1 (effective fed funds rate minus target t-1 < -9 bp)
R2

0.36
(23.151)
-0.02
(-0.559)
-0.05
(-0.858)
0.002

Billions of dollars
50

Regular TT&L balances
Term investment option balances

40
Total TT&L balances
30

20

Source: Author’s calculations.
Notes: t-statistics, in parentheses, are based on Newey-West (1987)
standard errors. The number of observations is 503. The period
examined is January 5, 2004, to December 30, 2005. TT&L is
Treasury Tax and Loan program; bp is basis points.

10

0
2002

03

04

05

06

Source: Author’s calculations, based on U.S. Treasury Department,
Daily Treasury Statement (<http://www.fms.treas.gov/dts>).

regular TT&L balances and TIO balances. During 2002 and
2003, there is very little correlation between total TT&L balances
and term investment balances. The correlation coefficient
between the balances for 2002-03 is -.03, while the coefficient
for 2004 is .79. The coefficient for 2005 is even higher, at .93.
For the time period studied here, the term investment
auction process typically took place over three business days.
This process is coordinated by the Federal Reserve Bank of
St. Louis as the fiscal agent for the Treasury:
• Day t: The Treasury announces that it will auction
$X billion for Y days.
• Day t+1: Participating institutions bid on the funds and
the Treasury announces the results.
• Day t+2: Funds are placed and the Fed balance falls by
$X billion.
• Day t+2+Y: $X billion plus interest is returned to the Fed
balance.
The Treasury occasionally compressed the schedule into
two days, announcing and auctioning on the same day and
placing the funds the following day.17 A compressed schedule
allows the Treasury to take into account more information on
cash flows before deciding on the auction size. The Treasury
has also occasionally auctioned two term investments of
different amounts and lengths on the same day.

2.3 Repurchase Transactions
A repo is essentially a purchase and subsequent sale of an asset
with the price differential reflecting the interest on the
transaction. The transaction resembles a collateralized loan, as
the lender of funds receives an asset as collateral to protect
against default. A general collateral (GC) repo transaction does
not involve a specific security within a class of securities, such
as Treasury, federal agency, and mortgage-backed securities.
For example, all Treasury bills, notes, and bonds (including
inflation-indexed securities) are eligible for a GC Treasury repo
transaction. GC repo rates are quoted for various lengths, such
as overnight, one week, two weeks, and three weeks.
TT&L depositories that participate in the TIO program and
bid on TIO funds can also obtain funds via repos; therefore,
repo rates can be considered a benchmark for TIO rates.18
Acceptable collateral for mortgage-backed-security repos is
also most similar to collateral pledged in the TIO program.
Acceptable collateral for GC MBS repos consists of Treasury
securities, non-mortgage-backed securities from agencies such as
the Federal National Mortgage Association and the Federal Home
Loan Mortgage Corporation, and mortgage-backed securities.
18

17

Since May 2006, the Treasury has moved to a standard process of announcing
and auctioning TIO funds on the same day.

From the Treasury’s standpoint, the TT&L rate is the proper rate against
which to compare the TIO rate because the TT&L rate represents what TIO
funds would have earned had they not been placed in the TIO program.
However, TT&L rates are not known at the time of TIO auctions.

FRBNY Economic Policy Review / March 2007

25

Repos can settle either as a delivery-versus-payment (DVP)
transaction or via a tri-party clearing arrangement. In the
former, collateral and funds are exchanged directly between
counterparties. In the latter, the transaction is conducted
through a third-party clearing bank (see Garbade [2006, p. 38]).
There are several benefits to a tri-party repo compared with a
DVP repo. For example, in a tri-party repo, the clearing bank,
instead of the counterparties, is responsible for the settlement
of funds and collateral. In addition, specific collateral does not

TT&L [Treasury Tax and Loan] depositories
that participate in the TIO program and
bid on TIO funds can also obtain funds
via repos; therefore, repo rates can be
considered a benchmark for TIO rates.

have to be allocated when the counterparties agree on the
transaction amount. Also, many different pieces of collateral
can be cleared together. Most MBS repos are tri-party
transactions, as the transfer of MBS collateral, which typically
consists of various heterogeneous securities, is potentially very
burdensome.19

during the pilot program. For example, TIO auctions now
occur more frequently than they did during the pilot program.
X1,…,XN represent the independent variables that influence
the TIO-MBS repo rate spread (the spread). These include the
size of the term investment auction and the term length. The
coefficients to be estimated are represented by α and the β s ,
and ε represents a random error term.
One complication when calculating comparable market
rates is that MBS repo rates are not observed for term intervals
other than overnight, one week, two weeks, etc., so exact
comparisons of rates are not possible for TIO term lengths of
two to six days, eight to thirteen days, etc. In addition, implied
forward rates are the appropriate benchmark because TIO
funds are placed on the next business day after the day of
auction. In contrast, a repo transaction typically starts on the
trade date.
We calculate comparable MBS repo rates in two steps. First,
we compute repo rates for a length of time equal to t+k days,
where t is the number of days from auction to placement and k
is the term length.21 We calculate these rates by linearly
interpolating comparable rates using the MBS repo term
structure.
For example, TIO no. 54 was auctioned on September 14,
2004, was issued on September 15, 2004, and matured on
September 27, 2004, for a term length of twelve days, so that

One complication when calculating
comparable market rates is that MBS
[mortgage-backed-security] repo rates are
not observed for term intervals other
than overnight, one week, two weeks, etc.,
so exact comparisons of rates are not
possible for TIO term lengths of two to
six days, eight to thirteen days, etc.

3. Data and Regression Framework
Our regression framework is as follows:20
TIO - MBS repo ratei spread = α + β 1 X 1, i + … + β N XN, i + ε i
2
ε i ∼ N ( 0, σε ) ,
where the subscript i represents the TIO auction number. We
analyze auctions after TIO became an official Treasury cash
management tool (those after no. 27) through February 2006,
for a total of 166 auctions. Auctions held in this sample period
are more similar to the way in which TIO auctions are likely to
be structured and conducted in the future than auctions held
19

Special thanks to John McGowan for his insights into DVP and tri-party
repos. For more on repo markets, see Meulendyke (1998, pp. 101-4).
20
The data on term investment auctions studied here are publicly available.
See <http://www.wrightson.com/treasury/data/tio> (registration required)
or <http://www.fms.treas.gov/tip>. These websites contain information
on dates of announcement, auction, placement, and maturity; the amount
auctioned; and the TIO auction award rate (the TIO rate). Comparable
MBS repo rates are calculated from the opening MBS repo rate, which
can be obtained via Bloomberg.

26

An Examination of Treasury Term Investment Interest Rates

t = 1 and k = 12. The one-week MBS repo rate on the day of
auction, September 14, 2004, was 1.55 percent and the twoweek MBS repo rate was 1.62 percent. The difference between
these two rates (.07 percent) is multiplied by the number of
days within the seven-day interval between two weeks and one
week that is covered by t+k, (13-7)/7.22 This product is added
to the one-week MBS repo rate to arrive at the thirteen-day
MBS repo rate for TIO no. 54 (see Chart 7):
21

The parameter t can take on values greater than 1 because of weekends and
holidays.

Chart 7

Table 3

Interpolation of Thirteen-Day Mortgage-BackedSecurity (MBS) Repo Rate for Term Investment
Option No. 54

Summary Statistics

Mean

Standard
Deviation

TIO-TT&L rate spread (basis points)
TIO-MBS repo rate spread (basis points)

16.34
-6.14

7.12
6.99

Size (billions of dollars)
Term (days)
Term investments outstanding
on day of placement (billions of dollars)
Days since last TIO auction

5.98
8.01

3.74
4.36

14.99
5.04

13.02
7.12

Interest rate (percent)
1.64

Two-week MBS repo
rate = 1.62 percent

1.62
1.60

Interpolated
thirteen-day MBS repo
rate = 1.61 percent

1.58
1.56
1.54

1 (announcement day = auction day)
1 (first auction if two auctions on same day)
1 (second auction if two auctions on same day)

One-week MBS repo
rate = 1.55 percent

0.283
0.054
0.054

0.452
0.227
0.227

1.52
Source: Author’s calculations.

1.50
7

8

9
10
11
12
13
Number of days for MBS repo rate

14

Notes: The number of observations is 166. TIO is term investment
option; TT&L is Treasury Tax and Loan program; MBS is mortgagebacked security.

Sources: Author’s calculations; Bloomberg.

Rt+k = R13 = 1.55 percent + .07 percent ∗ (6/7) = 1.61 percent.
Second, implied forward rates must be calculated. The
forward rate is the proper comparison rate because TIO
investments are placed on the next business day after auction.
To calculate the comparable MBS repo rate for a given TIO
auction, fk, we use:
t+k
1 + ----------- R t + k
360
k
(1)
1 + --------- f k = --------------------------------------- ,
360
t
1 + --------- R o ⁄ n
360
where Ro/n represents the overnight MBS repo rate, and
overnight is defined as the next business day. Thus, for TIO
no. 54, Ro/n on September 14, 2004, was 1.5 percent, and given
the calculation of R13 to be 1.61 percent, we substitute values
into equation 1:
13
1 + --------- 00161
.
360
12
1 + --------- f12 = ---------------------------------------- .
360
1
.
1 + --------- 0015
360

22
Note that for t+k<7, the interval will typically be six days (seven days for a
one-week transaction minus one day for an overnight transaction). The proper
interval will also be affected by weekends and holidays. For example, an
overnight transaction conducted on a Friday will be for three days, assuming
no holiday on the following Monday.

Therefore, the comparable MBS repo rate for TIO no. 54 is:
MBS repo rate54 = f12 = .01619, or 1.619 percent.
We present summary statistics for the variables in Table 3.
For the sample period, the average spread is negative, at
-6.14 basis points. The average TIO investment is for $5.98 billion for a term of eight days. While the Treasury only began
announcing and auctioning term investments on the same day
in 2005, 28.3 percent of term investments in the sample were
announced and auctioned on the same day.
Chart 8 depicts TIO and MBS repo rates. Consistent with
the negative average spread, the MBS repo rate typically trades
slightly above the TIO rate. The spread between the two rates is
also plotted in the chart. The largest spread was 8.8 basis points
for TIO no. 125 and the smallest spread was -24.5 basis points
for TIO no. 70. While the spread is typically negative, there are
a number of cases where it is positive. There does not appear to
be any obvious trend in the spread over time despite the growth
of the TIO program.
In terms of expected signs for the regression coefficients, as
more TIO funds are auctioned (the supply of term investments
increases), assuming a downward-sloping demand curve, the
TIO rate is expected to fall. Therefore, the spread is expected to
narrow or become more negative, so the size of the auction is
expected to be negatively related to the spread.23 The amount
of term investments outstanding is also expected to have a

FRBNY Economic Policy Review / March 2007

27

Chart 8

Term Investment Option (TIO) Rate Compared with
Mortgage-Backed-Security (MBS) Repo Rate
Interest rate (percent)

5
MBS repo rate

4

banks bid less aggressively when they have less time to prepare
for an auction. The Treasury has also occasionally held two
auctions for different amounts and term lengths on the same
day. A casual observation of the data suggests that the rate for
the second auction of a multiple-auction day is low compared
with the rate for the first auction. Dummy variables for days of
the week of an auction are also investigated.

3
TIO rate

2

4. Regression Results

1

TIO-MBS repo rate spread

0
-0.5
1

20

40

60

80

100

120

140

160

180

Term investment option number
Sources: Author’s calculations; U.S. Treasury Department
(<http://www.fms.treas.gov/tip>); Bloomberg.

negative relationship with the spread, as banks are expected to bid
less aggressively as more of their allocated collateral is exchanged
for TIO funds.24 The need for funding assets will also generally be
reduced by prior TIO awards. As the auctioned amount can differ
from the amount actually placed (on rare occasions), the
auctioned amount is used in the regressions because this is the
amount on which banks are bidding.25 Because the benchmark
rate is for the same term length, it is not clear that longer term
lengths should have any relationship with the spread. We also
analyze the number of days since the last auction. More frequent
auctions are generally associated with more TIO funds outstanding, so more time between auctions is expected to be
positively related to the spread. However, this coefficient should
be interpreted carefully.
In addition, in the sample period the Treasury occasionally
compressed the TIO auction schedule by announcing and
auctioning term investments on the same day. We investigate
the relationship between a compressed schedule and the spread
using a dummy variable for auctions announced and auctioned
on the same day. This coefficient is expected to be negative if
23

For Treasury debt auctions, Seligman (2006), Fleming (2002), Simon (1991,
1994), and Duffee (1996) find that increases in the size of issuance lead to
higher yields (lower prices for Treasury debt).
24
When two auctions occur on the same day, we set the amount outstanding
for the second (higher numbered) auction to include the amount in the first
auction. The higher numbered auction will have a later closing time.
25
This scenario can occur for a variety of reasons. For example, the announced
amount for TIO no. 137 was $3 billion, but because of a collateral deficiency
only $2.96 billion was placed (<http://www.fms.treas.gov/tip/auctions/
HistoricalFinal05.pdf>).

28

An Examination of Treasury Term Investment Interest Rates

Column 1 of Table 4 presents a basic specification with only an
intercept, the size of the TIO auction, and the term length. The size
of the TIO auction is negatively related to the spread, so an
increase in supply leads to lower bids. The term length is positively
related to the spread. All coefficients are statistically significant.
Column 2 adds other explanatory variables and represents
the preferred specification. For the other variables, we add
quadratic and cubic terms for the term length as well as a
dummy variable for one-day TIOs. A casual observation of the
data shows that the six TIO offerings with one-day term lengths
in the sample resulted in relatively low spreads. The dummy
variable for one-day terms explicitly controls for these

Overall, for small auction sizes . . . for
term lengths of five to nineteen days,
the Treasury appears to receive an
interest rate comparable to market rates.

auctions. As expected, one-day term lengths result in very poor
outcomes for the Treasury.26 The linear term coefficient is now
larger in magnitude and still statistically significant. The
squared term coefficient is negative, while the cubic term
coefficient is positive.
Holding all other variables at zero, we plot in Chart 9 the effect
of term length on the spread. The effect of increasing term length
is greatest for lengths of one to four days. For term lengths of five
to sixteen days, predicted spreads are close to zero, and the effect
of increasing term length is not large in magnitude. Beyond
sixteen-day terms, the cubic term starts to dominate and the effect
of increasing term length starts to climb again. Overall, for small
auction sizes, the chart shows that for term lengths of five to
nineteen days, the Treasury appears to receive an interest rate
26

When a dummy variable for two-day term investments was added, its
coefficient was negative but not significant.

Table 4

Ordinary Least Squares Regression Results
Dependent Variable: TIO-MBS Repo Rate Spread
(1)
Intercept
Size
Term

-0.068
(-4.424)
-0.005
(-2.538)
0.004
(3.328)

Term2
Term3
1 (term = 1)
Term investments outstanding
on day of placement
Days since last TIO auction
Days since last TIO auction2

(2)

(3)

-0.123
(-3.745)
-0.007
(-3.936)
0.035
(3.331)
-0.003
(-2.934)
0.0001
(2.705)
-0.059
(-2.530)

-0.105
(-3.194)
-0.007
(-3.784)
0.036
(3.171)
-0.003
(-2.762)
0.0001
(2.576)
-0.065
(-2.601)

-0.001
(-1.029)
0.006
(1.988)
-0.0001
(-1.705)

-0.001
(-2.687)

(4)
-0.132
(-4.326)
-0.007
(-3.728)
0.033
(3.067)
-0.003
(-2.871)
0.0001
(2.788)
-0.058
(-2.534)

0.008
(3.334)
-0.0002
(-2.562)

Tuesday
Wednesday
Thursday
Friday
1 (announcement day = auction day)
1 (first auction if two auctions on same day)
1 (second auction if two auctions on same day)
Time trend

(5)
-0.136
(-3.524)
-0.007
(-3.858)
0.038
(3.269)
-0.004
(-3.028)
0.0001
(2.881)
-0.040
(-1.452)
-0.001
(-1.653)
0.005
(1.802)
-0.0001
(-1.309)
-0.017
(-1.138)
-0.022
(-1.074)
-0.012
(-0.706)
-0.0004
(-0.022)
0.008
(0.513)
-0.0002
(-0.009)
-0.038
(-1.129)
0.018
(1.325)

Adjusted R2

0.104

0.272

0.249

0.266

0.287

Durbin-Watson

1.59

1.39

1.41

1.42

1.41

Source: Author’s calculations.
Notes: t-statistics, in parentheses, are based on Newey-West (1987) standard errors. The number of observations is 166. TIO is term investment option;
MBS is mortgage-backed security.

comparable to market rates. We note that the effect on the spread
for term lengths greater than sixteen days should be interpreted
with caution, because—as Chart 5 shows—only ten offerings were
for term lengths of more than sixteen days.

For term lengths of one to four days, the impact on the
spread may be associated with the more cumbersome process of
transferring TIO collateral compared with MBS repo collateral.
As we discussed, the settlement of TIO transactions with

FRBNY Economic Policy Review / March 2007

29

Chart 9

Intercept and Term Length Coefficients;
Other Variables Set to Zero
Predicted spread (basis points)
5
0

-5

-10

-15

investments outstanding is retained. Whereas in column 2 the
coefficient for the amount of term investments outstanding is
insignificant, the coefficient in column 3 is now statistically
significant at the 95 percent confidence level.
In column 4, the variables for the number of days since the
last auction are retained and the amount of term investments
outstanding is deleted. Compared with their values in column 2,
the coefficients for both the linear and quadratic terms for the
number of days since the last auction are larger in magnitude
and statistically significant at the 95 percent confidence level.
Furthermore, an F-test of the null hypothesis that these
three coefficients are jointly equal to zero can be rejected at the
99 percent confidence level.30 As a result, we retain these three
variables in the preferred specification in column 2.

-20
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19
Term length (number of days)

4.1 Additional Issues

Source: Author’s calculations.

noncommercial loans pledged as collateral is essentially via
delivery-versus-payment.27 However, MBS repos are predominantly settled via tri-party, the more operationally efficient
method of settlement. Accordingly, depository institutions
may consider the transfer of TIO collateral back and forth
for term lengths of less than five days to be particularly
burdensome, leading to low relative TIO rates for short term
lengths.28
As expected, the coefficient on the amount of term investments outstanding on the day of placement is negative, but the
coefficient is not statistically significant.29 The magnitude of this
coefficient is also smaller than the coefficient for size of auction.
The number of days since the last TIO auction is positive and
significant; the coefficient on the quadratic term is negative and
significant at the 90 percent level.
Columns 3 and 4 of Table 4 present results in which the
number of days since the last TIO auction and the amount of
term investments outstanding, respectively, are deleted from
the specification. The interaction of these variables may be
confounding their coefficients in column 2. As we discussed,
more frequent auctions generally are associated with more TIO
funds outstanding. In column 3, the variables for the number of
days since the last auction are deleted and the amount of term

Table 4, column 5, presents a fuller specification with
additional variables for the day of the week of auction, cases
when TIO funds are announced and auctioned on the same
day, dummy variables for days with multiple auctions, and a
time trend (in decimal years).31 None of the additional
coefficients is statistically significant. Therefore, column 2
represents the preferred specification.
The insignificant time trend suggests that spreads did not
narrow over the sample period. Higher order terms for the time
trend (not presented) also were insignificant. The coefficient on
the dummy variable for auctions announced and auctioned on
the same day is positive, but insignificant. This result suggests
that compressing the auction schedule does not negatively affect
the Treasury in terms of the spread; banks appear to be
indifferent to more advance notice of a TIO auction.
In addition, coefficients on the dummy variables for days
with multiple auctions are not significant.32 Note that the
amount of term investments outstanding is always greater for
the second auction on a day with multiple auctions. Also, the
number of days since the last auction is always zero for the
second auction. While the magnitude of the coefficient for the
second auction on a multiple-auction day suggests that the
Treasury may need to be somewhat cautious in conducting
multiple auctions on the same day, the statistical insignificance of the coefficient implies that this variable does
30

27

At this time, it is not clear whether the Treasury has the legal authority to
engage in tri-party transactions.
28
For a given cost of transferring collateral, the average cost (per day) is larger
for shorter term lengths.
29
This amount does not include the amount being placed.

30

An Examination of Treasury Term Investment Interest Rates

The test statistic has a value of 6.82, which exceeds the 1 percent F3,157
critical value of 3.78.
31
Thus, the time trend takes on a value of 1 on November 21, 2004, one year
after the sample period began.
32
In the sample, there are nine occasions on which two auctions occurred on
the same day.

not add much explanatory value beyond the effects of the
amount of term investments outstanding and the time since
the last auction.

5. Conclusion
This article considers whether the interest rates received by the
Treasury through TIO auctions are comparable to market
rates. Central to our study is an analysis of the spread between
rates on TIO auctions and rates on mortgage-backed-security
repos. We study the 166 TIO auctions held from November
2003, when TIO became an official Treasury cash management
tool, through February 2006.
We find that for small auction sizes, TIO interest rates and
MBS repo rates are comparable for auctions with term lengths33
of five days or more. However, the Treasury tends to receive

lower TIO rates relative to market rates when term lengths are
of shorter durations. We also find that the spread between the
TIO rate and the MBS repo rate is negatively related to auction
size. Finally, banks appear to be indifferent to more advance
notice of TIO auctions. We base this conclusion on our finding
that TIO interest rates are not adversely affected by a more
compressed auction schedule, whereby the Treasury
announces and auctions TIO funds on the same day.
These findings may be of interest to a variety of market
participants. For instance, the Treasury would be interested in
whether its term investments are receiving a rate of return
comparable to market rates. In addition, those who study
Treasury auctions may find our results informative, because
TIO auctions vary along more dimensions than do typical
Treasury debt auctions and hence can offer new insight.
Finally, our work may be of interest to other central banks, as
the management of treasury funds affects the level of bank
reserves and thus the conduct of monetary policy.33

33

Different countries have different frameworks for managing government
funds. For example, in Japan all government funds are held at the central bank
and no funds are held at banking institutions. See Bank of Japan (2004).

FRBNY Economic Policy Review / March 2007

31

References

Bank of Japan. 2004. Functions and Operations of the Bank
of Japan. Tokyo, Japan: Institute for Monetary and Economic
Studies.

Meulendyke, A.-M. 1998. U.S. Monetary Policy and Financial
Markets. New York: Federal Reserve Bank of New York.

Duffee, G. R. 1996. “Idiosyncratic Variation of Treasury Bill Yields.”
Journal of Finance 51, no. 2 (June): 527-51.

Newey, W. K., and K. D. West. 1987. “A Simple, Positive SemiDefinite, Heteroskedasticity and Autocorrelation Consistent
Covariance Matrix.” Econometrica 55, no. 3 (May): 703-8.

Fleming, M. J. 2002. “Are Larger Treasury Issues More Liquid?
Evidence from Bill Reopenings.” Journal of Money, Credit,
and Banking 34, no. 3 (August): 707-35.

Seligman, J. S. 2006. “Does Urgency Affect Price at Market? An
Analysis of U.S. Treasury Short-Term Finance.” Journal of
Money, Credit, and Banking 38, no. 4 (June): 989-1012.

Garbade, K. D. 2006. “The Evolution of Repo Contracting
Conventions in the 1980s.” Federal Reserve Bank of New York
Economic Policy Review 12, no. 1 (May): 27-42.

Simon, D. P. 1991. “Segmentation in the Treasury Bill Market:
Evidence from Cash Management Bills.” Journal of Financial
and Quantitative Analysis 26, no. 1 (March): 97-108.

Garbade, K. D., J. C. Partlan, and P. J. Santoro. 2004. “Recent
Innovations in Treasury Cash Management.” Federal Reserve
Bank of New York Current Issues in Economics and
Finance 10, no. 11 (November).

———. 1994. “Further Evidence on Segmentation in the Treasury Bill
Market.” Journal of Banking and Finance 18, no. 1 (January):
139-51.

The views expressed are those of the author and do not necessarily reflect the position of the Federal Reserve Bank of New York
or the Federal Reserve System. The Federal Reserve Bank of New York provides no warranty, express or implied, as to the
accuracy, timeliness, completeness, merchantability, or fitness for any particular purpose of any information contained in
documents produced and provided by the Federal Reserve Bank of New York in any form or manner whatsoever.
32

An Examination of Treasury Term Investment Interest Rates

Nicola Cetorelli, Beverly Hirtle, Donald Morgan, Stavros Peristiani, and João Santos

Trends in Financial Market
Concentration and Their
Implications for Market
Stability
• The issue of whether concentrated financial
markets—those with a few large suppliers—
are more stable or less stable than less
concentrated markets is important to
policymakers and others concerned about
potential market disruptions.

• An analysis of how U.S. financial market
structure has changed over the last decade
finds no pervasive pattern of high and
increasing concentration.

• A complementary line of inquiry into the link
between concentration and the risk or severity
of market instability focuses on substitution by
firms; substitution can stabilize markets by
dampening the upward pressure on prices
attributable to a large exiting supplier.

• The departure of a major supplier will cause
less market disruption the more promptly
other firms can substitute for it.

Nicola Cetorelli is a senior economist and Beverly Hirtle a senior vice
president at the Federal Reserve Bank of New York; Donald Morgan,
Stavros Peristiani, and João Santos are research officers at the Bank.
Correspondence: <nicola.cetorelli@ny.frb.org>

1. Introduction

I

magine two very different financial market structures. The
first has many suppliers, each with only a small share of the
market. The second has a few very large firms that supply most
of the market, plus many smaller players that make up the rest.
Which structure is more stable: the one with many small firms
or the concentrated market where a few firms dominate?
Which structure best describes financial markets in the
United States? Those are questions we address in this article.1
A stable market is one that can endure shocks to supply or
demand without collapsing—that is, without experiencing
surging (or wildly oscillating) prices or sharply shrinking
volumes. Stability requires certain self-correcting tendencies
that ensure that a market can right itself. If supply falls because
a major producer fails, for example, the resulting excess
demand must push prices upward. Rising prices, in turn, must
induce prompt substitution toward other suppliers or
products. Substitution tends to dampen upward pressure on
prices, thus stabilizing the market.
1

Our study analyzes market concentration. That is, we focus on the risks to
financial stability in markets with a few large suppliers. We do not discuss other
forms of concentration that might be of concern to financial supervisors, such
as concentration in a firm’s asset portfolio, concentration among users of a
specific product or service, or concentration of many firms with the same risk
exposures. These are all very important but distinct concepts requiring separate
analysis.
The authors thank two anonymous referees for helpful comments. The views
expressed are those of the authors and do not necessarily reflect the position
of the Federal Reserve Bank of New York or the Federal Reserve System.

FRBNY Economic Policy Review / March 2007

33

Markets can experience shocks to supply or demand from
many sources, such as changes in regulation, technological
innovation, shifts in demographics, and knock-on effects from
shocks to other markets or economic sectors. We focus here
primarily on one particular type of supply shock: the failure
and exit of one or more large suppliers. This is a natural
channel to focus on given our interest in the relationship
between market concentration and market stability, since the
presence of a few large suppliers is the defining feature of a
concentrated market.
The link between concentration and stability is hard to pin
down, so we mostly try to identify the link by breaking it down
into parts. For example, we distinguish between the probability
of distress by a given firm and the severity of the market
consequences in that event. After reviewing literature that
investigates the link between financial market concentration
and financial stability, we conclude that the link is ambiguous—some of the side effects of changing market structure
may have a stabilizing influence, while other influences may
be destabilizing. Our own findings are consistent with that
ambiguity. We find a mixed relationship between market
concentration and volatility in the investment-grade-bond
and syndicated loan markets, consistent with an ambiguous
relationship as suggested in the theoretical literature. We
conclude that there are no simple answers to the question of
whether concentrated financial markets are more stable or
less stable than less concentrated markets.
Our analysis of how U.S. financial market structure has
changed over the last decade produces more definitive
conclusions. Using firm-level data from a variety of sources,

Markets can experience shocks to supply
or demand from many sources . . . .
We focus here primarily on one particular
type of supply shock: the failure and exit
of one or more large suppliers.
including data collected by central banks, we document that in
aggregate, most U.S. wholesale credit and capital markets are
only moderately concentrated. Concentration in most global
over-the-counter (OTC) derivatives markets is low, though
rising. Overall, concentration trends are mixed, rising in
some markets and falling in others. Given the rise in bank
concentration at the national level, we view the moderate and
mostly stable levels of concentration at the individual market
level as surprising. We also find that linkages across markets

34

Trends in Financial Market Concentration

have increased since the late 1990s as more second-tier firms
have ventured into other markets. The stability implications of
increased cross-market linkages are mixed; the probability of
disruption is lower if firms in multiple markets are more
diversified, but contagion across markets may make disruption
more severe.
After documenting those facts, we return to the question of
stability and concentration, but with a twist: we argue that the
exit of a single large firm will cause less market disruption the
more promptly other firms can substitute for the exiting firm,

Our findings should offer some
reassurance to policymakers concerned
about whether high or rising financial
market concentration portends greater
financial market instability.
and we discuss market characteristics that will speed or impede
such substitution. We then rank markets by potential
substitutability among firms in that market (as proxied by
turnover in market share rankings) on the one hand, versus
concentration on the other. We find few markets with high
concentration and low turnover.
In sum, our findings should offer some reassurance to
policymakers concerned about whether high or rising financial
market concentration portends greater financial market
instability. Most financial markets, at least those in the United
States, are not particularly concentrated, nor are they
becoming more so. Moreover, even if the opposite were true,
the implications for financial stability are ambiguous; it
depends on what else is changing along with market structure,
and on how fluidly other firms can substitute for the
incapacitated firm. Looking at concentration alone, without
considering these other factors, will not always provide a
reliable view of the likelihood or likely damage from a market
disruption. More detailed analysis of individual markets is
needed to obtain a full understanding.
Our policy recommendations are simple. Besides the
obvious—monitoring trends in concentration and turnover—
we advocate public policies that enhance substitution among
firms within a given market by, for example, promoting
standardization of products, ensuring rapid clearing of
payments, and monitoring competition to ensure that key
players do not become entrenched (and hence irreplaceable)
because of privileged access to trading platforms or
technologies.

2. The Ambiguous Link between
Concentration and Stability
Why should a change in concentration affect either the
probability of a firm’s distress or the severity of the consequent
market disruption? In this section, we review theory and
empirical evidence that address this question.
History certainly suggests a link between market
concentration and the severity of market disruption given
the distress of a major market supplier. A good example is
the market for original-issue, below-investment-grade (junk)
bonds and the role played in it by Drexel Burnham Lambert.
At the peak of the firm’s market dominance in the mid-1980s,
Drexel’s market share oscillated around 50 percent, with a
dollar value of issues up to ten times that of the second largest
competitor (Altman and Nammacher 1987). As a result of
well-known events, Drexel filed for Chapter 11 bankruptcy
protection in February 1990.
Drexel’s exit significantly disrupted the junk-bond market.
Return spreads over Treasury securities increased from an
average of 400 basis points during the 1980s to 1,000 basis
points after Drexel’s exit. Issuance also shrank substantially.

Why should a change in concentration
affect either the probability of a firm’s
distress or the severity of the consequent
market disruption?
The annual value of new issues declined from about $30 billion before Drexel’s exit to about $4 billion in 1990, and it
took three years to return to pre-exit volumes (Edwards and
Mishkin 1995). Moreover, negative repercussions were also
felt in other industries, as large junk-bond holders attempted
to find suitable substitutes for the services Drexel had
provided.2
Theory, however, has focused almost exclusively on the link
between market concentration and the probability of a firm’s
distress, offering mixed conclusions about the link’s direction.
Some of the literature suggests a negative link between market
concentration and the probability of firm distress. This
literature focuses on how market concentration affects firms’
incentives to take risk, a concept with direct correspondence to
the probability of a firm’s distress. Keeley (1990) as well as
Hellmann, Murdock, and Stiglitz (2000) argue that banks in
2

For example, this was the case in the life insurance sector, where foreclosures
occurred as a result of sizable losses from junk-bond investments (Brewer and
Jackson 2000).

concentrated markets have incentives to reduce risk. If higher
concentration reflects decreased competition and increased
profitability, then banks’ franchise values will be higher. Higher
franchise values reduce the incentives of equity holders to
engage in excessive risk-taking behavior that might jeopardize
their franchise. Focusing more on how firms interact with each

History certainly suggests a link between
market concentration and the severity of
market disruption given the distress of a
major market supplier.
other, Carlin, Lobo, and Viswanathan (2004) argue that a
market with a few large players will be stable most of the time,
as firms choose optimally to act as cooperating oligopolists.
However, one player will find it optimal, occasionally, to
deviate from this strategy, and its action could lead to
significant market instability.
There are also links between concentration and risk through
a size channel. The dominant banks in concentrated markets
are frequently very large, and large banks have opportunities to
diversify and reduce risk. Concentrated markets thus should be
more stable overall (for example, Allen and Gale [2000]).
However, large firms may reoptimize by changing investment
strategies (entering riskier market segments or adopting lower
capital ratios) so that eventually overall risk might remain
unaltered. Empirical evidence based on U.S. data supports this
conjecture (Demsetz and Strahan 1997; Stiroh 2006).
While these factors suggest a negative or neutral link
between market concentration and firms’ incentives to take on
risk, other factors suggest the opposite effect. In particular, an
increase in firm size may be associated with lower transparency.
Size allows financial firms to expand across multiple geographic markets and lines of business. It also allows the use
of increasingly sophisticated financial instruments and the
evolution toward complex forms of corporate organization.
This may result in reduced managerial efficiency, less effective
internal corporate control, and the potential for increased
operational risk. The increasing complexity of the organizations could also render both market discipline and regulatory
action less effective in preventing excessive risk exposure. Large
size also raises moral hazard concerns if the owners of large
banks operate under the presumption that they are too big
to be allowed to fail.
Given the ambiguous theoretical relationship between
financial market concentration and financial market stability, it
should come as no surprise that the scant empirical literature

FRBNY Economic Policy Review / March 2007

35

on that question also reaches conflicting conclusions.3 Using
data across seventy countries from 1980 to 1997, Beck,
Demirguc-Kunt, and Levine (2003) estimate the relationship
between banking market concentration and the likelihood of a
banking crisis.4 They find a negative relationship; as concentration increases, the probability of crises decreases. However,
De Nicoló et al. (2003) investigate empirically the role of
concentration on an indicator proxying for the probability of
the largest financial firms failing. Using cross-country data,
they find that higher concentration is associated with higher
probability of failure.
We find a similarly ambiguous relationship in our estimates
of the link between concentration and volatility in two
particular U.S. financial markets: investment-grade-bond
underwriting and syndicated loans. Our two-step regression
methodology constructs a measure of volatility from the excess
variation in bond or loan spreads—variation above and beyond
what one would predict given the risk of the issuer or borrower,

Given the ambiguous theoretical
relationship between financial market
concentration and financial market stability,
it should come as no surprise that the
scant empirical literature on that question
also reaches conflicting conclusions.
contract terms (for example, maturity), and macroeconomic
conditions at the time of issuance. (Our statistical methodology
is described in greater detail in the appendix.) Put differently,
volatility is measured by deviations in spreads that are not
attributable to firm or macroeconomic fundamentals. Those
nonfundamentals are presumably the types of disturbances to
supply and demand that can destabilize a market.5
In the second stage of our regression methodology, we
estimate how volatility in each market changes over time in
relation to changes in the level of concentration, as measured
by the Herfindahl-Hirschman Index (HHI) of concentration.6
The estimates of the volatility-concentration relationships are
not robust; they depend instead on the market in question and
the period under observation (Chart 1). For syndicated loans,
3

Boyd and De Nicoló (2005) also conclude that theory and evidence relating
concentration and financial stability are ambiguous.
4
Banking crises are defined as events where 1) emergency measures were taken
to assist a nation’s banks (bank holidays, deposit freezes, blanket guarantees to
depositors or creditors, or large-scale nationalization), 2) nonperforming
assets reached at least 10 percent of total assets at the height of the crisis, or
3) the cost of rescue operations was at least 2 percent of GDP (see <http://
www.nber.org/digest/feb04/w9921.html>).

36

Trends in Financial Market Concentration

the relationship is nonlinear but generally negative, suggesting
somewhat lower volatility as market concentration rises. For
investment-grade bonds, the relationship is negative in a
narrow range of low concentrations but turns positive for

We find a similarly ambiguous relationship
in our estimates of the link between
concentration and volatility in two
particular U.S. financial markets:
investment-grade-bond underwriting
and syndicated loans.
higher HHI levels, suggesting the opposite relationship
to the syndicated loan market, at least for higher market
concentration levels. However, the volatility-concentration
relationship for bonds is unstable. When we exclude
observations before 1990 (a period in which most banks
were not allowed to compete for underwriting business),
the relationship estimated over the observations in the
1990-2004 period is negative.7
These findings showing variation across markets and across
time do not support any particular conclusions about the
relationship between concentration and volatility. Perhaps the
safest view is to take these estimates as consistent with the
ambiguous relationship in the literature we just reviewed. Put
differently, our findings can be seen as a counter-example to
hypothetical claims that concentrated markets are always more
stable or less stable.

5

While this volatility measure does not directly reflect the impact of a large
supplier’s failure, we believe it provides a reasonable proxy for market
resiliency to a range of supply and demand shocks. In fact, the measure tracks
other, broader gauges of financial market instability fairly closely. For instance,
the correlation between our annual measure of bond price volatility and the
Chicago Board Options Exchange Volatility Index (VIX) is close to
70 percent. The VIX is a key measure of market expectations of near-term
volatility conveyed by S&P 500 stock index option prices. Essentially, many
consider this index one of the most important forward-looking indicators of
investor sentiment and market volatility. We take this close correlation as
evidence that the first-stage volatility estimates are doing a good job capturing
changes in market stability over time.
6
Volatile markets have more frequent and larger price disruptions (by
definition), so the self-correcting tendencies required for stability are more
demanding. We also looked at extreme events—that is, episodes in which
our measure of excess volatility was in the tail of the distribution. The results
were qualitatively similar to those reported in this article. To account for the
possibility that price volatility might also depend on the business cycle, we
also estimated a second-stage regression specification that, in addition to
concentration, included several macroeconomic controls such as GDP
growth, the unemployment rate, and inflation. Overall, the relationships
depicted in Chart 1 remained fairly unchanged.

Chart 1

Chart 2

Relationship between Price Volatility and Market
Concentration

Share of Total Bank Assets Held by Top Four
U.S. Commercial Banks
Percent

Quality-adjusted volatility (basis points)
0.30

180
Investment-grade bonds,
1980-2004

160

0.25

140

0.20

120
0.15
Syndicated loans

100

0.10

80
Investment-grade bonds,
1990-2004

60
40
800

1,000

1,200

1,400

1,600
HHI

1,800

2,000

0.05
0
1980

2,200

85

90

95

00

04

Source: Federal Financial Institutions Examination Council Reports
of Condition and Income.

Sources: Securities Data Corporation; Loan Pricing Corporation.
Note: HHI is the Herfindahl-Hirschman Index.

3. Concentration Trends
We now examine trends in concentration across a selection of
major U.S. financial markets over the past fifteen years. The
basic question is whether the regulatory changes of the 1990s
have led to a broad pattern of high and increasing concentration in U.S. financial markets. It is already well known that
bank concentration at the aggregate level (measured by the
market share of the four largest U.S. banks) has climbed
steadily since the early 1990s (Chart 2), rising from less than
10 percent of banking industry assets in 1990 to 25 percent
at the end of 2004. Our review shows that high and rising
concentration is not universal across individual financial
markets. We find generally moderate levels of concentration
in wholesale credit and capital market activities and in most
OTC derivatives markets, plus a mixed pattern in terms
of trend, with concentration rising in some markets and
falling in others. The most noticeable exception is the
prime brokerage market, where concentration is high (but
declining).
Our review covers major U.S. wholesale credit and capital
markets. Admittedly, these markets are not exhaustive;

however, they do represent some of the most important
markets for core wholesale financial and banking services.8
We measure market concentration by the standard n-firm
concentration ratio, calculated as the sum of the market shares
of the top n (two, three, or five) firms in the market, or by the
Herfindahl-Hirschman Index, the sum of squared market
shares of all firms in the market.9 The HHI ranges from zero for
a market with an infinite number of equally sized (very small)
competitors to 10,000 for a market with a single competitor
with a 100 percent market share. Guidelines published by the
U.S. Department of Justice used in antitrust analysis specify
that markets with HHIs of between 1,000 and 1,800 are
considered “moderately concentrated,” while markets with
HHIs greater than 1,800 are considered “highly concentrated.”
Although the application is not direct, these figures are useful
for interpreting the HHI figures we discuss.

3.1 Underwriting and Financial Services
The U.S. underwriting markets are dominated by a handful of
large financial firms. Increased competition from bank entry,
however, has changed the character and diversity of these

7

Implicit in the relationship that we derived between price volatility and
concentration is, among other things, our assumption that the pool of bond
issuers does not change with competition among bond underwriters (our
results assume similar conditions in the case of syndicated loans). If these
assumptions do not hold, other explanations for our findings are also plausible.
For instance, if more new issuers come to the market as concentration decreases,
these issuers are likely to contribute to a negative relationship between price
stability and concentration because, in general, there is less information
available about them than about issuers with an established track record.

8

We do not look at the markets for deposit-taking or other consumer services,
since studies have shown that these activities are conducted mostly in local
markets and that concentration in local markets has not been increasing
(Dick 2006). Nor do we analyze payment-related markets, since concentration
in these markets, especially government securities clearing, is well documented
and has been actively studied from a policy perspective.
9
In general, n-firm concentration ratios and HHIs display very high positive
correlations.

FRBNY Economic Policy Review / March 2007

37

markets. Table 1 summarizes the levels and changes in
concentration in the major underwriting and financial services
markets: securities underwriting, syndicated loan, and merger
and acquisition (M&A) advisory services. Chart 3 shows the
change in HHI in these markets from year to year since the
early 1980s.10 Overall, these measures reveal low to moderate
levels of concentration across the markets. Average HHIs range
from about 850 to 1,400, within or slightly below the
Department of Justice’s “moderately concentrated” range.
Several markets have seen significant declines in
concentration since 1980, most notably the high-yield-debt
underwriting and M&A advisory services markets (Chart 3).
Since 1990, the pattern across markets has been mixed, with
some experiencing increases in measured concentration
(equity initial public offerings [IPOs], seasoned equity, and
M&A advisory services) and others experiencing declines
(bond underwriting and syndicated loans). Even over the
relatively short period since 1998, no consistent pattern
emerges, with concentration in some markets trending up and
concentration in other markets trending down.

Table 1

Concentration Trends in Underwriting and Selected
Financial Services, 1990-2004
Average
HHI

Growth in HHI
(Percent)

Top Five
(Percent)

Securities underwriting
Initial public offerings
Seasoned offerings
Investment-grade bonds
High-yield bonds

1,149
854
1,122
1,144

4.32
4.85
-3.41
-1.54

60.7
49.2
56.4
56.1

Merger and acquisition
advisory services
Syndicated loan

1,160
1,391

9.44
-1.97

56.8
50.2

Market

Source: Securities Data Corporation.
Notes: Herfindahl-Hirschman Index (HHI) calculations are based on the
lead underwriter.

Chart 3

Concentration in Investment Banking Markets
HHI

HHI
5,000

2,500

High-Yield-Bond Underwriting

4,000

2,000

3,000

1,500

2,000

1,000

1,000

500

0

0

Equity Underwriting

Initial public offerings

3,000

3,000

Merger and Acquisition Advisory Services

2,500

2,500

2,000

2,000

1,500

1,500

1,000

1,000

500

500

Seasoned equities

Syndicated Loan and Investment-Grade-Bond
Syndicated loans

0

0
1980

82

84

86

88

90

92

94

96

98

00

02

04

Sources: Securities Data Corporation; Loan Pricing Corporation.
Note: HHI is the Herfindahl-Hirschman Index.

38

Investment-grade bonds

Trends in Financial Market Concentration

1980

82

84

86

88

90

92

94

96

98

00

02

04

3.2 OTC Derivatives Markets

Table 2
10

OTC derivatives markets have grown tremendously in recent
years along with rising demand for corporate risk management. Commercial banks are the largest dealers in these rapidly
growing markets.11
Tables 2 and 3 summarize patterns in market concentration
for a variety of OTC derivatives products. Table 2 reports
information on concentration in global markets for interest
rate and foreign exchange (FX) derivatives from the 2004 Bank
for International Settlements (BIS) Triennial and Semiannual

Concentration in credit derivatives
products has declined substantially
over the last few years as financial
institutions have rushed to take part
in this exploding market.
Surveys on Positions in Global Over-the-Counter Derivatives
Markets.12 Chart 4 shows how concentration in these markets
has varied from year to year since 1998. Overall, global concentrations for the major categories of interest rate and FX
products are low or moderate, though rising.
The BIS survey does not publish concentration measures for
the credit derivatives market. The last row of Table 2 presents
an estimate of concentration for the OTC credit derivatives
market based on U.S. dealers reporting to the BIS survey and
information gathered from the annual reports of major nonU.S. dealers. Our estimates reveal moderate levels of concentration in the credit derivatives market during the 2000-04
period. Moreover, concentration in credit derivatives products
has declined substantially over the last few years as financial
institutions have rushed to take part in this exploding market.
Table 3 reports concentration figures for equity-linked
derivatives markets. Concentration in global markets is low to
moderate for U.S. and European equity-linked derivatives,
though concentration in the more specialized regional markets,
such as in Asia and Latin America, is quite high. In addition to
presenting BIS estimates of global market concentration,
Panel B of Table 3 gives information on concentration for U.S.
10

The HHI for the syndicated loan market starts in 1986 because our data
source for this market is not comprehensive before that year.
11
For a thorough discussion of the link between derivatives markets and
the risk of systemic events, see Hentschel and Smith (1994).
12
The BIS database on major OTC dealers is made up of data collected by
central banks in major industrialized countries. The BIS reports aggregate
information on nominal positions and HHI concentration, but it does
not collect or make available bank-specific information on the roughly
240 reporters.

Concentration Trends in Interest Rate and Foreign
Exchange Over-the-Counter Derivatives Markets
Average
HHI

Growth in HHI
(Percent)

U.S. interest rate derivatives
Forward rate agreements
Interest rate swaps
Options

843
591
908

4.64
8.20
0.75

Foreign exchange derivatives
Forwards and swaps
Options

420
544

5.30
2.31

825

-14.04

Market
Panel A: Global concentration:
BIS surveys, 1998-2004

Panel B: Federal Reserve Bank of New York
Estimates of Concentration: 2000-04
Credit derivatives

Sources: Bank for International Settlements, Triennial and Semiannual
Surveys on Positions in Global Over-the-Counter Derivatives Markets
(2004); Federal Reserve Bank of New York; company annual reports.
Notes: HHI is the Herfindahl-Hirschman Index; BIS is Bank for International Settlements. Estimates for the credit derivatives market are calculated from the U.S. Reporter Survey, company annual reports, and call
reports.

Chart 4

BIS Estimates of Concentration in Over-theCounter Markets
1,400

HHI
U.S. Interest Rate Derivatives Contracts

1,200
1,000

Forward rate
agreements

800
600

Options

Interest rate swaps

400
200
0
700

Foreign Exchange Derivatives Contracts

600
Options

500
400
Forwards and swaps

300
200
100
0
1998

1999

2000

2001

2002

2003

2004

Source: Bank for International Settlements (BIS), Triennial and
Semiannual Surveys on Positions in Global Over-the-Counter
Derivatives Markets (2004).
Note: HHI is the Herfindahl-Hirschman Index.

FRBNY Economic Policy Review / March 2007

39

Table 3

Table 4

Concentration Trends in Equity-Linked
Over-the-Counter Markets

Concentration Trends for Primary Dealers,
1995-2004

Average
HHI

Market

Growth in HHI
(Percent)

Top Two
(Percent)

Panel A: Global concentration:
BIS surveys, 1998-2004
Forward, swap, and option
United States
Europe
Asia (ex Japan)
Latin America

924
827
2,707
5,771

7.44
4.30
35.88
12.81

—
—
—
—

Panel B: U.S. reporters only,
2000-04
Forward, swap, and option
United States
Europe
Asia (ex Japan)
Latin America

Growth in HHI
(Percent)

Top Five
(Percent)

Treasury securities
Bills
Coupons
TIPS

515
596
1,826

4.88
3.44
11.43

37.6
42.5
71.9

Other securities
Mortgage-backed
Corporate
Federal agency

954
1,336
694

0.39
-5.76
1.20

58.2
73.6
45.8

Source: Board of Governors of the Federal Reserve System, Weekly
Report of Dealer Transactions (FR 2004B).
2,162
3,239
4,257
6,976

-0.001
-9.65
25.15
4.38

Note: HHI is the Herfindahl-Hirschman Index; TIPS is Treasury
Inflation-Protected Securities.

53.3
70.5
77.6
96.2

Sources: Bank for International Settlements, Triennial and Semiannual
Surveys on Positions in Global Over-the-Counter Derivatives Markets
(2004); Federal Reserve Bank of New York; company annual reports.
Note: HHI is the Herfindahl-Hirschman Index; BIS is Bank for
International Settlements.

reporters.13 Concentration in the U.S. OTC derivatives
markets is higher, especially for the broader U.S. and European
equity-linked markets. For smaller equity-linked markets, such
as those in Asia and Latin America, however, concentration
measures are comparable because they are essentially
dominated by U.S. reporting firms.14

primary dealers in several types of securities.16 Concentration
in secondary-market trading of Treasury securities is generally
low, with the exception of the Treasury Inflation-Protected
Securities (TIPS) market (row 4 of Table 4). However, the
relatively high measured concentration in TIPS trading can be
attributed to the early dominance of one dealer. With the TIPS
market maturing, HHIs declined from 3,500 in 2002 to just
below 1,500 by the end of 2004. Mortgage-backed, corporate,
and federal agency securities trading also appears to be
unconcentrated, with HHIs beneath or just above the

Concentration in secondary-market
trading of Treasury securities is generally
low, with the exception of the Treasury
Inflation-Protected Securities market.

3.3 Secondary-Market Trading
by Primary Dealers
An important element of liquid securities markets is the extent
of secondary-market trading.15 Table 4 presents concentration
measures for the secondary-market trading volumes of
13

We use a database on large U.S. reporters available from the Statistics
Function of the Federal Reserve Bank of New York as well as call report
information.
14
We report the U.S. dealer information here to establish that it is reasonably
comprehensive for the global market. In the analysis to follow, we will need
firm-level data not provided in the BIS survey. For the interest rate and foreign
exchange derivatives markets, we can construct reasonable proxies for firmlevel data from data on U.S. reporters and from annual reports of non-U.S.
reporters. However, for the equity-linked markets, we are unable to collect
sufficiently comprehensive data from these sources; thus, we use the U.S.
reporter data.
15
The primary dealer information (Weekly Report of Dealer Transactions,
FR 2004B) is compiled by the Statistics Function of the Federal Reserve Bank
of New York.
40

Average
HHI

Market

Trends in Financial Market Concentration

Department of Justice’s “moderately concentrated” range.
Actual concentration levels in these securities may be even
lower than indicated by the HHIs in the table, since the primary
dealer data may not cover the full range of market participants
in the trading of these securities.

3.4 Prime Brokerage
An increasingly important business for investment banks and
large commercial banks is prime brokerage. Prime brokerage
firms essentially service the hedge fund community. Typically,
16

Primary dealers are banks and securities brokerages that trade in U.S.
government securities with the Federal Reserve System.

Table 5

Concentration in Prime Brokerage
Concentration
Year

HHI

Top Three (Percent)

2001
2002
2003

2,006.7
2,093.8
1,931.2

65.17
65.61
60.53

Average HHI
Growth in HHI (percent)

2,010.5
-1.71

managing a large portfolio of securities denominated in several
currencies. Consequently, global custody is dominated by a
small number of major banks and specialist providers. The topfive market for global custody during the 1994-2004 period
averaged around 76.9 percent. Overall, during this period the
market was moderately concentrated, with an average HHI
of 1,397.

4. Market Interdependencies

Source: HedgeWorld.com.
Note: HHI is the Herfindahl-Hirschman Index.

they provide hedge fund clients with a variety of services:
financing (securities lending, margin lending, or other
structured derivatives products), trading and clearing,
customer support, and research. The proliferation of hedge
funds over the last few years has made prime brokerage a
significant source of revenues for banks and other providers.17
Concentration measures for the prime brokerage industry
in 2001-03 show that the prime brokerage market is more
concentrated than the securities underwriting market
(Table 5).18 HHIs are in the “highly concentrated” range, but
concentration has remained fairly stable over the three-year
period.

3.5 Global Custody
The global custody business involves processing trades across
countries and safeguarding and servicing financial assets for a
variety of large customers (institutional investors, brokers/
dealers, and money managers). Typically, the portfolio of assets
held by global custodians for their customers includes bonds,
equities such as mutual fund holdings, and derivatives
products. With the rapid expansion of financial markets, assets
in custody surged from $7.6 trillion in 1994 to $36.3 trillion in
2000 and to more than $52.0 trillion in 2004.19
Global custody is a fairly specialized business requiring an
international network of subcustodians and expertise in
17

According to Boston Consulting Group, hedge fund industry revenues
in 2003 amounted to $60 billion. The servicing of hedge funds has generated
roughly $15 billion in revenue opportunities for prime brokers.
18
We use the HedgeWorld Service Provider Directory League Tables to derive
HHI measures of concentration. The HedgeWorld rankings are based on a
large pool of hedge funds tracked by TASS Research.
19
Our source is The Global Custody Yearbook, 2005 Eleventh Annual Survey,
Buttonwood International.

Thus far, our discussion has centered on the analysis of single
markets. However, the probability of distress for a firm and the
severity of market disruption may also be affected by
interdependencies across markets. The emergence of large
financial superstores in the late 1990s suggests that financial
markets may now be more interrelated. In this section, we

As financial markets become increasingly
dominated by the same set of financial
firms, these firms may also become more
and more alike, thus actually increasing
the risk of exposure to common aggregate
shocks.
examine a variety of evidence on cross-market linkages, finding
that these linkages have increased, especially since the late
1990s. This increase has been driven mainly by a growing
common set of second-tier firms, rather than by increases in
the number of firms with top-five market shares in multiple
markets.
Is an increase in cross-market linkages a concern for overall
stability? On the one hand, the ability of financial firms to
operate simultaneously in several product markets should
open up better diversification opportunities, reducing risk and
thus the probability of firm distress. On the other hand, the
diversification benefits may be spent by undertaking riskier
investment strategies, making the overall effect on risk unclear.
Moreover, as financial markets become increasingly
dominated by the same set of financial firms, these firms may
also become more and more alike, thus actually increasing the
risk of exposure to common aggregate shocks. Risk may also be
enhanced when the same firms are big providers in multiple
markets because alternate suppliers are needed in many places
at once. This multi-market presence might potentially strain

FRBNY Economic Policy Review / March 2007

41

alternate suppliers, especially if they themselves are operating
in the same multiple markets. On net, firms that are active in
multiple markets may be more diversified, but the financial
system on the whole may be more vulnerable to firm-specific
shocks.20
We look at cross-market linkages through two lenses. First,
we examine trends in market share correlations—that is, are
banks’ shares in one market now more or less correlated with
their shares in other markets? Second, we examine the extent to
which individual firms have high shares across multiple
markets and how those shares have changed.

Chart 5

Correlation in Market Shares
Correlation
0.6

Bond
0.2
0
M&A
-0.2
IPO
-0.4
-0.6
0.6
0.4

4.1 Correlations of Market Shares

Syndicated Loan Market with Other Markets

0.4

M&A Market with Other Markets
Bond

0.2
IPO

One direct measure of linkages between two markets is the
correlation of market shares of individual firms in any two
markets. A high positive correlation would signal that firms are
likely to have similar market shares in both markets. In fact,
market share correlations have increased since the late 1990s,
largely reflecting the increased role of commercial banks in
underwriting activities.
Charts 5 and 6 plot the market share correlation in selected
securities underwriting markets and M&A advisory services
from 1990 to 2004. The syndicated loan market has become
increasingly more integrated with securities underwriting and
M&A advisory services. The key reason for the higher
correlation is bank entry; in the early 1990s, most large
commercial banks at the top of the syndicated loan market
hierarchy were not very active in securities underwriting, but
by the end of the 1990s several leading syndicated loan
underwriters were heavily involved in investment banking.
The M&A and securities underwriting markets usually have
low positive correlations. Generally, correlations among these
markets have trended higher, especially after the mid-1990s,
indicating that many underwriters have sought to achieve some
synergies by operating in both markets. Stronger commercial
bank presence is again a catalyst for the rising correlations.
However, during this period a number of top-tier investment
banks have also made an effort to increase their market shares
in financial services.

0
-0.2
Syndicated loan
-0.4
-0.6
1990 91

92

93

94

95

96

97

98

99

00

01

02

Sources: Securities Data Corporation; Loan Pricing Corporation.
Note: M&A is merger and acquisition; IPO is initial public offering.

Chart 6

Correlation in Market Shares
Correlation
0.6

IPO Market with Other Markets

0.4
M&A
0.2
Bond

0
-0.2

Syndicated loan
-0.4
-0.6
0.5 Bond Market with Other Markets
0.4
M&A
0.3
IPO

0.2
0.1

Syndicated loan

0
20

The failures of Drexel and Long-Term Capital Management (LTCM)
illustrate the perils of cross-market interdependencies. While Drexel’s failure
roiled the high-yield-debt market, the broader impact was muted because
Drexel was a very small player in other financial markets. In contrast, the
collapse of LTCM created widespread concerns among market participants
worried about liquidity across several closely integrated financial markets.

42

Trends in Financial Market Concentration

-0.1
-0.2
1990 91 92

93

94

95

96

97

98

99

00

01

02

Sources: Securities Data Corporation; Loan Pricing Corporation.
Note: M&A is merger and acquisition; IPO is initial public offering.

4.2 The Presence of Large Banks
in Multiple Markets
We now consider a second and even more direct measure of
market interdependency: the extent to which individual firms
have high market shares in multiple markets. We find that the
number of firms ranking in the top five (by market share) in
multiple markets has not increased since the early 1990s,
though the number of firms with multiple top-ten and toptwenty market shares has increased. Taken together, those
findings reveal increased linkages across markets through the
emergence of more “second-tier” providers, rather than
through an increased commonality among “top-tier”
providers.
Table 6 presents these findings for four markets: syndicated
loan, investment-grade-bond underwriting, equity IPO, and
M&A advisory services. Table 7 lists the top twenty firms by
market share in each of these four markets in 2004.
The first measure in Table 6 is the number of distinct firms
ranking in the top five (by market share) in just one market
(top panel, column 1). The maximum possible for this number
is twenty—in other words, twenty different firms occupying
the top five rankings in the four separate markets. The mini-

Table 6

Banks Operating in Single and Multiple Markets
Year

In a Single
Market

In All Four
Markets

In Three or
Four Markets

In Two, Three, or
Four Markets

Among the Top Five Banks
1990
1995
2000
2004

9
7
7
6

0
0
0
0

3
3
3
4

4
5
5
5

Among the Top Ten Banks
1990
1995
2000
2004

17
19
9
8

0
1
3
2

5
4
8
8

9
8
10
11

Among the Top Twenty Banks
1990
1995
2000
2004

29
36
16
22

1
1
7
8

12
11
13
12

19
16
22
19

Sources: Securities Data Corporation; Loan Pricing Corporation.
Note: The markets are syndicated loan, investment-grade-bond
underwriting, equity initial public offering, and merger and
acquisition advisory services.

mum possible, zero, indicates that the twenty available slots
were occupied by firms all with at least two top-five ranking
positions, indicating a high degree of (at least pair-wise)
dependence across markets. We compute similar statistics for
the top ten and top twenty firms (middle and bottom panels
of Table 6).
This indicator, however, is silent about the extent of the
linkages between these markets. Changes in the “single market”
count could reflect more firms having high market shares in
just two markets, in three markets, or across all four markets.
This difference is important because the lower the number of
firms that dominate these markets, the higher the degree of
interdependency. To this end, we compute additional
measures of multi-market interdependency. These indicators
count how many firms occupy top-five rankings in at least two,

Table 7

Ranking of Top-Ten Firms in Bond Underwriting,
Equity IPO, M&A, and Syndicated Loan Markets
in 2004

Firm
Citigroup
Lehman
J.P. Morgan
Morgan Stanley
Goldman Sachs
Bank of America
Merrill
HSBC
Barclays
Credit Suisse
First Boston
Wachovia
Deutsche Bank
ABN AMRO Inc.
Union Bank
of Switzerland
Paribas
Corporation
Royal Bank
of Scotland
Mizuho Financial
Group
Friedman Billings
Ramsey
Lazard

Bond
Underwriting

Equity
IPO

M&A

5 (20)
5 (10)
5 (20)
5 (5)
5 (5)
10
10 (5)
10
10

5
10 (20)
10
5 (5)
5 (5)
10
5 (10)

10
10 (10)
5 (10)
5 (5)
5 (5)
20 (20)
5 (10)

10 (5)
20
20
20

10 (5)
20
20

5 (5)

20

5

10

10

20

Syndicated
Loan
5 (5)
20
5 (5)
20
5 (5)
20
20 (10)
5 (5)
20 (20)
10
5 (10)
10
(5)
10 (20)
10 (10)
10 (20)

10
10 (20)

Sources: Securities Data Corporation; Loan Pricing Corporation.
Notes: The values 5, 10, and 20 indicate that a firm was ranked in the top
five, top ten, and top twenty, respectively. Figures in parentheses are
rankings in 1990; if there is no figure, the firm did not have a ranking in
the top twenty that year. IPO is initial public offering; M&A is merger
and acquisition.

FRBNY Economic Policy Review / March 2007

43

at least three, or even all four markets (columns 2-4 of the
table). We compute similar statistics for the top ten and top
twenty banks, respectively. In contrast with our first measure of
multi-market interdependency, an increase in these indicators
suggests more interdependency.
As Table 6 shows, the number of independent firms ranked
in the top five in the four markets remained constant during
the 1990-2004 period. In contrast, there is a reduction in the
number of “single market” firms among the top-ten (from
seventeen in 1990 to eight in 2004) and, to a lesser extent,
among the top-twenty rankings. The other measures offer
similar interpretation. Among the top-five rankings, there were

[Our] results suggest that the markets for
syndicated loans, bond underwritings,
equity IPOs, and M&As became more
interlinked between 1990 and 2004.
no significant changes in the number of firms with large market
shares in more than one market over time. In contrast, among
the top-ten and top-twenty rankings, there was a clear increase
in the number of firms that have large market shares in more
than one market. Significantly, the largest changes occurred in
the number of firms with large market shares in all four
markets (among the top twenty) and in the number of firms
with large shares in three markets (among the top ten).
These results suggest that the markets for syndicated loans,
bond underwritings, equity IPOs, and M&As became more
interlinked between 1990 and 2004. This finding is important,
because a problem experienced by one of the key players in
these markets is now more likely to spread to a larger number
of markets. However, given that the new interdependencies
emerge among second-tier firms, the disruption arising from a
problem in one of these firms is likely to be smaller than what
would emerge had the new market linkages arisen among firsttier firms.21

5. Prompt Substitution Minimizes
Disruptions
Our review of trends in financial market structure yields two
main findings. First, while high and rising concentration is not
universal, some markets are indeed highly concentrated or
21

Moreover, the presence of more firms operating simultaneously in these
markets may make it easier for one of them to step in and replace the one in
trouble, thereby reducing the disruptions due to its exit.

44

Trends in Financial Market Concentration

increasingly so. Second, financial markets are becoming more
interdependent, and the same set of large institutions is
increasingly likely to occupy top rankings in several markets.
The stability implications of higher concentration in some
markets and increasing interdependence are two-sided. If the
firms that dominate a concentrated market or that are spreading across markets are more diversified, then the probability
of a given firm’s failure should be lower accordingly. In such
an event, however, disruptions may be more severe, because
the exit of a dominant firm in a concentrated market leaves a
bigger hole in that market and in any others where that firm
was top-ranked.
Whether the failure of a leading financial provider will
disrupt the entire market for a given product depends crucially
on how quickly users can switch to other providers or products.
If clients of the departed leader can readily switch to secondary
providers at little extra cost, or if they can substitute a related
service, the resulting disruption will be accordingly small. If
switching is slow or costly, then disruptions will be more severe.
This section discusses financial product characteristics that
tend to speed or slow substitution. We also compare financial
markets by two simple indicators of potential substitution: the
number of active providers and the turnover in providers’
relative rankings. Lastly, we array markets by those indicators
and by the level of concentration. Markets with low turnover,
indicating less potential for substitution among providers, and
high concentration may be more susceptible to severe market
upheaval in the event of failure by a leading firm than would
those markets characterized by high concentration alone.
Considering both characteristics together thus may provide
more insight than examining concentration in isolation.

5.1 Ready (or Not) Substitution
What determines how readily and cheaply financial market
users can switch between producers or products? For the goods
market, the answer would be tastes. Does the consumer like this
product or producer better than another? For financial
markets, the speed and cost of substitution depend on a variety
of factors.
Substitution will be slower, all else equal, the closer the
relationship between the provider and user. Bank loans,
especially to small firms, are relationship-intensive compared
with the more arm’s-length dealing in syndicated loans (to
large firms), bonds (especially investment-grade), and stocks.
Banks have to learn about a small firm before they lend, and
that information gets embodied in the relationship.22 The same
is true with junk bonds; underwriters require detailed
knowledge of issuers before they can sell their bonds—

knowledge that could not be instantaneously or credibly
transferred to another underwriter (Benveniste, Singh, and
Wilhelm 1993). The price of bonds underwritten by Drexel
dropped sharply before the firm failed, indicating that Drexel’s
services could not have been replaced easily by other firms
operating in the market or by alternative financial instruments

In a fast market, with many transactions
occurring over a short period . . . it
would be more difficult for other market
players to substitute promptly than in
a slow market.
(Brewer and Jackson 2000). Relationship-intensive products
also tend to be highly tailored to clients, and customization
slows substitution. Bank loans to small firms are bespoke
products, with pricing, covenants, maturity, and other terms
negotiated case by case. Syndicated loans to larger firms are
more standardized, and bonds (especially high-grade) and
stocks are even more so.
A second determinant of the speed or cost of substitution is
the knowledge or technology required to produce or price a
particular product. OTC derivatives can require considerable
sophistication to value and substantial platforms to manage
and market. For instance, a recent Federal Reserve study argues
that the complexity of interest rate options may hinder
substitutability in that market more than in the market for
more commoditized OTC interest rate swaps, where the risks
are linear and noncomplex in nature and the technology to
manage them is widely dispersed.23 Some products also require
more intermediation between users and “raw material”
suppliers. The knowledge, technology, and relationships
needed to make loans, for example, or to underwrite stocks or
bonds may be more widely held than those needed to generate
a supply of interest rate volatility for an options dealer.
Lastly, the speed and cost of substitution may depend on the
duration of the product in question and the “speed” of the
particular market. All else being equal, substitution will be
slower or costlier the longer the exposure implied by a
transaction. For instance, a long-term credit or counterparty
relationship implies a longer exposure than a one-off service
such as underwriting. The speed of the market—the frequency

of transactions and the time required between initiating and
consummating a transaction—also affects the speed of
substitution. In a fast market, with many transactions
occurring over a short period—payments, for example—it
would be more difficult for other market players to substitute
promptly than in a slow market.

5.2 Comparing Substitutability
across Markets
How do the markets we examined rank in terms of potential for
prompt substitution? It would be difficult to rank them directly
by the various characteristics just discussed, as some products
may not be very relationship-intensive yet still very technologyintensive. Instead of applying those characteristics directly, we
rank the markets by two simple proxies that should reflect the
overall potential for substitution: breadth and turnover.
Breadth is just the number of firms actively competing in the
market. A thicker, deeper market suggests easy entry and plenty
of substitutes. A thin or shallow market hints at informational
or technological barriers that limit entry and, by extension,

There are significant differences in
breadth and turnover across markets.
substitution. Turnover is the average change over time in the
market share ranking of firms in a given market.24 High
turnover means the leading firms are not entrenched and that
users are in fact switching between providers. Low turnover
suggests some friction—relationships or technological
barriers—that limits substitution among providers.
There are significant differences in breadth and turnover
across markets (Table 8). At one end, securities underwriting
markets are very deep and have relatively high turnover. The
numbers for market breadth may not fully capture the extent
of likely substitution, however, since small or midsize underwriters may not be able to substitute for top-tier firms. That
said, the fairly high level of the top-five ratios in underwriting
and financial services markets (Table 1) suggests the presence
of several interchangeable top-tier underwriters. The turnover
figures also suggest considerable movement in the hierarchy
Algebraically, turnover can defined by ∑ i ω i Δ ri , where Δ ri represents the
change in the ranking of the firm (i ) in two consecutive years. The change is
measured in absolute value, so any moves up and down will not cancel out.
Also, turnover is weighted by ω i (based on a firm’s asset size), so a move from
rank one to rank two counts substantially more than a move from rank fifty to
rank fifty-one.

24
22

A study by Polonchek, Sushka, and Slovin (1993) finds that when a bank is
on the verge of failure, the values of its borrowers rise and fall with the
prospects of the bank, precisely because investors know that firms may not
readily switch banks.
23
Board of Governors of the Federal Reserve System (2005).

FRBNY Economic Policy Review / March 2007

45

Table 8

Estimates of Substitutability for Financial Markets
Breadth:
Number of
Participants

Turnover:
Average Change
in Rank

Securities underwriting (1990-2004)
Initial public offerings
Seasoned offerings
Investment-grade bonds
High-yield bonds

100
60
40
30

4.03
3.64
1.95
2.54

Merger and acquisition
advisory services (1990-2004)

100

5.89

Syndicated loan (1990-2004)

40

3.10

Derivatives (2000-04)
Interest rate
Foreign exchange
Credit

40
40
40

2.21
1.57
1.63

Prime brokerage (2001-03)

35

0.69

Global custody (1994-2004)

20

0.87

Primary dealer (1995-2005)
Treasury bills
Coupons
TIPS (1999-2005)
Corporate securities (2002-05)
Mortgage-backed
Federal agency

21
21
21
21
21
21

3.67
2.15
2.79
1.35
2.43
2.44

Market

Mean turnover, all markets

2.50

Sources: Securities Data Corporation; Loan Pricing Corporation; Board
of Governors of the Federal Reserve System, Weekly Report of Dealer
Transactions (FR 2004B); Buttonwood International, The Global Custody
Yearbook; Bank for International Settlements, Triennial and Semiannual
Surveys on Positions in Global Over-the-Counter Derivatives Markets
(2004); HedgeWorld.com; company annual reports.
Notes: Estimates of market breadth represent the approximate number of
firms that are actively participating, and collectively account for most
of the business in each market. The turnover measure is weighted by
market share. Periods in parentheses indicate the sample over which
estimates are derived. Estimates for derivatives markets are calculated
from the U.S. Reporter Survey, company annual reports, and call
reports. TIPS is Treasury Inflation-Protected Securities.

of underwriters over time, some of which can be attributed
to bank entry, as noted above. The high turnover ratios in
the M&A advisory services and syndicated loan markets
also signify major changes in the hierarchy of top-tier
underwriters. Overall, high breadth and turnover in these
underwriting markets suggest the potential for reasonably
fluid substitution.
Turnover in secondary-market securities trading by
primary dealers is also relatively high. The exception is trading

46

Trends in Financial Market Concentration

in corporate securities, where the turnover figure is about half
that for many of the other security types, perhaps reflecting
less-than-full coverage of all market participants in these data.
The breadth measures are perhaps somewhat less relevant for
these markets, as primary dealer status is regulated by the
Federal Reserve. As noted above, the primary dealer data may
not cover the full range of participants in these activities for
non-Treasury securities.
In contrast with underwriting, M&A advisory services, and
trading, turnover in the derivatives markets is considerably
lower. To calculate the breadth and turnover numbers for these
markets, we combine detailed data on U.S. participants with
data derived from annual reports for major non-U.S. dealers.25

In contrast with underwriting, M&A advisory
services, and trading, turnover in the
derivatives markets is considerably lower.
The resulting figures combine activity across several derivatives
products (swaps, options, and forwards) by the nature of
the underlying instrument (FX, interest rate, and credit
derivative). Although the markets are arguably distinct across
some of these product types, we view the aggregate turnover
figures as reasonably representative of the submarkets.
As intermediaries between sellers and buyers of options or
swaps, top-tier derivatives dealers require ready and steady
access to financial instruments (for example, callable debt or
structured notes) or investors and clients (hedge funds) to
facilitate these complex transactions. Top-tier derivatives
dealers are required to commit significant investments and
resources to building the infrastructure and maintaining these
important trading relationships. Consequently, the exit of a
large derivatives dealer would probably require a concerted
effort by other top-tier dealers to fill the gap.26
The turnover ratio in prime brokerage during the 2001-03
period is also significantly lower than it is for underwriting
markets. This low estimate reflects the continued dominance of
just a few firms. However, the recent boom in hedge funds has
encouraged more aggressive entry in the industry, as evidenced
25

The global data from the BIS survey are available only in aggregate form, not
on the firm-by-firm basis needed to calculate our turnover measure. While the
BIS survey focuses on OTC products, it is not always possible to separate out
OTC and exchange-traded derivatives from the annual reports. Thus, the
reported turnover and concentration measures for interest rate and FX may
include both OTC and exchange-traded products.
26
For a full discussion of tiering in the OTC U.S. dollar interest rate options
market and a discussion of the structure of that market more generally,
see Board of Governors of the Federal Reserve System (2005).

by the 5 percent decline in the market share of the two largest
firms, mostly captured by commercial bank competitors.
The low turnover scores in derivatives and prime brokerage
markets are not surprising, because they do not meet the
prompt-substitutability criteria outlined earlier. These markets
rely heavily on client relationships that are often built over a
number of years. OTC derivatives products and prime
brokerage services are continually evolving to meet the
changing needs of the financial community and clients. Both
markets require an extensive infrastructure to satisfy their
sophisticated customers. As we discussed, OTC dealers have to
commit significant resources to building and maintaining a
trading infrastructure. Similarly, in prime brokerage hedge
fund clients require integrated products and services that
encompass trading in complex financial assets, financing
(margin and securities lending), and customer support services.

Chart 7

Market Concentration and Turnover
HHI
2,500

HHI x Turnover
K

2,000

N

1,500

J

P

C
I

500

B

Q

G

H

E

A

D

O

1,000

F

L
M

0
0

1

2

3
4
Turnover

5

6

7

6

7

Top-five market share
100

Top-Five Share x Turnover

90

K

80

5.3 The Concentration-Substitution
Dimension

J

P

N

70
O

60

C
I

50

A
D
Q

F

E

B

The potential for market instability depends not just on
concentration, we have argued, but also on the potential
for prompt substitution. To summarize these potential
determinants of instability, we use a graphical approach to
classify markets based on concentration and turnover.
Although this approach lacks the specificity that detailed case
studies of individual markets might offer, it has the advantage
of being easy to calculate using available market share information for a wide number of markets. Thus, we argue, it
is a useful first-cut indicator of the likely severity of market
disruption that can be used to rank markets and prioritize
resources for further investigation.
The resulting concentration-substitution comparison is
given in Chart 7. The chart arrays the seventeen markets we
have examined by our measure of market turnover (along the
x-axis) and by two different measures of market concentration
(along the y-axis). The first measure of concentration is the
HHI, which summarizes the overall degree of concentration in
each market. The second measure is the market share of the five
largest firms in the market. Empirically, the two measures are
correlated. However, the top-five market share measure may
help us identify markets where the largest participants have
very large market shares, even if the overall market appears not
to be highly concentrated based on the HHI.27
As it turns out, the results from the two different
concentration measures are quite similar. The figures show no
systematic relationship between concentration and turnover.28

A possible objection to our analysis might be that a market with
a naturally high level of turnover is also a market where the
dynamics of entry and exit are such that one would never

27

28

This could happen if one or two firms had large market shares but there were
many other small competitors.

H

40

M

G

L

30
20
0

1

2

3
4
Turnover

A – Initial public offerings
B – Seasoned offerings
C – Investment-grade bonds
D – High-yield bonds
E – Merger and acquistion
advisory services
F – Syndicated loans
G – Interest rate derivatives
H – Foreign exchange
derivatives

5

I – Credit derivatives
J – Global custody
K – Prime brokerage
L – Treasury bills
M – Nominal coupon securities
N – Treasury Inflation-Protected
Securities
O – Corporate securities
P – Mortgage-backed securities
Q – Federal agencies

Sources: Securities Data Corporation; Loan Pricing Corporation;
Board of Governors of the Federal Reserve System, Weekly Report
of Dealer Transactions (FR 2004B); Buttonwood International,
The Global Custody Yearbook; Bank for International Settlements,
Triennial and Semiannual Surveys on Positions in Global Over-theCounter Derivatives Markets (2004); HedgeWorld.com; company
annual reports.
Notes: The chart plots the measure of market turnover by two
different measures of market concentration for the seventeen markets
examined in this article. HHI is the Herfindahl-Hirschman Index.

The correlations between turnover and the top-five market share and HHI
variables are negative but not statistically significant.

FRBNY Economic Policy Review / March 2007

47

observe a high level of concentration (the substitutability
indicates low barriers to entry and hence low incumbent
advantage). That we do not observe any relationship indicates
instead that the two market characteristics convey independent
information on market stability.
Focusing on market-specific patterns, Chart 7 also indicates
that relatively few markets appear to be in the potentially
unstable neighborhood of high concentration and low

By focusing solely on market
concentration, one misses important
factors influencing market stability.

turnover (the upper-left-hand regions). Among the markets
we examine, prime brokerage and global custody tend most
strongly to fall into this region. While some other markets have
relatively low turnover (for example, the FX, interest rate, and
credit derivatives markets), they have low concentration, even
when the markets are split into the more disaggregate subcategories by product type. Two other markets with somewhat
high concentration—the mortgage-backed-security (MBS)
and TIPS primary dealer markets—also have relatively high
turnover. It is not unusual initially to observe higher concentration in newly created markets such as the TIPS and MBS
markets. As the markets have matured, concentration has
come down with the entry of additional primary dealers.
As this simple example suggests, more detailed analysis is
necessary to understand the true stability characteristics of
particular markets. Such analysis could include examining
trends in concentration, considering additional measures of
concentration and market substitutability, and conducting
descriptive case studies of individual markets.29 In our view,
the basic analysis in Chart 7 is not sufficient to draw strong
conclusions about individual markets in the absence of more
detailed study. Instead, our point in presenting the chart is that
by focusing solely on market concentration, one misses
important factors influencing market stability. In particular,
understanding the extent to which prompt substitution can
take place is a crucial second factor in assessing financial
market stability.

29

See Board of Governors of the Federal Reserve System (2005) for an example
of a detailed market study—in this case, that of the OTC markets for U.S.
dollar interest rate options.

48

Trends in Financial Market Concentration

6. Conclusion
Our review of the literature shows that, theoretically, higher
concentration may either increase or decrease the probability
of a firm leaving the market as a result of distress. However,
anecdotal evidence, and common sense, indicates that the
market disruption generated by such an event would be more
severe in concentrated markets. Hence, even if concentration
were to reduce firms’ incentives to take risk and thus the
potential for distress, public oversight would still be justified.
We find that market concentration has not followed a
universal upward trend: concentration has increased in some
markets and fallen in others. Markets have become more
interdependent, it seems, as the same small set of financial
firms has become more dominant across multiple markets.
We argue that the risk or severity of financial instability
depends not just on concentration, but also on whether other
firms can promptly substitute for an exiting firm. By examining
the concentration-substitution dimension, we are able to
identify potentially problematic areas where the exit of a large
player might exacerbate financial instability.
What does our analysis say about the role of policymakers?
If the severity of disruptions is limited by the availability of
ready substitutes, what can or should policymakers do to
enhance substitution? The answer depends on those factors
that limit substitution in the first place. If close relationships
are the limiting factor, laissez-faire may be optimal. Financial
relationships are delicate, dynamic, and sometimes implicit
contracts that are probably hard to improve from the top
down. However, if the drag on substitution is customized
products, policymakers might help in efforts to standardize.
Standardization is a public good or externality, so public
officials are right to lead efforts in that direction.30 The recent
initiative to remove the backlog of uncleared derivatives transactions and to hasten future clearing appears to be a good step.
Policymakers may also have a say when the friction that limits
substitution is some technological barrier; if privileged access
to a key trading or pricing platform entrenches dominant
providers and limits the choices of users, policymakers clearly
have a legitimate interest to ensure both stability and
competition.

30

All producers might gain from standardization, but no individual producer
may have an incentive to lead and coordinate standardization initiatives.

Appendix: Price Stability and Market Concentration—Econometric Strategy

We describe our investigation of the link between price
stability and market concentration. The analysis focuses on
investment-grade bonds and syndicated loans because pricing
information is more transparent in these two markets.
Information on corporate bond issuance was obtained from
the Thomson Financial Securities Data Corporation database.
The final sample of bond issues excludes convertible issues
and offerings by financial companies. The Loan Pricing
Corporation DealScan database provides extensive
information on syndicated loans granted to large and midsize
corporations.
The price of an investment-grade bond at issue is defined by
its credit spread (yield to maturity minus a comparablematurity Treasury yield). Similarly, for syndicated loans the
price is measured by the credit spread over LIBOR. The
relationship between price stability and concentration is
derived from a two-step estimation procedure. Let yti
represent the bond (or loan) spread for firm ( i ) at time ( t ).
In the first stage, the credit spread is regressed on a set of
explanatory variables defined by the vector x ti • . In particular,
(A1)

yti = αt + β x ti • + u ti .

The initial price of corporate bonds or syndicated loans is
primarily determined by borrower and deal characteristics
represented by xti • and macroeconomic conditions measured
by the time-varying parameter αt . In the case of bonds, xti •
includes the Standard and Poor’s (S&P) rating and firm size
to capture the creditworthiness of the issuer. The bond price
regression also controls for issue characteristics that are normally expected to affect the price of the security. In particular,
we control for bond maturity, coupon rate, callability, sinking
fund provisions, subordinate debt, and 144a issues.
In the case of loans, xti • includes both a set of firm-specific
variables and loan-specific variables. Included in the former
set are proxies for the overall risk of the firm, such as its age
and sales; proxies for the risk of the firm’s debt, such as the
firm’s profit margin, its interest coverage, leverage, and
earnings volatility; and proxies for the losses the firm’s debt
holders can incur in the event of default, such as the firm’s
tangible assets and the firm’s net working capital (current
assets less current liabilities) divided by total debt. The
regression controls for the firm’s growth opportunities and its

sector of activity. We also control for loan-specific variables,
including controls for the purpose of the loan and for the type
of loan contract; controls to distinguish, among other things,
loans that are senior, those that are secured, and those that
have a guarantor; and information on the maturity of the loan,
its size, and variables to control for the size of the loan
syndicate.
The first-stage regression residual measure û ti represents
the portion of the credit spread not explained by fundamentals.
This component includes all the idiosyncratic shocks that may
affect the issue markets. In the second stage of the estimation,
we use the squared residuals û ti2 to construct a measure of price
instability. This quality-adjusted volatility measure is next
regressed on the annual Herfindahl-Hirschman Index (HHI)
of market concentration,
(A2)

2

û ti2 = γ 0 + γ 1 HHI t + γ 2 HHI t + ε ti .

Essentially, equation A2 asserts an additive form of heteroskedasticity on the error structure of the price equation A1.
To obtain asymptotically efficient estimators, we use an
iterative procedure described in Kmenta (1986).
The results of the first-stage estimation are not reported in
this article. As expected, in the case of bonds the S&P rating is
the most significant variable impacting bond spreads. A onenotch increase in the S&P rating (for example, from BBB to
BBB+) lowers the spread on investment-grade bonds by
roughly 12 basis points. Callability and bond maturity are also
important factors increasing the costs to bond issuers.
The coefficients for the control variables in our model on
loan spreads are generally consistent with what we would
expect. Older and larger firms, as well as firms with more
tangible assets, pay significantly lower spreads. The market-tobook ratio comes in strongly negative. Our proxies for default
risk have their expected signs, and all but profit margin is
strongly significant. The statistical insignificance of profit
margin is likely due to the inclusion of interest coverage in our
model. Our loan-specific controls are also generally consistent
with our expectations. In contrast to the purpose of the loan,
which appears to play only a limited role in the loan interest
rate, the type of loan contract is important in this regard.
Credit lines, for example, carry lower interest rates than do
term loans and bridge loans. The other loan controls show that

FRBNY Economic Policy Review / March 2007

49

Appendix: Price Stability and Market Concentration—Econometric Strategy
(Continued)

larger loans and loans extended by larger syndicates have lower
spreads. Loan features that increase loan safety (dividend
restrictions, secured interests, guarantors, and sponsors)
generally have positive effects on spreads. This finding is
consistent with the well-established result that banks tend to
require these features for riskier credits. Finally, longer term
loans have lower spreads, but the effect is not statistically
significant.

50

Trends in Financial Market Concentration

Regarding the second stage of our method, we find that the
estimates for the parameter vector ( γ 0 , γ 1 , γ 2 ) of the additive
specification are significant for both investment-grade bonds
and syndicated loans. Chart 1 illustrates more clearly the
nonlinear volatility-concentration relationships for
investment-grade bonds and syndicated loans estimated
from the second-stage equation A2.

References

Allen, F., and D. Gale. 2000. Comparing Financial Systems.
Cambridge, Mass.: MIT Press.
Altman, E. I., and S. A. Nammacher. 1987. Investing in Junk Bonds:
Inside the High Yield Debt Market. John Wiley and Sons.

De Nicoló, G., P. F. Bartholomew, J. Zaman, and M. G. Zephirin. 2003.
“Bank Consolidation, Internationalization, and Conglomeration:
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no. 3/158, July.

Beck, T., A. Demirguc-Kunt, and R. Levine. 2003. “Bank Concentration
and Crises.” NBER Working Paper no. 9921, August.

Dick, A. A. 2006. “Nationwide Branching and Its Impact on Market
Structure, Quality, and Bank Performance.” Journal of
Business 79, no. 2 (March): 567-92.

Benveniste, L. M., M. Singh, and W. J. Wilhelm. 1993. “The Failure
of Drexel Burnham Lambert: Evidence on the Implications for
Commercial Banks.” Journal of Financial Intermediation 3,
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Edwards, F., and F. Mishkin. 1995. “The Decline of Traditional
Banking: Implications for Financial Stability and Regulatory
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Board of Governors of the Federal Reserve System. 2005. “Concentration
and Risk in the OTC Markets for U.S. Dollar Interest Rate
Options.” Report prepared by the staffs of the Board of Governors
of the Federal Reserve System and the Federal Reserve Bank of
New York. Available at <http://www.federalreserve.gov/
boarddocs/surveys/OpStudySum/OptionsStudySummary.pdf>.

Hellman, T. F., K. C. Murdock, and J. E. Stiglitz. 2000. “Liberalization,
Moral Hazard in Banking, and Prudential Regulation: Are Capital
Requirements Enough?” American Economic Review 90, no. 1
(March): 147-65.

Boyd, J. H., and G. De Nicoló. 2005. “The Theory of Bank Risk Taking
and Competition Revisited.” Journal of Finance 60, no. 3
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Brewer, E., and W. E. Jackson. 2000. “Requiem for a Market Maker:
The Case of Drexel Burnham Lambert and Junk Bonds.” Journal
of Financial Services Research 17, no. 3 (September): 209-35.

Hentschel, L., and C. W. Smith, Jr. 1994. “Risk and Regulation in
Derivative Markets.” Journal of Applied Corporate
Finance 7, no. 3 (fall): 8-21.
Keeley, M. C. 1990. “Deposit Insurance, Risk, and Market Power in
Banking.” American Economic Review 80, no. 5 (December):
1183-1200.
Kmenta, J. 1986. Elements of Econometrics. Macmillan.

Carlin, B., M. Lobo, and S. Viswanathan. 2004. “Episodic Liquidity
Crises: The Effect of Predatory and Cooperative Trading.”
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Polonchek, J. A., M. E. Sushka, and M. B. Slovin. 1993. “The Value
of Bank Durability: Borrowers as Bank Stakeholders.” Journal
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Demsetz, R. S., and P. E. Strahan. 1997. “Diversification, Size, and Risk
at Bank Holding Companies.” Journal of Money, Credit, and
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Stiroh, K. J. 2006. “A Portfolio View of Banking with Interest and
Noninterest Activities.” Journal of Money, Credit, and
Banking 38, no. 5 (August): 1351-62.

The views expressed are those of the authors and do not necessarily reflect the position of the Federal Reserve Bank of New York
or the Federal Reserve System. The Federal Reserve Bank of New York provides no warranty, express or implied, as to the
accuracy, timeliness, completeness, merchantability, or fitness for any particular purpose of any information contained in
documents produced and provided by the Federal Reserve Bank of New York in any form or manner whatsoever.
FRBNY Economic Policy Review / March 2007

51

Kenneth D. Garbade

The Emergence of
“Regular and Predictable”
as a Treasury Debt
Management Strategy
• In 1975, the U.S. Treasury had to finance a
rapidly growing federal deficit with sales of
new notes and bonds on an offering-byoffering basis.

• Because the timing and maturities of these
“tactical” offerings did not follow a predictable
pattern, the issuances sometimes caught
investors off guard and disrupted the market.

• Treasury officials, recognizing the need for
more regularized offerings, revised the
framework within which they selected the
maturities of new notes and bonds.

• By 1982, the Treasury had abandoned tactical
issuance and was following a “regular and
predictable” schedule of new note and bond
offerings.

• The move to regular and predictable issuance
was widely credited with reducing market
uncertainty, facilitating investor planning, and
lowering the Treasury’s borrowing costs.

Kenneth D. Garbade is a vice president at the Federal Reserve Bank of New York.
<kenneth.garbade@ny.frb.org>

1. Introduction

T

reasury debt management is the set of actions taken by
U.S. Treasury officials in the course of financing the
federal deficit and refinancing maturing debt. An important
dimension of debt management is the decision of which
maturity debt to sell. On the one hand, short-term financing
can complicate budget planning because it raises the variability
of near-term interest expenses; on the other, longer term
borrowings have a higher expected cost because of term premia
on intermediate- and long-term interest rates.
During the 1970s, Treasury officials revised the framework
within which they selected the maturities of new notes and
bonds. Previously, they chose maturities on an offering-byoffering basis, typically after surveying market participants to
identify investor demand for different maturities. By 1982, the
Treasury had abandoned this type of “tactical” debt management and was selling notes and bonds on a “regular and
predictable” schedule, with monthly offerings of two-year
notes and quarterly sales of longer term securities.
The switch from tactical to regular and predictable debt
management is illustrated in Charts 1 and 2. Between 1960 and
1964, the Treasury made regular quarterly offerings, for cash or
in exchange for maturing debt, of coupon-bearing securities in
February, May, August, and November of each year (Chart 1).

The author thanks Megan Cohen, Jeff Huther, Paul Malvey, Kara Masciangelo,
William Silber, Charles Steindel, Paul Volcker, and two anonymous referees for
help researching this article and for comments on earlier drafts. The views
expressed are those of the author and do not necessarily reflect the position
of the Federal Reserve Bank of New York or the Federal Reserve System.

FRBNY Economic Policy Review / March 2007

53

Chart 1

Chart 2

Maturities of Offerings of Coupon-Bearing Securities,
January 1960-December 1964

Maturities of Offerings of Coupon-Bearing Securities,
January 1982-December 1986

Maturity (years)

Maturity (years)

30

30
Midquarter
refundings

25

Other
offerings

Midquarter
refundings

25

20

20

15

Other
offerings

15
10
10
5
5
0
1960

61

62

63

64
0
1982

Source: Federal Reserve Bank of New York circulars (1960-64).

83

84

85

86

Source: U.S. Department of the Treasury, Bureau of the Public Debt.

The number and maturities of these tactical “midquarter
refundings,” though, varied from quarter to quarter. The only
persistent feature was the appearance of an “anchor” issue
maturing in one to one and a half years. As Chart 1 shows, the
Treasury also sold coupon-bearing securities outside of
midquarter refundings on nine occasions between 1960 and
1964. However, neither the timing of the nine issues nor their
maturities followed any readily apparent pattern.
By comparison, the regularity of the Treasury’s offerings
between 1982 and 1986 is striking (Chart 2). The Treasury
continued to sell coupon-bearing securities in the middle of
each quarter, but offered the same maturities in every
refunding: a three-year note, a ten-year note, and, with two
exceptions, a thirty-year bond.1 Additionally, it sold two-year
notes monthly; four-, five-, and seven-year notes quarterly;
and, with two exceptions, twenty-year bonds quarterly until
terminating the twenty-year series in the spring of 1986. The
Treasury sold two-, three-, and ten-year notes and thirty-year
bonds in amounts that did not vary substantially from offering
to offering (Charts 3 and 4). Other series exhibited a similar
pattern of substantially comparable amounts sold from
offering to offering.
This article examines why, during the 1970s, Treasury
officials changed the framework within which they made their

debt management decisions. We show that the Treasury
financed an unusually rapid expansion of the deficit in 1975
with a flurry of tactical offerings. The offerings disrupted the
market and provided the impetus to adopt a program of
regular and predictable issuance that allowed investors to plan
future commitments of funds with greater confidence.
The emergence of regular and predictable as a Treasury debt
management strategy is important for three reasons. First, this
type of issuance is one of the pillars of the modern Treasury
securities market. In 1982, Mark Stalnecker, Treasury Deputy
Assistant Secretary for Federal Finance, expressed the view that
“regularity of debt management removes a major source of
market uncertainty, and assures that Treasury debt can be sold
at the lowest possible interest rate consistent with market
conditions at the time of sale.”2 More recently, Gary Gensler,
Treasury Assistant Secretary for Financial Markets, observed
that “consistency and predictability in [the Treasury’s]
financing program … reduces uncertainty in the market and
helps minimize our overall cost of borrowing.”3 Second, the
circumstances that led to regular and predictable issuance
illustrate the costs of tactical issuance, and the benefits of
2

Committee on Banking, Finance, and Urban Affairs (1982, p. 5).

3
1

Following the February 1982 midquarter refunding, the Treasury exhausted
its authority to issue bonds with coupon rates in excess of a statutory ceiling of
4¼ percent. It was limited to issuing bills and notes until Congress increased
the exemption following the August 1982 refunding.

54

The Emergence of “Regular and Predictable”

Testimony before the House Committee on Ways and Means, June 24, 1998
(available at <http://www.treas.gov/press/releases/rr2555.htm>). Gensler went
on to note that “in keeping with this principle, Treasury does not seek to time
markets; that is, we do not act opportunistically to issue debt when market
conditions appear favorable.”

Chart 3

Chart 4

Monthly Sales of Two-Year Notes,
January 1982-December 1986

Sales of Three-Year Notes, Ten-Year Notes,
and Thirty-Year Bonds in Midquarter Refundings,
January 1982-December 1986

Quantity sold (billions of dollars)
15

Quantity sold (billions of dollars)
15

12

Three-year notes

Ten-year notes

Thirty-year bonds

12
9
9
6
6
3
3
0
1982

83

84

85

86

0
1982

Source: U.S. Department of the Treasury, Bureau of the Public Debt.

83

84

85

86

Source: U.S. Department of the Treasury, Bureau of the Public Debt.

predictability, in an environment of large deficits. Finally, the
emergence of regular and predictable issuance shows how a
change in the economic environment can induce policymakers
to alter the practices of the institutions they manage.
The first half of the 1970s also witnessed the successful
introduction of auction sales of notes and bonds. There is an
important connection between this development and the
emergence of regular and predictable issuance: Treasury bills

The Treasury did try to institutionalize
auction sales of Treasury bonds in 1935
and again in 1963, but failed in both
attempts.
provided a template for both actions. This raises the question
of why, since the Treasury had been auctioning bills on a
regular and predictable basis for decades, it did not introduce
regular auction sales of notes and bonds at an earlier date.4
In fact, the Treasury did try to institutionalize auction sales of
Treasury bonds in 1935 and again in 1963, but failed in both
attempts.5 The earlier attempts suggest that officials appreciated the advantages of auction sales of notes and bonds long
before they were able to institutionalize such sales. Conversely,
the absence of any attempt to introduce regular and predictable
4

The Treasury first issued bills in 1929; it began auctioning bills on a regular
and predictable basis in the early 1930s. Some of the same observers who
advocated auction sales of notes and bonds in the late 1950s and early 1960s
also advocated regular and predictable sales of those securities. See Joint
Economic Committee (1959, p. 3024, testimony of Milton Friedman),
Friedman (1960, pp. 60-5), and Gaines (1962, ch. 8).

sales of notes and bonds before 1972 suggests that, prior to
that time, tactical flexibility may have been perceived as
more beneficial.
Our study proceeds as follows. Section 2 presents an
overview of the goals and instruments of Treasury debt
management and the choice between tactical and regular and
predictable issuance. In Section 3, we explain how the Treasury
conducted financing operations in the 1960s. The Treasury’s
initial steps toward “regularizing” short-term notes in 1972 are
examined in Section 4. We explain in Section 5 how rapid
growth of the deficit in 1975 led the Treasury to begin
embracing regular and predictable issuance more completely.
Section 6 presents empirical evidence consistent with the
hypothesis that regular and predictable issuance mitigated a
cost of tactical issuance. Finally, we briefly describe in Section 7
the subsequent development of debt management policy
within the framework of regular and predictable issuance.

2. Goals and Instruments
of Debt Management
Debt management has goals, or objectives, and it has decision
variables that managers have to choose to advance toward their
stated goals.
5

Garbade (2004) suggests that the Treasury failed in its earlier attempts
primarily because it began by auctioning long-term bonds. The Treasury was
more successful when, in the early 1970s, it began by auctioning short-term
notes and then gradually extended the maturities of its offerings. The gradual
extension gave dealers an opportunity to build up their risk management and
sales programs in an orderly fashion.

FRBNY Economic Policy Review / March 2007

55

Financing at least cost over time is the most frequently
and consistently cited goal of Treasury debt management.
Andrew Mellon, Secretary of the Treasury from March 1921
to February 1932, was said to manage the public debt “by
providing various types of securities suited to the needs of
various classes of lenders, thereby obtaining funds for needed
periods at minimum cost.”6 Robert Roosa, Treasury Under
Secretary for Monetary Affairs from January 1961 to December

Financing at least cost over time is the
most frequently and consistently cited
goal of Treasury debt management.
1964, observed that Treasury debt “must be placed at an
interest cost that will stand up to the critical test of both the
Congress and the public who do not want to have any more
money devoted to the debt service . . . than is necessary.”7
The Treasury has sometimes announced debt management
goals in addition to least-cost financing. During the 1960s,
Treasury officials sometimes made debt management decisions
to maintain upward pressure on short-term interest rates (to
support the value of the dollar in foreign exchange markets)
and/or to limit upward pressure on long-term interest rates
(to promote economic growth).8 In the 1990s, officials focused
on three debt management goals, including ensuring the availability of adequate cash balances and promoting efficient
capital markets as well as financing at least cost.9
More recently, however, Peter Fisher, Under Secretary of
the Treasury from August 2001 to October 2003, observed that
ensuring the availability of adequate cash balances is a
constraint on, rather than a goal of, debt management and that
the single objective of financing at least cost best describes the
basis for Treasury debt management decisions.10
6

Simmons (1947, p. 334).
Roosa (1963).
8
The resulting decisions to sell short-term debt in lieu of long-term debt were
typically made in the context of some version of the “segmented markets”
theory of the term structure of interest rates, which implies that debt securities
of different maturities are imperfect substitutes and that exogenous variation
in the maturity composition of the debt can affect the shape of the yield curve.
See Culbertson (1957). See also the “preferred habitat” theory proposed by
Modigliani and Sutch (1966, 1967) and the analysis in Modigliani and Sutch
(1966) of the attempt by Treasury and Federal Reserve officials to alter the
shape of the yield curve by raising short-term rates and reducing, or at least
maintaining, long-term rates in what became known as “Operation Twist.”
9
Testimony of Gary Gensler, Treasury Assistant Secretary for Financial
Markets, before the House Committee on Ways and Means, June 24, 1998
(available at <http://www.treas.gov/press/releases/rr2555.htm>), and
testimony of Lewis Sachs, Treasury Assistant Secretary for Financial Markets,
before the House Committee on Ways and Means, September 28, 1999
(available at <http://www.treas.gov/press/releases/ls128.htm>).
7

56

The Emergence of “Regular and Predictable”

The primary decision variables of Treasury debt
management are the quantities of debt to be sold at different
maturities. Other important decision variables include the type
of offering, that is, a fixed-price subscription offering or an
auction offering in either a single-price or multiple-price
format, and whether the Treasury is obligated to repay fixed
nominal amounts or amounts indexed to current prices (as has
been the case with inflation-protected securities issued since
1997).
This article examines the emergence of a self-imposed
constraint on the Treasury’s method of choosing the timing
and maturities of new issues. As illustrated in Section 7, the
constraint limits the frequency with which the timing and
maturities of new offerings are changed. Treasury officials
adopted the constraint to advance the always important (and,
more recently, unique) goal of financing at least cost. As we
show in the next section, prior to 1970, tactical issuance
preserved a high level of managerial discretion that allowed
debt managers to shift the focus of their decision-making

The primary decision variables of Treasury
debt management are the quantities of
debt to be sold at different maturities.
literally from offering to offering. It also allowed debt managers
substantial flexibility as to when they would raise new money
with sales of coupon-bearing debt. However, tactical issuance
had a downside: investors could not readily anticipate what
maturity debt the Treasury would choose to sell and they could
not easily anticipate when the Treasury would sell notes and
bonds outside of the midquarter refundings. The downside
became excessively costly when Treasury officials had to
finance unprecedented peacetime deficits after 1974. In order
to facilitate investor planning and thereby reduce Treasury
borrowing costs, the officials began to adopt a more regular
and predictable issuance schedule.

3. Debt Management in the 1960s
In mid-1960, the marketable public debt of the United States
was $184 billion, including $33 billion in bills, $18 billion in
certificates of indebtedness, and $133 billion in notes and
10

Remarks of Under Secretary of the Treasury Peter Fisher to the Futures
Industry Association, March 14, 2002 (available at <http://www.treas.gov/
press/releases/po1098.htm>). See also remarks of Assistant Secretary of the
Treasury Brian Roseboro to the UBS Eighth Annual Reserve Management
Seminar for Sovereign Institutions, June 3, 2002 (available at <http://
www.treas.gov/press/releases/po1349.htm>).

bonds. Bills were single-payment instruments maturing in a
year or less; the other three instruments made semi-annual
coupon payments. A certificate of indebtedness matured in no
more than a year from its date of issue; notes matured in no
more than five years. A bond could have any term but could
not be issued with a coupon rate in excess of 4¼ percent.11
There were four distinct types of Treasury financings at the
beginning of the 1960s: bill financings, midquarter refundings,
stand-alone offerings, and advance refundings. All but the last
were mechanisms for borrowing money to finance the federal
deficit and to refinance maturing debt.12

3.2 Midquarter Refundings
By 1960, maturing coupon-bearing debt was refinanced
exclusively in midquarter refundings. Offerings were sometimes in exchange for maturing debt and sometimes for cash.
New issues were always set to mature on the fifteenth of the
second month of a quarter so they could be refinanced in
subsequent refundings.
An exchange offer was an offer to exchange a new issue for an
equal principal amount of a maturing issue and was available
only to holders of the maturing debt. An investor who was not

Midquarter refundings followed a regular
routine. Toward the middle of the first
month of each quarter, Treasury officials
solicited the advice of market participants
on what maturities were currently in
demand and then held a press conference
to announce what would be offered.

3.1 Bill Financings
The Treasury used bills to bridge the gap between cash
management and debt management and to finance a portion of
the debt at low short-term interest rates. Thirteen-week bills
had been auctioned on a regular weekly basis since 1937. In late
1958, the Treasury began a parallel program of regular weekly
auctions of twenty-six-week bills “to place on a routine basis,
so far as practicable, the roll-over of … debt maturing within
one year.”13 The sizes of the thirteen- and twenty-six-week-bill
auctions varied from time to time, but investors knew the
auctions would be held and they knew the amounts offered
would be comparable to what was maturing—perhaps a bit less
if the government was flush with cash or a bit more if cash
balances were low. In early 1959, the Treasury further
expanded its bill offerings by introducing regular quarterly
sales of one-year bills, to be issued on or about the fifteenth of
the first month of a quarter and to mature a year later.14

11

The 4¼ percent ceiling on Treasury bond rates was established by the Third
Liberty Bond Act (April 4, 1918). A brief history of the rate ceiling appears in
Committee on Ways and Means (1967, pp. 25-8).
12
An advance refunding was an offer to exchange a new security for an equal
principal amount of an existing, shorter term security that was not close to
maturity. For example, an advance refunding in October 1960 gave investors
an opportunity to exchange a bond maturing in nine years for an equal
principal amount of a bond maturing in thirty-eight years. Treasury officials
introduced advance refundings in 1960 when they became concerned that a
growing concentration of Treasury indebtedness in short-term securities
might be contributing to inflation (U.S. Treasury Department 1960, p. 4; Beard
1966, p. 7). See also Committee on Finance (1962) and Bryan (1972). Advance
refundings did not play any substantial role in the emergence of regular and
predictable issuance.
13
Federal Reserve Bank of New York Circular no. 4663, November 18, 1958.
14
The Treasury also used irregular offerings of “tax anticipation bills” to
smooth seasonal variations in tax receipts. Tax anticipation bills were first
introduced in 1951 (Nelson 1977).

interested in exchanging a maturing issue could either sell the
debt to another investor who wanted to acquire the new issue
or present the debt for redemption. The fraction of a maturing
issue presented for redemption was known as “attrition.”
A cash offering was made at a fixed price and was open to all
investors. Subscriptions were filled on a pro-rata basis. Cash
refundings allowed the Treasury to raise modest amounts of
new cash by offering somewhat more than what was needed to
redeem maturing debt.
Midquarter refundings followed a regular routine. Toward
the middle of the first month of each quarter, Treasury officials
solicited the advice of market participants on what maturities
were currently in demand and then held a press conference to
announce what would be offered.15 Subscription books opened
within a week of the announcement and remained open for
several days, after which the Treasury announced the results
and began to fill subscriptions. The entire process was
completed by the middle of the second month of the quarter.
Box 1 describes the origin of midquarter refundings.
15

Although the Treasury kept in regular contact with a variety of market
participants (Committee on Government Operations 1956, p. 113), it
particularly solicited the views of several advisory committees when it
contemplated a major operation. Committee members reflected their
“impressions of what the market demand and supply is” (p. 50) and what
they thought “could best be sold” (p. 63).

FRBNY Economic Policy Review / March 2007

57

Box 1

The Origin of Midquarter Refundings
The Treasury introduced midquarter refundings during the 1950s
to ease constraints on the conduct of monetary policy. Both cash
subscription offerings and exchange offerings were made on fixed
terms: an investor could only accept or reject the terms proposed
by the Treasury. A decision by Federal Reserve officials to tighten
monetary policy during the five to seven days between the
announcement of a new offering and the close of the subscription
books therefore was liable to jeopardize the success of the offering.
Following the Treasury-Federal Reserve Accord of March 1951
and the restoration of Federal Reserve control of monetary policy,
Federal Reserve officials adopted a policy of maintaining a fixed
monetary policy during Treasury offerings.a Concentrating the
Treasury’s longer term financings in four quarterly windows
minimized the amount of time that the Treasury was in the market
and thus maximized the amount of time during which monetary
policy could be changed. Quarterly refundings also reduced direct
competition with other issuers by providing constructive notice
about when the Treasury would be in the market. By late 1958,
80 percent of coupon-bearing Treasury debt was scheduled to
mature on the fifteenth of February, May, August, or November
of some future year.b

a
This policy was sometimes known as “even keeling.” See Gaines (1962,
pp. 241-3, 264), Struble and Axilrod (1973), and Committee on Banking,
Finance, and Urban Affairs (1982, pp. 32-3, testimony of Stephen Axilrod,
Staff Director for Monetary and Financial Policy, Board of Governors of
the Federal Reserve System).

3.4 Debt Management Decisions
The variation in marketable Treasury debt in the 1960s is illustrated in Chart 5. Indebtedness did not decline, so midquarter
refundings remained important. However, indebtedness did
not grow rapidly, so stand-alone cash subscription offerings
remained relatively unimportant. Marketable debt increased
from $184 billion in 1960 to $226 billion in 1969, or less than
$5 billion per year. The Treasury financed $17 billion of the
$42 billion increase with bills and with certificates of
indebtedness and $25 billion with notes and bonds.
As we observed, there was considerable irregularity in terms
of the maturities offered in midquarter refundings in the first
half of the 1960s. Table 1 summarizes the justifications
provided by Treasury officials for their maturity choices.
Two features are significant:
•

As we discussed in Section 2, officials sometimes chose
to issue short-term securities to maintain upward
pressure on short-term interest rates (to support the
value of the dollar) and to moderate upward pressure on
long-term rates (to promote economic growth). At other
times, officials emphasized the importance of maintaining or extending the average maturity of the debt.
Box 2 discusses the importance that Treasury officials
attached to maturity extension.

•

Maturity decisions were sometimes based on the
character of contemporaneous demand. For example,
investor preferences were important in the decision to
offer 28¼-year bonds in July 1964, when Under Secretary
Roosa stated that the bond market was “strong,” “eager,”
and “indicating an actual need” for long-term bonds.16

b

Federal Reserve Bank of New York Circular no. 4663, November 18, 1958.
(“For some time, the Treasury has been working towards scheduling its
maturities on these quarterly dates to reduce the number of times each year
its financing will interfere with other borrowers such as corporations,
states, municipalities, etc.; to minimize the ‘churning’ in the money
markets on the major quarterly corporate income tax dates; and to facilitate
the effective execution by the Federal Reserve of its monetary policy.”)

Chart 5

Marketable Treasury Debt, 1950-2003
Principal amount of debt (trillions of dollars)

4
Notes and bonds
Certificates of indebtedness

3

Bills

3.3 Stand-Alone Cash Subscription Offerings
A stand-alone offering was an offering of a coupon-bearing
security on a cash subscription basis outside of a midquarter
refunding. The Treasury made stand-alone offerings when it
needed funds to finance a deficit or to rebuild its cash balance
following heavy attrition on a midquarter exchange offering.
New issues sold in stand-alone offerings, like new issues sold in
midquarter refundings, were set to mature on the fifteenth of
the second month of a quarter to facilitate refinancing.

58

The Emergence of “Regular and Predictable”

2
1
0
1950

55

60

65

70

75

80

85

90

95

00 03

Source: Treasury Bulletin (various issues).
Note: The chart depicts outstanding marketable debt at the end of
each fiscal year—on June 30 until and including June 30, 1976, and
on September 30 thereafter.

Table 1

Midquarter Refundings, 1960-64
Years to Maturity
Anchor
Issue

Intermediate
Issues

Long-Term
Bond

Feb. 1960
May 1960
Aug. 1960
Nov. 1960

1
1
1
1¼

4¾
5
7¾
5½

—
—
—
—

11.36e
6.41e
8.75c
10.84e

Feb. 1961

1½

—

—

6.90c

May 1961

1

2

—

7.75c

Jul. 1961b

1¼

3, 6¾

—

12.20e

Nov. 1961
Feb. 1962

1¼
1

4½, 13
4½

—
—

6.96e
11.18e

May 1962

1

3¾, 9½

—

11.68e

Aug. 1962

1

6½

30

8.75c

Nov. 1962
Feb. 1963
May 1963

1
1
1

3, 9¼
5½
2¾

—
—
—

10.98e
9.47e
9.49e

Aug. 1963

1¼

—

—

6.64e

Nov. 1963

1½

—

—

7.60c

Feb. 1964
May 1964

1½
1½

2½
10

—
—

8.38e
10.61e

Jul. and Aug. 1964c

1½

5¼, 9¼

28¼

10.13e, c

Nov. 1964

1½

—

—

9.25c

Offering

Amount Offered
(Billions of Dollars)a

Comment

The Treasury reduced the term of the intermediate-term issue from
seven years to five and a half years to make the offering
“a little more attractive.”
The refunding offered only a single short-term note to maintain
upward pressure on short-term interest rates and to limit upward
pressure on long-term rates.
The refunding offered two short-term issues to maintain upward
pressure on short-term rates.
Surveys indicated investor interest in securities out to seven years,
but no interest in any longer maturities.
A four-and-a-half-year issue was offered because surveys indicated
bank interest in higher yielding (even if longer term) securities.
A nine-and-a-half-year issue was offered because of continuing
bank demand for higher yielding securities.
The thirty-year bond was a surprise. The Treasury cited the need for
“balanced financing” (referring to a need to avoid contraction of
average maturity).
A “plain vanilla” financing in the midst of the Cuban Missile Crisis.
The refunding offered two short-term issues to maintain upward
pressure on short-term rates.
The refunding offered a single short-term note to maintain, and
possibly even lift, short-term interest rates.
The refunding offered a single short-term note to maintain upward
pressure on short-term rates.
The maturities were selected to fill relatively open dates.
Market participants expected a five-year note. The Treasury offered
a ten-year bond to avoid “over-loading” the front end.
Treasury surveys indicated a “strong” market, investors “eager”
to acquire long-term bonds.
The refunding offered a single short-term note to maintain upward
pressure on short-term rates.

Sources: Federal Reserve Bank of New York circulars (1960-64); New York Times (1960-64); Wall Street Journal (1960-64).
a
Amounts are total amount offered in a cash subscription offering (denoted “c”) or total amount of maturing securities eligible for exchange
in an exchange offering (denoted “e”).
b
This refunding was accelerated because the security being refunded was a note that matured on August 1, 1961.
c
The exchange portion of this refunding was accelerated to July to take advantage of favorable market conditions. See “Treasury Offers Giant Refunding,”
New York Times, July 9, 1964, p. 43, and “Treasury Offers Advance Refund of $41.7 Billion,” Wall Street Journal, July 9, 1964, p. 3. Attrition was financed
with a cash subscription offering in August 1964.

Taken as a whole, midquarter refundings between 1960 and
1964 evidenced a debt management process in which officials
made maturity decisions on an offering-by-offering basis.
16

“Treasury Offers Giant Refunding,” New York Times, July 9, 1964, p. 43, and
“Treasury Offers Advance Refund of $41.7 Billion,” Wall Street Journal, July 9,
1964, p. 3.

Midquarter refundings in the second half of the 1960s
exhibited greater regularity than those in the preceding five
years (Chart 6). However, the greater regularity was largely a
by-product of the statutory prohibition on issuing bonds with
coupon rates in excess of 4¼ percent. The rate ceiling kept the
Treasury out of the bond market after May 1965. In the

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59

Box 2

Treasury Concerns with Debt Maturity
The average maturity of marketable Treasury debt fell from
6.6 years in 1950 to 4.6 years in 1959 (see chart below). The decline
was an inevitable result of the reluctance of Treasury officials to
issue longer term debt. They did not want to issue longer debt
when economic activity was strong and interest rates were high
because such issuance would commit the Treasury to paying high
rates for a long time, and they did not want to issue longer debt
when activity was weak for fear of stifling a recovery.a
At the end of the 1950s, Treasury officials became concerned
that the growing concentration of indebtedness in securities

Average Maturity of Marketable Debt
Years
8
Calculated from
total debt

6

a

Calculated from
debt held by
public investors

4

2

0
1950

55

60

65

70

75

80

85

90

95

00

05

Advance refundings are described in footnote 12.

Chart 6

Maturities of Offerings of Coupon-Bearing Securities,
January 1965-December 1969
Maturity (years)
30
25
20
15
Midquarter
refundings

Beard (1966, p. 10) observed that “the cost of lengthening the debt [during
periods of strong economic activity] appeared to be excessive since the
Treasury would be saddled for extended periods with securities sold at
cyclically high rates of interest” and that “many economists held that
extensive sales of longer maturities during recessionary periods were
contrary to desirable stabilization policies.” Volcker (1972) noted that “no
time seems to be a good time for offering long-term Treasury securities—
either rates are too high or there is a desire to maximize the flow of funds
to other borrowers.” See also U.S. Treasury Department (1960, p. 3).

b

Source: Treasury Bulletin (various issues).

10

maturing in fewer than five years—and viewed as close substitutes
for money—was contributing to price inflation. They introduced
advance refundings in 1960 in an attempt to reverse the steady
decline in average maturity.b As noted in Table 1, extending the
average maturity of Treasury debt was also important from time to
time in the Treasury’s maturity choices in midquarter refundings.
The chart shows that the average maturity of marketable Treasury
debt increased to 5.3 years by mid-1965.
Between mid-1965 and early 1973, the statutory 4¼ percent
ceiling on Treasury bond coupon rates kept the Treasury from
issuing bonds and led to a renewed decline in average maturity.
Congress extended the maximum maturity of a note to seven years
in 1967 and provided some exemptive relief from the 4¼ percent
ceiling in 1971, but the renewed decline in average maturity was
not reversed until Congress further extended the maximum
maturity of a note to ten years in 1976.

Other
offerings

5

refundings between August 1965 and August 1967, officials
typically offered only two securities: a short-term anchor issue
and a note with a maturity at or near the five-year maximum.
Following Congressional action in June 1967 to extend the
maximum maturity of a note to seven years, officials began
offering an anchor issue and a note maturing in six or seven
years.
The Treasury also sold coupon-bearing securities in standalone cash subscription offerings on nine occasions during the
1960s.17 Table 2 summarizes the justifications for the maturities of the nine issues. As in the midquarter refundings,
Treasury officials were sometimes concerned with maintaining
or extending the average maturity of the debt and were
sometimes explicitly responsive to the character of
contemporaneous demand.

0
1965

66

67

68

69
17

Source: Federal Reserve Bank of New York circulars (1965-69).

60

The Emergence of “Regular and Predictable”

Additionally, in two auctions in 1963, the Treasury offered a total of $550 million of long-term bonds to competing syndicates of securities dealers.

Table 2

Stand-Alone Cash Subscription Offerings, January 1960-December 1969

Offering

Years to
Amount Offered
Maturity (Billions of Dollars)

Comment

Apr. 1960
Apr. 1960

2.1
25.1

2.00
1.50

Oct. 1961

1.6

2.00

Jan. 1962

7.7

1.00

The maturity of the offering came as a surprise to the market. Dealers had expected an offering with a
maturity of two to three years but the Treasury, feeling no immediate need to put upward pressure on shortterm rates, took advantage of an opportunity to lengthen the average maturity of the debt.

Apr. 1962

6.3

1.00

The offering came earlier than expected (it had been expected for late May or early June) because individual
income tax refunds ran ahead of expectations. The Treasury again felt no immediate need to put upward
pressure on short-term rates and again took advantage of the opportunity to lengthen average maturity.

Jun. 1963

7.2

1.25

The Treasury felt the market was “clearly ready” to accept an intermediate-term issue.

Mar. 1964

1.3

1.00

The Treasury chose a short-term issue to do the financing “in an inconspicuous way” because the market
was “trying to find itself.”

Jan. 1966

0.8

1.50

The maturity was kept short to make the offering more appealing to banks.

Aug. 1967

3.5

2.50

Dealers had expected a longer (five-to-seven-year) issue. They conjectured that the Treasury was reluctant to
issue longer because that would have required a higher coupon rate and provoked more disintermediation
from thrift institutions.

The Treasury was “testing” public demand for long-term bonds.

Sources: Federal Reserve Bank of New York circulars (1960-67); New York Times (1960-67); Wall Street Journal (1960-67).

4. Debt Management between 1970
and 1974
The first half of the 1970s was a time of transition for Treasury
debt management. The changes that occurred reflected
concern with the continuing decline in the average maturity
of Treasury debt and the need to provide some measure of
predictability in note offerings outside of midquarter
refundings.

In the August 1971 midquarter refunding, Treasury officials
used their new bond issuance authority to give holders of
maturing securities an opportunity to exchange the securities
for ten-year bonds. The Treasury offered a bond in virtually
every subsequent refunding (Chart 7).19 It first offered a longterm bond in a refunding in May 1973, and it continued to
offer a long-term bond in every subsequent refunding. By mid1974, the Treasury was offering a short-term anchor note, an
intermediate-term note of six or seven years, and a long-term
bond on a fairly regular basis in its midquarter refundings.

4.1 The Renewal of Bond Issuance and
a Growing Regularity in Midquarter
Refundings
In 1971, Treasury officials became concerned with the
continuing decline in the average maturity of Treasury debt
(Box 2 chart) and petitioned Congress to eliminate the 4¼ percent ceiling on bond rates. Congress declined to remove the
ceiling but did authorize the Treasury to issue up to $10 billion
of bonds at interest rates in excess of 4¼ percent.18
18

Committee on Ways and Means (1971, pp. 3, 5-7) and U.S. Treasury
Department (1971, p. 10). Congress increased the amount of bonds that could
be issued at interest rates in excess of 4¼ percent from time to time after 1971
and eliminated the rate ceiling altogether in November 1988.

4.2 The Introduction of Two-Year
Cycle Notes
Between 1970 and the first half of 1972, midquarter refundings
experienced unusually high attrition. In contrast to the 10 percent attrition that was considered normal in the 1960s,20 the
average rate of attrition in nine exchange offerings between
19

The only exceptions were November 1972, when only a small amount of
securities had to be refinanced, and February 1973. The February 1973
refunding followed the first sale of a long-term Treasury bond—a stand-alone
offering of twenty-year bonds in January 1973—in eight years. Officials
promised that they would let the twenty-year bonds “get fully digested” before
they offered more bonds for sale (“U.S. to Offer 20-Year Bonds By New
Method,” Wall Street Journal, December 29, 1972, p. 2).

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61

Chart 7

Maturities of Offerings of Coupon-Bearing Securities,
January 1970-December 1981
Maturity (years)
30

Midquarter
refundings

25

20
Stand-alone offerings

15

10

5
0
1970 71

72

73

74

75

76

77

78

79

80

81

Source: Federal Reserve Bank of New York circulars (1970-81).
Note: Cycle notes are not shown.

February 1970 and February 1972 was 24.3 percent. The high
attrition forced the Treasury to rebuild its cash balances by
issuing additional securities, including a total of $7.25 billion of
new notes in four stand-alone cash offerings between June 1971
and April 1972.
The spate of stand-alone offerings—there had been only
eleven in the 1960s—led Treasury officials to begin to think
about “regularizing” their note offerings. In March 1972,
Under Secretary of the Treasury Paul Volcker revealed that
Treasury officials were considering whether “to routinize or
regularize the handling of more of our debt, as we have done
for many years in the bill area.”21 In particular, officials were
considering whether, “in contrast to building up the present
concentration of note and bond maturities at quarterly
intervals [that is, on the fifteenth of the second month of each
quarter], to be handled flexibly at the Treasury’s discretion at
maturity,” it might not be better to adopt a scheme of “more
frequent but also more routine rolling over of relatively short20

The average rate of attrition for all exchange offerings in midquarter
refundings between February 1960 and November 1969 was 13.4 percent.
The average falls to 9.8 percent if the refundings in the third quarter of 1964
and the first quarter of 1965 are excluded. Those two refundings were
accelerated several weeks, to mid-July and mid-January, respectively, and
were not representative of other refundings. They had respective attrition
rates of 67.0 percent and 54.5 percent.
21
Volcker (1972). See also “Proposals on Reform of Debt Management Offered
by Volcker,” New York Times, March 8, 1972, p. 57, and “Treasury Seeking to
Put More Borrowing on Regular Basis, as With Bill Auctions,” Wall Street
Journal, March 8, 1972, p. 2.

62

The Emergence of “Regular and Predictable”

term notes.” Such a scheme might “reduce market
uncertainties . . . caused by large intermittent financing
operations.”
Treasury officials took the first step toward putting shortterm note sales on a regular schedule when they announced in
early October 1972 that they would begin shortly to auction
two-year notes at regular quarterly intervals. The first
tranche—$2 billion of notes maturing on September 30,
1974—was auctioned on October 11. One market participant
praised the new program as “safe, simple, and not at all
damaging to the market.”22
Although Treasury officials initially intended to sell subsequent issues of two-year notes at the end of every quarter, the
new program got off to a somewhat irregular start. A second
offering came at the end of December but, because the
Treasury’s cash balances grew unexpectedly in the next six
months, officials canceled the offerings that had been expected
in March and June 1973.23 The Treasury returned to issuing
quarterly two-year notes in September 1973.
The Treasury’s two-year note program broke new ground in
two ways. Most important, it was the first program of regular
and predictable sales of coupon-bearing securities with a
specified term to maturity. Additionally, it broke the pattern of

Treasury officials took the first step toward
putting short-term note sales on a regular
schedule when they announced in early
October 1972 that they would begin
shortly to auction two-year notes at
regular quarterly intervals.
coupon-bearing securities always maturing on the fifteenth of
the second month of a quarter. Debt management officials
clearly intended that two-year notes should be on their own
self-sustaining cycle, separate and apart from the midquarter
refundings that had previously dominated Treasury finance.24
The introduction of two-year cycle notes put short-term
note sales on a regular schedule but it did not signal that longer
term notes and bonds would soon be sold on a regular and
predictable basis. Volcker commented in his March 1972
speech that “regularization and routinization are nice
sounding words; straightjacket and rigidity are not. From
where I sit, I cannot help but be conscious of the number of
22

“Treasury Treads Lightly At Outset of Big Funding,” New York Times,
October 6, 1972, p. 59.
23
U.S. Treasury Department (1973, pp. 12, 22) and “Treasury Postpones
$2 Billion Note Offering,” Wall Street Journal, April 2, 1973, p. 17.

times in which particular market or economic objectives may
influence the Treasury’s thinking as to the form of a particular
financing.”25 His comments suggest that Treasury officials
were not prepared to abandon tactical discretion in 1972. The
cancellation of the two-year note auctions in March and June
1973 support that conjecture.

Table 3

Stand-Alone Cash Offerings, January 1974December 1975

5. Embracing Regular and Predictable
as a Debt Management Strategy
The pattern of growth in marketable Treasury debt changed
dramatically in fiscal year 1975. Outstanding notes and bonds
increased by $25 billion between June 30, 1974, and June 30,
1975, an increase substantially in excess of the increases in prior
years. The rapid expansion of the deficit led Treasury officials
to regularize note sales beyond the two-year sector.

Auction Date

Issue Date

Oct. 23, 1974
Dec. 30, 1974
Jan. 2, 1975
Feb. 19, 1975
Mar. 11, 1975
Mar. 13, 1975
Mar. 20, 1975
Apr. 1, 1975
May 22, 1975
Sep. 24, 1975
Oct. 7, 1975

Nov. 6, 1974
Jan. 7, 1975
Jan. 9, 1975
Mar. 3, 1975
Mar. 19, 1975
Mar. 25, 1975
Apr. 7, 1975
Apr. 8, 1975
Jun. 6, 1975
Oct. 7, 1975
Oct. 22, 1975

Amount
Offered
Years to (Billions of
Maturity Date Maturity Dollars)
May 15, 1979
May 15, 1979
Mar. 31, 1976a
Aug. 31, 1976b
Nov. 15, 1981
May 31, 1976b
May 15, 1990
Nov. 30, 1976b
Oct. 31, 1976b
Feb. 28, 1978
Dec. 31, 1978

4.5
4.4
1.2
1.5
6.7
1.2
15.1
1.6
1.4
2.4
3.2

1.00
1.25
0.75
1.65
1.75
1.60
1.25
1.50
1.60
2.10
2.50

Source: Federal Reserve Bank of New York circulars (1974-75).
a

Offering reflects the reopening of an outstanding two-year note.
Date represents an end-of-month maturity date not already filled by
an outstanding two-year note.
b

5.1 The Increasing Pace of Treasury
Financings
Forecasts of the federal budget deficit deteriorated rapidly
during the winter of 1974-75. In November 1974, officials
estimated that the deficit for the fiscal year ending June 30,
1975, would be about $9 billion and that the deficit for fiscal
year 1976 would be $10 billion-$20 billion.26 By mid-March
1975, the deficit projections had grown to $45 billion and
$80 billion, respectively.27
The five-fold growth in the two-year deficit, from
$25 billion to $125 billion, meant that the Treasury would
24

The introduction of two-year cycle notes had two knock-on effects. First, it
led officials to replace monthly sales of one-year bills (issued at the end of a
month and maturing at the end of the same month one year later) with quadweekly sales of fifty-two-week bills. This released end-of-month maturity dates
for the new two-year notes. Additionally, beginning in August 1972, the
Treasury extended the maturities of anchor issues in midquarter refundings
from less than two years to about three years. By the end of 1972, the Treasury
was offering fifty-two-week bills once every four weeks, two-year notes at the
end of every quarter, and notes with about three years to maturity in the middle
of each quarter.
25
Volcker (1972). Similarly, Edward Roob, Special Assistant to the Treasury
Secretary for Monetary Affairs, remarked in 1973 that despite the benefits of
regular and predictable note offerings, “we cannot tie down our debtmanagement strategy too much” (Roob 1973, p. 184).
26
“Fiscal ’76 Budget Deficit is Now Likely, In a Range of $10 Billion to
$20 Billion,” New York Times, November 11, 1974, p. 3, and “Estimate of Fiscal
’75 U.S. Deficit Raised By Ford Aides as Recession Cuts Revenues,” Wall Street
Journal, November 21, 1974, p. 2.
27
“$37-Billion Rise in Deficit Is Seen,” New York Times, March 18, 1975, p. 15,
and Committee on the Budget (1975, pp. 996, 1030, 1033, testimony of
Secretary of the Treasury William Simon).

have to sell an unprecedented (for a peacetime economy)
volume of new securities. As early as December 1974,
economists at one large dealer firm were predicting that
stand-alone cash offerings would “most likely be [made] in
nearly each month of [the next] half year.”28 The Treasury
made a total of nine such offerings in fiscal year 1975
(Table 3), easily breaking the previous record of four
stand-alone offerings in fiscal year 1972.
Treasury officials struggled to cope with the growing
financing requirements. In January 1975, they announced an
offering of two-year notes outside of the quarterly cycle
established in 1972-73. Under Secretary of the Treasury Jack
Bennett stated that “in the coming months, we will be studying
the possibility of establishing regular month-end, rather than
quarter-end, two-year notes.”29 Officials confirmed the new
monthly frequency in early April.30
The Treasury also began to give market participants more
notice of when it would offer securities. In late February 1975,
Under Secretary Bennett announced that it would auction four
new issues in a three-week interval between mid-March and
early April. The New York Times commented that the “unusual
28

“Treasury Plans Big Borrowings,” New York Times, December 30, 1974, p. 39
(forecast of Henry Kaufman and Albert Gross of Salomon Brothers).
29
Committee on Ways and Means (1975, p. 16, transcript of news conference
on Treasury financing plans by Under Secretary Jack Bennett on January 22,
1975).
30
“Official of Treasury Discloses Need for $41-Billion,” New York Times,
April 1, 1975, p. 62.

FRBNY Economic Policy Review / March 2007

63

advance disclosure … was aimed at giving the … market some
idea of how the Treasury will be coping with the large present
and impending budget deficit.” Bennett said he wanted to give
investors an opportunity to “get ready and find a place” for the
coming issues.31
In spite of their efforts, Treasury officials soon reached the
limit of what could be accommodated within the existing debt
management framework. On March 20, 1975, the Treasury
auctioned $1.25 billion of fifteen-year bonds at the same time
that an underwriting syndicate led by Morgan Stanley & Co.
brought to market the largest industrial debt offering in
history: $300 million of ten-year notes and $300 million of
thirty-year debentures from AAA-rated General Motors
Corporation. The simultaneous offerings left the bond market
in “chaos.” One dealer described the market as a “disaster,”
another said it was a “shambles,” and the New York Times
reported that “the head-on competition between the most
credit-worthy borrowers from the public and private sectors
left the . . . market in disarray.”32 The chairman of the Joint
Economic Committee, Senator Hubert Humphrey of
Minnesota, characterized Treasury debt management as
“being conducted in an inexplicable and seemingly highly
inappropriate fashion.”33

Five months later, in January 1976, shortly after what
initially looked like a stand-alone auction of five-year notes,
Under Secretary of the Treasury Edwin Yeo announced that
officials were “seriously considering” adopting a new series of
five-year notes.37 In early April, the Treasury issued a second
tranche of five-year notes without additional comment, but
when it announced a third tranche for settlement in early July
an official stated that investors could henceforth expect the
Treasury to issue five-year notes at the beginning of each
quarter.38 Thus, by mid-1976, the Treasury was issuing twoyear notes monthly and four- and five-year notes quarterly.
Observers pointed out that the Treasury did not have any
immediate need for the proceeds of the third five-year note
offering in July 1976, but that it had nevertheless proceeded
with the offering to maintain a regular and predictable auction

Regularization of coupon offerings proved
enormously popular.

The deficit had to be financed, but Treasury officials and other
market participants appreciated that head-on competition and
closely spaced tactical offerings could be reduced by replacing
stand-alone sales with regular and predictable offerings.34
In June 1975, Treasury officials announced $1.75 billion of
four-year notes that “might be the first of a ‘cycle’ of four-year
notes maturing at the end of a quarter.”35 “Might” turned to
“would” when officials announced a second tranche of fouryear notes in August.36

schedule.39 That decision—the reverse of the tactical decisions
to cancel the two-year note auctions in March and June 1973
because of ample cash balances—was an important step in the
adoption of a strategic approach to Treasury debt management. The Treasury never again canceled an auction merely
because it had no immediate need for additional funds.
Instead, it sold securities on a regular and predictable basis
and managed any undesirably large cash balances through its
Treasury Tax and Loan program,40 by reducing the amounts
offered or, as we discuss in Section 7, by terminating a series.
Box 3 describes the subsequent extension of regular and
predictable issuance in the late 1970s and early 1980s. By the
beginning of 1982, the Treasury had added a seven-year note
series and a twenty-year bond series and it had standardized
the midquarter refundings with regular offerings of three- and
ten-year notes and thirty-year bonds.

31

36

5.2 A Change in Strategy

“$7-Billion in Borrowing Is Planned by Treasury,” New York Times, February 25,
1975, p. 45, and “Treasury to Raise Total of $7 Billion Via Spring Issues,”
Wall Street Journal, February 25, 1975, p. 3.
32
“Treasury Bond Auction Creates Chaos; Supply of Money Shows a Record
Rise,” New York Times, March 21, 1975, p. 53, and “Financier for the U.S.
Debt,” New York Times, April 20, 1975, p. F7.
33
“Financier for the U.S. Debt,” New York Times, April 20, 1975, p. F7.
See also Joint Economic Committee (1975).
34
As early as February 1975, two Treasury advisory committees had
recommended expanding the use of cycle notes to maturities beyond two years
(Committee on Ways and Means 1975, pp. 25, 31, transcript of news
conference by Under Secretary Jack Bennett, February 24, 1975).
35
“2 New Notes, More Bills Set but No Long-Term Issue,” New York Times,
June 19, 1975, p. 63.

64

The Emergence of “Regular and Predictable”

The Wall Street Journal referred to the second tranche of four-year notes as
“the second four-year cycle note.” “Treasury Boosts Earlier Estimate of Its
Cash Needs,” Wall Street Journal, August 7, 1975, p. 3.
37
“Treasury Plans Heavy Borrowing,” New York Times, January 28, 1976, p. 58,
and “Treasury to Sell $13.8 Billion Bills, Notes and Bonds,” Wall Street Journal,
January 28, 1976, p. 25.
38
“Treasury to Sell Notes To Raise $2.5 Billion New Cash Next Week,” Wall
Street Journal, March 17, 1976, p. 27, and “Treasury Refines Its Management of
Federal Debt,” New York Times, June 28, 1976, p. 50.
39
“Treasury to Raise $2.5 Billion by Selling 61-month Notes Despite Bulging
Coffers,” Wall Street Journal, June 28, 1976, p. 15.
40
Brockschmidt (1975), McDonough (1976), and Lovett (1978) describe the
Treasury Tax and Loan program in the 1970s. Garbade, Partlan, and Santoro
(2004) describe the present program.

Box 3

Debt Management between 1977 and 1982
Marketable Treasury debt continued to grow rapidly in the late
1970s and early 1980s (Chart 5). That growth led Treasury officials
to expand further their new program of regular and predictable
issuance.
In April 1977, Under Secretary of the Treasury Anthony
Solomon announced that in the interest of extending the average
maturity of the debt, officials were considering substituting a
fifteen-year bond for the five-year note that they would normally
auction for settlement in early July.a They made the change and
thereafter alternated fifteen-year bonds and five-year notes for

Maturities of Cycle Notes and Regularized Notes
and Bonds, January 1975-December 1981
Maturity (years)
20

15

10

5

another four quarters (see chart below). In September 1978, the
Treasury eliminated five-year notes and began offering fifteen-year
bonds exclusively for settlement at the beginning of every quarter.
The replacement of five-year notes with fifteen-year bonds left
the five-year sector open. When the Treasury needed to raise new
funds in August 1979 it announced a stand-alone five-year issue.
Under Secretary Solomon stated explicitly that officials did not
anticipate issuing five-year notes on a regular basis.b However, the
press of financing requirements led the Treasury to continue to
auction five-year notes for settlement in the beginning of the third
month of every quarter.
In March 1976, Congress extended the maximum maturity of a
note to ten years. Thereafter, the Treasury twice offered ten-year
notes in lieu of seven-year notes in its midquarter refundings
(Chart 7). In November 1977, it began to alternate the two
maturities and in August 1980 it made ten-year notes a regular part
of the midquarter offerings.
The replacement of seven-year notes with ten-year notes in
midquarter refundings left the seven-year sector open. When the
Treasury needed to raise still more funds at the beginning of 1981,
it introduced a seven-year cycle note. At the same time, it replaced
the fifteen-year bond with a twenty-year bond, reportedly because
fifteen-year bonds had not been popular with investors.c

a

“U.S., With Cash Surplus in Quarter, Plans to Pay Off $2 Billion of Debt,”
New York Times, April 28, 1977, p. 85, and “Treasury to Sell $3.75 Billion
of Securities,” Wall Street Journal, April 28, 1977, p. 33.

0
1975

76

77

78

79

80

81

Source: Federal Reserve Bank of New York circulars (1975-81).
Note: Monthly two-year and quarterly four- and seven-year cycle notes
are depicted as circles; regularized beginning-of-quarter offerings
(initially five-year notes, then alternating five-year notes and
fifteen-year bonds, then fifteen-year bonds, then twenty-year bonds)
are depicted as squares; regularized beginning-of-third-month-ofquarter offerings of five-year notes are depicted as crosses.

Regularization of coupon offerings proved enormously
popular. The Wall Street Journal described it as a “widely
applauded campaign to finance the nation’s debt in a more
orderly manner” and an observer noted that “regularity makes
a lot of sense from a debt management view. Making … new
issues available on a regular basis gives market participants a
better feel for the securities when they are sold.”41 A dealer

b

“Treasury Schedules a $7.25 Billon Sale,” New York Times, July 26, 1979,
p. D7, and “Treasury to Raise Additional Cash of $2.42 Billion,” Wall Street
Journal, July 26, 1979, p. 32.

c

“Yields of Treasury Bills Tumble,” New York Times, December 23, 1980,
p. D5. See also Committee on Banking, Finance, and Urban Affairs (1982,
p. 78, reporting the opinion of a Treasury advisory committee that “the
fifteen-year bond has not had an auspicious history in the market”).

stated that cycle notes “have enabled the Treasury to raise
enormous amounts of money, have minimized any impact on
the securities markets, have reduced uncertainty, have
extended the average maturity of the national debt, and
produced a better defined yield curve.”42

42
41

“Treasury to Raise $2.5 Billion by Selling 61-month Notes Despite Bulging
Coffers,” Wall Street Journal, June 28, 1976, p. 15.

“New Interest in Treasury Yields,” New York Times, October 30, 1977, p. 120.
See also “Decoding the Treasury’s Auction Agenda,” New York Times, May 20,
1979, p. F2.

FRBNY Economic Policy Review / March 2007

65

6. The Cost of Tactical Issuance
Treasury officials began to switch from tactical issuance to
regular and predictable issuance when the fiscal environment
changed. Officials had found tactical issuance useful in the
1960s—it allowed them to advance any of a variety of policy
objectives, depending on the circumstances of the moment—
and there is no reason to believe that this aspect of tactical
issuance became less important.43 This suggests that the change
to regular and predictable issuance occurred because of an
increase in some cost associated with tactical offerings. We now
present empirical evidence consistent with that proposition.
Our data are the constant maturity Treasury (CMT) yields
reported in Federal Reserve Statistical Release H.15. Daily
yields on three-, five-, and ten-year coupon-bearing Treasury
securities are available from January 1, 1962. We divided the
data into four periods. The first period—January 1, 1962, to
December 31, 1970—ends before the Treasury reentered the
bond market in 1971 and before it had to rebuild its cash
balances with four stand-alone cash offerings between June
1971 and April 1972. The second period—January 1, 1971, to
May 31, 1975—includes the stand-alone offerings of 1971-72,
the rapid increase in the deficit during the first half of 1975, and
the nine stand-alone cash offerings in fiscal year 1975. The
third period—June 1, 1975, to December 31, 1981—begins
with the introduction of four-year cycle notes in June 1975 and
includes the subsequent extensions of regular and predictable
issuance to five- and seven-year notes and twenty-year bonds.
We are not sure when market participants finally concluded
that the Treasury had wholeheartedly adopted a strategy of
regular and predictable issuance,44 but it seems reasonable to
believe that they reached that understanding no later than
1982.45 Thus, the third period concludes at the end of 1981.
The last period—January 1, 1982, to December 31, 1986—
includes offerings made following the unambiguous adoption
of a regular and predictable strategy.

The Treasury announced offerings of coupon-bearing
securities on thirty-eight different days between January 1,
1971, and May 31, 1975 (Table 4, panel B). The root-meansquare (RMS) change in the five-year CMT yield over the
interval from the close of business one business day before an
announcement to the close of business one business day after
an announcement was 10.8 basis points.46 Over the same
Table 4

Root-Mean-Square (RMS) Changes in Constant
Maturity Treasury Yields over Two-Day Intervals
that Include Treasury Offering Announcements
and over Other Two-Day Intervals
Sector
Ten-Year

Number of
Observations

Panel A: January 1, 1962-December 31, 1970
Announcement
intervals
5.7
5.7
Other intervals
6.3
5.4

4.2
4.8

43
416

Panel B: January 1, 1971-May 31, 1975
Announcement
intervals
11.6*
10.8**
Other intervals
9.3
7.9

6.7
5.6

38
192

Panel C: June 1, 1975-December 31, 1981
Announcement
intervals
21.0**
18.9**
Other intervals
14.7
14.2

16.4**
12.0

152
209

Panel D: January 1, 1982-December 31, 1986
Announcement
intervals
12.0
11.1
Other intervals
12.1
11.9

11.2
11.7

120
143

5.9
5.2

97
142

26.1*
19.8

55
67

Interval

Three-Year

Five-Year

Panel C1: June 1, 1975-October 7, 1979
Announcement
intervals
8.4
7.0
Other intervals
7.4
7.0

43

See, for example, Volcker’s 1972 comment on the value of discretion quoted
in the text at footnote 25.
44
Prior to 1982, Treasury officials sometimes denied, and sometimes failed to
confirm, that an offering was the first in a new series rather than a stand-alone
offering. See, for example, the discussion in the preceding section and in Box 3
of the initial introduction of a five-year note series in 1976 and the
reintroduction of a five-year series in 1979. In addition, some series were
changed too quickly to justify characterizing them as regular and predictable
offerings. See the discussion in Box 3 of the partial (and subsequently
complete) substitution of fifteen-year bonds for five-year notes in 1977 and
1978, the partial (and subsequently complete) substitution of ten-year notes
for seven-year notes in midquarter refundings between 1976 and 1980, and the
introduction of seven-year cycle notes and replacement of fifteen-year bonds
with twenty-year bonds in 1981.
45
See Chart 2 and the remarks of Deputy Assistant Secretary Stalnecker quoted
in the text at footnote 2.

66

The Emergence of “Regular and Predictable”

Panel C2: October 8, 1979-December 31, 1981
Announcement
intervals
33.2**
30.0*
Other intervals
23.7
22.9
Source: Author’s calculations.
Note: RMS changes are expressed in basis points.

**Statistically significantly greater than the RMS yield change over twoday intervals that did not include a Treasury offering announcement
at a 1 percent confidence level.
*Statistically significantly greater than the RMS yield change over two-day
intervals that did not include a Treasury offering announcement at a
5 percent confidence level.

period, there were 192 disjoint intervals of two consecutive
business days, each of which was disjoint from the two-day
intervals associated with the thirty-eight offering announcements. The RMS change in the five-year yield over the 192
nonannouncement intervals was 7.9 basis points. The “excess”

[Our results suggest] that investors were,
on average, surprised by—or, equivalently,
did not fully anticipate—Treasury offering
announcements between January 1971
and May 1975.
yield volatility for the thirty-eight announcement intervals was
therefore 2.9 basis points (2.9 = 10.8 – 7.9). We can reject the
null hypothesis that the volatility of five-year CMT yields was
the same for the thirty-eight announcement intervals and the
192 nonannouncement intervals at a confidence level in excess
of 1 percent.47 Similar comments apply to yield changes in the
three-year sector.
This result implies that, on average, more new information
became available to market participants on days when the
Treasury announced a new offering than on other days, and is
consistent with the proposition that offering announcements
contained new information relevant to the valuation of
Treasury securities. More generally, the result is consistent with
the proposition that investors were, on average, surprised by—
or, equivalently, did not fully anticipate—Treasury offering
announcements between January 1971 and May 1975. It is not
unreasonable to conjecture that the inability of investors to
anticipate and plan for new issues led to higher financing costs
for the Treasury.
In contrast, panel D of Table 4 shows that offering
announcements after 1981 were not associated with unusual
yield changes. This result implies that, following the
unambiguous adoption of a regular and predictable issuance
strategy, no more new information became available to market
participants on days when the Treasury announced a new
offering than on other days, and is consistent with the
proposition that announcements of regular and predictable
46

The Treasury sometimes made offering announcements before the close of
trading and sometimes after the close. We used a two-day interval to ensure
that each yield change occurred over an interval that included an offering
announcement.
47
On the null hypothesis that yield changes over two-day intervals are normally
distributed with a mean of zero and a common variance, the statistic
(10.8/7.9)2 is distributed as F with 38 and 192 degrees of freedom. There is
no evidence of any statistically significant mean change, or drift, in interest
rates during announcement intervals in any of the four periods.

offerings did not contain new information. More generally, the
result is consistent with the proposition that regular and
predictable issuance reduced the element of surprise in
Treasury offering announcements and therefore facilitated
investor planning.
Two other features of Table 4 are of interest. First, panel A
shows that offering announcements before 1971 were, on
average, not associated with unusual yield changes. It is outside
the scope of this article to identify the reason for this result,48
but the result is consistent with the evident absence of any
incentive for Treasury debt managers to shift to regular and
predictable issuance in the 1960s.
The second interesting feature of Table 4 is that panel C
suggests that offering announcements between June 1975 and
December 1981 were associated with unusual yield changes.
This result is surprising because the transition to regular and

[Our results suggest that after 1981,]
regular and predictable issuance reduced
the element of surprise in Treasury
offering announcements and therefore
facilitated investor planning.
predictable issuance was well under way by the time the initial
five-year series was formalized in July 1976. Nevertheless,
panel C shows that excess yield volatility during announcement
intervals was greater in the second half of the 1970s than in
any of the other three periods.
One possible explanation for this result is that the reaction
of market participants to Treasury offering announcements
changed following the well-known change in monetary policy
in October 1979 that placed greater emphasis on control of
monetary aggregates.49 Panels C1 and C2 of Table 4 divide the
period from June 1975 to December 1981 into two subperiods.
Panel C1 shows that after June 1975 but before the change in
monetary policy, offering announcements were not associated
with unusual yield changes. This is consistent with the proposition that the benefits of adopting a regular and predictable
strategy accrued rather quickly. Panel C2, however, suggests
that these benefits were negated when the Federal Reserve
altered its approach to monetary policy. The relationship
between debt management policy and monetary policy is
48

One possibility is that, during the 1960s, Treasury officials did a better job
communicating their financing plans prior to making formal offering
announcements. Assessing this hypothesis would require careful study of
informal contacts between Treasury officials and market participants.
49
See Melton (1985, ch. 4).

FRBNY Economic Policy Review / March 2007

67

left for future research. For the present, it suffices to observe
that the benefits of regular and predictable issuance reemerged
when the Federal Reserve began to reemphasize control of
interest rates.

7. Debt Management Policymaking
within the Framework of Regular
and Predictable Issuance
The regularity of coupon-bearing debt offerings between 1982
and 1986 (Chart 2) demonstrates that the Treasury had
adopted a strategy of regular and predictable issuance by the
beginning of 1982. The new strategy limited, but did not
eliminate, the ability of Treasury debt managers to alter the
timing and maturity of new issues.
Chart 8 shows offerings of coupon-bearing securities
between 1987 and 2002. Several important debt management
actions are evident, including:
• Termination of the four-year note series and initiation of
monthly (in lieu of quarterly) five-year notes in January
1991. The Treasury made the change to shift some of its
financing activity from bills to intermediate-term
notes.50

Chart 8

Maturities of Offerings of Coupon-Bearing Securities,
January 1987-December 2002
Maturity (years)
30
25
20

10

• Termination of the three-year note series and reduction
to quarterly (in lieu of monthly) issuance of five-year
notes as part of the regular midquarter refundings in
August 1998. Officials made the change in light of large
and persistent federal budget surpluses and a material
reduction in financing requirements.52

30

“Treasury Announces Change in Regular Quarterly Auction Cycles
Beginning in January 1991,” Treasury News, December 11, 1990. The Treasury
also wanted to reduce the build-up of issues maturing on midquarter refunding
dates. Five-year notes had previously been issued in the beginning of the third
month of a quarter and matured in the middle of the following quarter five
years and two and a half months later. The new five-year notes were issued at
the end of a month and matured at the end of the same month five years later.
51
“Treasury Slashes Sales of Long-Term Bonds,” Wall Street Journal, May 6,
1993, p. C1, and “Treasury Maturities Shortened,” New York Times, May 6,
1993, p. D1.
52
“It’s Two Steps Back for Short-Term Treasury’s,” Wall Street Journal, May 7,
1998, p. C1.

The Emergence of “Regular and Predictable”

Midquarter
refundings

15

• Termination of the seven-year note series and reduction
to semi-annual (in lieu of quarterly) issuance of thirtyyear bonds in May 1993. The Treasury made the change
to shift some of its financing activity from intermediateterm notes and long-term bonds to bills and shorter
term notes in an effort to reduce interest expenses.51

50

68

These actions show that adherence to a regular and predictable
issuance schedule did not foreclose the exercise of managerial
discretion with respect to the maturity structure of new issues.
Treasury debt managers have continued to alter the timing and
maturities of new offerings in light of evolving fiscal conditions
and their assessments of the costs and benefits of shorter term
versus longer term financing, but they now choose the times
and maturities of series of debt issues rather than of individual
issues.

Other
offerings

5
0
1987

88

89

90

91

92

93

94

1995

96

97

98

99

00

01

02

25

20

15

10

5
0

Source: U.S. Department of the Treasury, Bureau of the Public Debt.

8. Conclusion
During the 1970s, Treasury officials changed the framework
within which they made debt management decisions,
transitioning from tactical issuance of notes and bonds to a
regular and predictable schedule. The emergence of regular and
predictable sales of Treasury notes and bonds reduced the
element of surprise in Treasury offerings and allowed investors
to plan future commitments of funds with greater confidence.
Treasury officials have asserted repeatedly that regular and
predictable issuance allows them to finance deficits and
refinance maturing debt at the lowest possible interest rates
consistent with contemporaneous market conditions.
Regular and predictable issuance was not a novel concept in
the 1970s; the Treasury had been issuing bills on a regular
schedule for decades. Nevertheless, debt managers had kept

note and bond offerings on a tactical basis—in part because
financing at least cost was not the only objective of Treasury
debt management. Debt managers sometimes chose to issue
short-term debt to maintain upward pressure on short-term
interest rates and limit upward pressure on long-term rates;
they sometimes chose to issue longer term debt to limit further
contraction in the average maturity of Treasury debt.
Regular and predictable issuance became more attractive
after Treasury officials had to bring four stand-alone cash
offerings in fiscal year 1972 as a result of unusually high
attrition in midquarter exchange offerings. They introduced
two-year cycle notes to put short-term note financings on a
more routine basis. The much larger and more significant need
to finance a rapid expansion of the deficit beginning in 1975 led
them to phase in additional cycle notes in 1975 and 1976 and,
ultimately, to abandon tactical issuance altogether.

FRBNY Economic Policy Review / March 2007

69

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The views expressed are those of the author and do not necessarily reflect the position of the Federal Reserve Bank of New York
or the Federal Reserve System. The Federal Reserve Bank of New York provides no warranty, express or implied, as to the
accuracy, timeliness, completeness, merchantability, or fitness for any particular purpose of any information contained in
documents produced and provided by the Federal Reserve Bank of New York in any form or manner whatsoever.
FRBNY Economic Policy Review / March 2007

71