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For Release on Delivery
12:20 p.m. PDT (3:20 EDT)
May 25, 2000

Remarks by
Alan Greenspan
Chairman
Board of Governors of the Federal Reserve System
before the
NAUB: Urban Financial Services Coalition
San Francisco, California

May 25, 2000

It is a pleasure to discuss with you the evolving challenges for bankers and
supervisors posed by financial reform and continuing technological and financial
innovation. Today the nation is enjoying the longest-running economic expansion in its
history. The expansion has not only been unprecedented in its duration, but also in its
strength. Clearly the rapid technological innovation of the past decade has played a
strong role in the expansion's endurance by improving labor productivity and
opportunities for businesses to efficiently expand their output of goods and services.
Economic growth has also been supported by the strength and stability of our banking
system, which recently recorded its eighth consecutive year of record earnings. The
agility with which our banking system recovered from the severe difficulties of the late
1980s and early 1990s to fulfill a critical intermediary role is a testament to its resilience.
However, as our economy continues to evolve rapidly, banking organizations will need to
continue to adapt to the changing needs of businesses and consumers. In particular, with
the passage of the Gramm-Leach-Bliley Act, our financial services industry will be better
able to meet those demands in the decades to come through prudent innovation.
As an example of innovation and adaptation, I note that your own organization is
widening its scope to invite membership from the entire financial services industry.
Broadening your reach to include insurance, brokerage, and other financial services not
only reflects market realities but should also assist in your endeavors to improve the
economic development of underserved communities and promote the professional growth
of your members.

-2-

While innovations and adaptations in our economy have helped create and
prolong the prosperity we are now enjoying, they also bring to bear new challenges.
Today I would like to provide a brief overview of what I think are the key challenges,
risks, and opportunities faced by bankers and their supervisors.
To start, I would like to shift your attention from the vibrant economy and
exceptional banking conditions to some of the risks that are always present. For example,
the lax standards, excesses, and fraud present in the recent few recent bank failures show
that even as most banks post record profits, the deposit insurance fund can still
experience disproportionate losses from undisciplined institutions. The high cost of
recent failures reinforces lessons of the past for banks and supervisors, including the need
for continuous vigilance against causes of bank failure such as fraud, credit
concentrations, and rapid entry into new and unfamiliar activities.
In addition to these risks, institutions face the challenge of fighting both
complacency and competitive pressures with regard to their lending practices. There are
some recent indications that the industry is aware of these challenges. The most recent
Federal Reserve Senior Loan Officer Opinion Survey suggests that banking organizations
are becoming more sensitized to risk and are continuing to firm their lending practices.
In particular, the percentage of domestic banks tightening standards on commercial and
industrial (C&I) loans was the largest since the November 1998 survey. In addition, risk
premiums on C&I loans have also risen. While firming loan standards and terms is one
technique for managing credit risk, sound risk-management systems also involve testing
the performance of borrowers under more stressful conditions to reveal weaknesses.
When strong conditions largely mask the susceptibility of marginal borrowers, stress

-3-

testing is invaluable for revealing the magnitude of portfolio risk posed by more
challenging economic conditions.
Other factors that are important for strong asset quality include maintaining
adequate pricing amidst fierce competition from other banks and nonbanks alike. Some
organizations are responding to these pressures by moving lower on the credit quality
spectrum in a reach for higher nominal yields. In a special question added to the latest
lending survey, banks indicated that demand for C&I loans has somewhat strengthened as
below-investment-grade borrowers have found unfavorable conditions in the high-yield
bond market and have turned to banks as an alternative. The majority of banks reporting
additional demand from these borrowers also indicated that they were fairly receptive to
these customers. While lending to higher-risk borrowers presents opportunities, banks
must ensure that their risk-management systems can properly discern the difference
between nominal and risk-adjusted yields, identify credit concentrations, and allocate
enough capital and reserves to offset the higher risk of these loans. Banks without these
safeguards, as well as limits and adequate tracking and reporting to senior management
and their boards, have in the past experienced significant problems and sometimes
failure.
Credit quality issues are not the only areas of supervisory focus. The trend of
narrowing interest margins at many banks has been coupled with lengthening asset
maturities and declining core deposits. The erosion in bank core deposits is to some
extent attributable to competitive pressure from the marked rise in equity values and
mutual funds. In addition, as runoff of lower-cost deposits has been replaced with
higher-cost funding from capital markets, pressures on interest margins and liquidity have

-4-

intensified. Moreover, the decline in stable core deposits and the steady rise in average
asset maturities has resulted in higher levels of interest rate risk, a trend evident in our
surveillance screens. Banking organizations with strong risk management systems will of
course carefully evaluate how these asset/liability trends are affecting their performance
and risk profile and take mitigating steps as appropriate.
As competitive pressures have intensified, large and small banks alike have
sought solutions by broadening the variety of products they offer and delivering them
through innovative delivery channels such as the Internet. Interestingly, though
conventional wisdom would suggest that smaller community banks would be at a
disadvantage in the competitive financial services arena, this has not been the case. By
forging cooperative alliances with technology, insurance, brokerage and other firms,
community banks have kept up with larger organizations in providing their customers
with the diversity of financial tools and products they demand without the attendant fixed
start-up costs. Moreover, while larger organizations may have some advantage over
smaller banks through their brand identity and larger budgets for technology and
marketing, community banks are more likely to have a comparative advantage in
understanding the diverse needs of their customer base and in their ability to respond
quickly with personalized service.
More fully recognizing and responding to customer needs is particularly
important when viewed in the context of trends in wealth formation in our economy.
The Federal Reserve's most recent Survey of Consumer Finances suggests that although
the current economic expansion resulted in broad gains in median household wealth
between 1995 and 1998, families with low-to-moderate incomes and minorities do not

-5-

appear to have fully benefited. For example, median net worth declined over this period
for families with incomes below $25,000, and medians for non-whites and Hispanics
were little changed. In addition, lower-income families were less likely to own homes,
which constitute the bulk of the value of assets for those below the top quintile according
to income. Despite these troubling indications, there were some encouraging signs. In
particular, the share of families with incomes below $25,000 fell from 41 percent in 1995
to 37 percent in 1998, and more families within that lower-income group reported that
they had a checking account. Moreover, homeownership rates among minorities have
risen. For example, according to U.S. Census data, homeownership rates among blacks
rose from 43 percent in 1995 to 48 percent in the first quarter of 2000, suggesting that
some progress has been made in access to credit for minorities.
Although breaking down the barriers that have produced disparities in income and
wealth is not simple, promoting equal access to credit for sound borrowers is one step in
the right direction. As I have said previously, discrimination is against the interests of
business—yet business people too often practice it. To the extent that market participants
discriminate, they erect barriers to the free flow of capital and labor to their most
profitable employment, and the distribution of output is distorted. In the end, costs are
higher, less real output is produced, and national wealth accumulation is slowed. By
removing the non-economic distortions that arise as a result of discrimination, we can
generate higher returns to both human and physical capital. Banking and other lending
organizations that develop expertise to tap, educate, and encourage underserved
customers are likely to provide better and more informed access to credit and expand
profit opportunities. In that regard, many banks are well equipped to tailor their services

-6to individual customer circumstances in a personalized setting and to educate customers
about various products and services that could help them achieve their financial goals.
In today's more complex world, the diversity of financial product choices facing
consumers is truly astonishing. Similarly, banks are now also facing much broader
choices, especially when one considers the opportunities presented by the passage of the
Gramm-Leach-Bliley Act. By modernizing our banking laws and making them more
consistent with marketplace realities and the needs of consumers, the financial services
industry will be able to grow and innovate with far fewer artificial constraints. How
various financial service providers choose to take advantage of the act will be one of the
more interesting dynamics as our financial system evolves in the years ahead.
Clearly, many franchises can succeed by continuing to focus on traditional
banking. Organizations that decide to depart from past successful strategies by
expanding into new activities should do so only after careful consideration. As of midMay, 270 domestic banking organizations and 17 foreign banking organizations had filed
to become financial holding companies. Of those, roughly three-quarters had less than
one billion dollars in assets. I suspect that many of these organizations are not intending
to immediately launch into full-scale brokerage, venture capital, or insurance activities,
but rather are looking to keep their options open and retain flexibility should
opportunities present themselves.
If true, that is encouraging, for it is one thing to gain FHC status and begin
cautiously experimenting with these new powers, and quite another to take on the risks
related to full-scale acquisitions or extremely rapid growth of new businesses.
Whichever configuration financial firms choose, translating the traditional and new

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financial powers into longer-term economic value for customers and shareholders will be
the leading challenge in the coming decades.
In this changing environment, supervisors will be challenged to adapt and refine
their programs to accommodate both innovations in traditional banking and new activities
permitted by the act. The supervisory strategy for addressing banking innovations of the
past decade has been a risk-focused approach that moves well beyond earlier, one-sizefits-all examinations to achieve what we believe is a more effective and less burdensome
process. The risk-focused approach has also been tailored to distinguish between larger,
more complex banking organizations, on the one hand, and the more traditional regional
and community organizations on the other. The large, complex companies are receiving
a more continuous level of oversight given the rapidly shifting risk profiles that can result
from their operations, while well-capitalized and well-managed regional and community
organizations receive a greater degree of off-site monitoring and less frequent on-site
visitations, consistent with statutory mandates. I should emphasize that these programs
are not meant to be implemented in a rigid fashion; institutions that have characteristics
that fall somewhere in the middle of the two programs would be flexibly accommodated
through adjustments to our supervisory plan for the institution. That kind of flexibility
will be essential with the emergence of smaller financial holding companies and the
expanded range of permissible activities. Clearly, these two broad supervisory programs
will need further customization or segmentation to respond to the evolving diversity of
our supervisory caseload.
Another area where supervisors are attempting to more appropriately align risks
with regulatory approaches is capital. You may be aware that the Basel Committee on

-8Banking Supervision and Regulation is working to refine and improve the risk-based
capital measure to make it more sensitive to the underlying risks of various banking
activities. As you might surmise, those efforts are likely to result in a revised framework
that is geared toward the kinds of exposures and risk-management systems typical of
internationally active institutions. For these organizations, the benefits from more
precisely aligning risks with capital charges, we trust, will outweigh the substantial costs
of added complexity. However, for community banks with traditional exposures, the
costs of such a complicated framework will likely outweigh any benefits, and hence it
will be impractical to implement.
This has led to the consideration of a dual or bifurcated approach to capital that
parallels our approach to supervision. Such an approach would recognize the potential
tension between the complexity and cost of the next version of the international capital
standards and the more limited needs of smaller, more traditional banks. Implementing a
second, more streamlined capital adequacy standard for qualifying domestic institutions
would seem to have merit. Discussions on such an approach are only preliminary, but the
arguments for continuing to more fully calibrate our supervisory and regulatory
approaches to the nature and risk profiles of the institutions we supervise are compelling.
Capital standards and the supervisory process are two of the three key tools
regulators use to get their job done. The third tool, disclosure, holds promise for yielding
benefits to our financial system both domestically and globally. In past decades, the
business of banking was fairly opaque but straightforward, with banking risks largely
embedded in the credit judgments inherent in the loan portfolio. Today, with the
explosion in financial innovation that has created various derivative, securitization,

-9insurance, and other structured products and the greater diversity in activities permitted
by the Gramm-Leach-Bliley Act, not only are risks more opaque, but even when
revealed, sometimes difficult to interpret.
Fortunately, the same technology and financial techniques that have created this
added complexity can also be harnessed to produce more meaningful disclosures that
allow markets to analyze risks and exert discipline on those that would take on imprudent
levels of exposure. While not a panacea, improved disclosure can complement the
supervisory process and regulatory capital, and obviate more intrusive investigations,
holding out the promise of less supervisory intervention. Recently, the Federal Reserve,
in collaboration with the Securities and Exchange Commission and the Office of the
Comptroller of the Currency, established a private-sector working group to review
industry best practices and develop options for improving the public disclosure of
financial information by large, complex banking and securities organizations. Enhanced
disclosures are also being pursued through regulatory reporting. A proposal to be
released shortly will eliminate less meaningful items on the Call Report and request
additional information on activities of growing significance for some institutions,
including loan servicing, securitizations, venture capital, and insurance. More relevant
regulatory disclosures should not only improve transparency but should also help our offsite monitoring and tailoring of our supervisory program.
In closing then, we live in a fascinating period in American history, in which
rapid change will force business and government to continuously reevaluate previously
held assumptions and adapt to change. There is no static, optimum model either for
financial service providers or for financial regulators, as both are engaged in a

-10continuously evolving process. I am optimistic that recent financial reforms and
continuing innovations will translate into more useful financial products and services to a
broader spectrum of consumers and businesses and, in turn, fuller participation by all
segments of our society in the kind of economic progress we have experienced to date.