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For release on delivery
9 15 a m. E D T
July 26, 1996

Statement by
Alan Greenspan
Chairman
Board of Governors of the Federal Reserve System
before the
Committee on Banking, Housing, and Urban Affairs
U S Senate

July 26, 1996

I appreciate this opportunity to appear before the Banking Committee
today to address certain recent reports on the Federal Reserve's operations

Of

most relevance, the GAO has raised some significant issues with respect to the
management of the Federal Reserve System

Both the GAO and the Congress

deserve our full response
We are strongly committed to ensuring that the Federal Reserve
System is managed efficiently and effectively

It is most important to us at the

Federal Reserve Board and the Reserve Banks, not only to run a "tight ship," but
to foster the attitudes and processes that will ensure continuous improvement in
the effectiveness of the Federal Reserve's operations

We recognize that

spending non-appropriated funds places a special obligation on us to be
particularly diligent in the use and application of those funds
Accordingly, even though we may ultimately disagree with some of
the specific suggestions of the GAO, we welcome all of them and their insights
because they require us to rethink our positions and change them, if appropriate
Certain GAO recommendations for review of specific aspects of our management
clearly have merit and reviews of a number of issues highlighted in the GAO's
report are currently underway. These reviews may lead to changes in the Federal
Reserve's administration that will further enhance our effectiveness
It is most important for any organization, including the Federal
Reserve, periodically to reassess its businesses and how they are carried out.

- 2Strategic planning is particularly critical given our rapidly changing environment, in
which technology is advancing at an extraordinary pace and the financial services
industry is becoming ever more complex

It is essential that the Federal Reserve

adapt to this changing environment with some foresight and as effectively as
possible

To that end, in 1995 we formalized our strategic focus by establishing a

System Strategic Planning Coordinating Group to assess how the Federal Reserve
can most effectively meet its public policy objectives into the next century
Our strategic focus is also reflected in recent significant changes that
the Federal Reserve has made in the way it carries out its major responsibilities
For example, we have undertaken a major redesign and upgrade of our computer
systems, communications networks, and critical software applications to improve
reliability, respond more quickly to changing business requirements, and improve
our disaster recovery capabilities. We have placed an increasing reliance on
automation to provide a more flexible approach to bank examinations -- an
approach that is risk-oriented, cost-effective, and sensitive to the burden placed
on banks. We have also consolidated certain fiscal agency functions that we
provide for the government in order to improve cost effectiveness and quality, and
a Reserve Bank policy committee has been established to coordinate the provision
of Federal Reserve financial services.
In addition, the Federal Reserve already had underway several
specific initiatives related to recommendations made by the GAO

For example,

-3we recently engaged an independent accounting firm to audit and certify the
combined financial statements of the Reserve Banks

The firm issued an

unqualified opinion on the 1995 financial statements, as prepared in accordance
with the financial accounting manual for the Reserve Banks

In addition, we are

actively reviewing the appropriate infrastructure for providing certain financial
services, taking into consideration both cost efficiency and service quality. One
difficult issue that has and will confront the Federal Reserve Board in our oversight
of the System is the appropriate degree of consolidation of various activities
Certain Systemwide activities do appear to be more cost effective if consolidated
For example, we anticipate that the consolidation of our critical electronic
payment applications will reduce our costs of providing these services

But it is

also evident that the element of autonomy that is accorded to the Reserve Banks
has created an environment within the Federal Reserve that attracts highly
qualified staff who contribute importantly to the effectiveness and efficiency of
the Federal Reserve System over the long run

The advantages of this

environment must be balanced against the possible savings from consolidation.
Federal Reserve's Role as Service Provider
Many of our resources are devoted to providing priced payment
services

The Federal Reserve has played an integral role in the nation's payments

system since the System's inception

Indeed, one of Congress' original goals in

establishing the Federal Reserve System was to improve the efficiency of check

- 4clearmg

Prior to the passage of the Monetary Control Act in 1980, the Federal

Reserve provided payment services to its member banks, the banks paid for these
services implicitly with non-interest bearing reserves rather than through explicit
fees

The MCA fundamentally changed the manner in which the Federal Reserve

provided and received payment for these services.
Because the Act expanded reserve requirements to all depository
institutions, it also required that the Federal Reserve offer its payment services to
all depository institutions

To offset the Act's reduction in the level of required

reserves, as well as to broaden and level the competitive market for interbank
payment services, Congress required us to price our services at full cost with a
rate of return comparable to that of private firms

I believe that the increased

competition resulting from the MCA requirements has benefited the payments
system
The GAO has recommended that we review our future role in
providing payment services

We are in the process of conducting such a review in

the context of our overall strategic plan

In general, we view our role as a

payments service provider as crucial in carrying out our overall central bank
mission

We believe it is important for the Federal Reserve to foster the integrity,

efficiency, and accessibility of the U S dollar payments system, which in turn is
important to maintain financial stability and maximize sustainable economic
growth

The provision of services by the Federal Reserve has contributed directly

- 5to these goals

In addition, the knowledge and operational expertise we have

gained as a service provider strengthens our efforts in containing systemic risks
and is crucial in managing potential financial crises.
We regard the wholesale payments services we provide, such as
Fedwire and net settlement, as essential central bank services and important in
limiting payments system risk

Our role in providing these services probably will

not change significantly as the marketplace evolves, although the nature of the
services themselves might
It is quite possible, if not likely, that as changes occur in the financial
services marketplace over time, or owing to other considerations, our role in
providing other services, such as check collection, may change as well

In this

regard, we must be sensitive to the fact that, as the nation's central bank, we
have an unsurpassable credit rating that must not be used to unfairly compete
with private-sector providers

We are continually assessing our available means of

achieving our payments system goals, including our regulatory authority and our
role as a direct participant in the payments system, with our public service role
always kept paramount

For example, the Federal Reserve has adopted

regulations that have fostered competition and efficiency in the provision of check
collection services, even though they resulted in a reduction in the Federal
Reserve's direct participation in the check system

At the same time, the Federal

Reserve has encouraged other efficiencies in the payments system through

- 6innovations in its service offerings. To the extent that we can achieve our
payments system goals most effectively through our direct participation, our
continued provision of these services will remain appropriate
Federal Reserve Cost Effectiveness
In considering the cost structure of the Federal Reserve, it is
necessary to keep in mind the unique combination of responsibilities that have
been assigned to this institution. The Federal Reserve is responsible for
conducting monetary policy; supervising and regulating certain financial
institutions, promoting the efficiency and integrity of the payments system, and
providing fiscal agency services to the Treasury and other government agencies at
their direction
Different factors affect the cost structure of each of these functions
For example, priced services are subject to the inherent discipline of the
marketplace as the Federal Reserve must control costs in order to meet the
statutory directives for cost recovery in the Monetary Control Act. On the other
hand, in providing depository and fiscal services to the Treasury, the Federal
Reserve must respond to the instructions of the Treasury

We endeavor to carry

out Treasury's directives in a cost effective manner, but cannot refuse legitimate
requests because of their effect on our costs or because they are inconsistent
with other Federal Reserve plans

In the areas of monetary policy and financial

institution supervision, there are fewer external constraints on our expenses

Here

- 7we must be particularly vigilant
Given the critical nature of the Federal Reserve's responsibilities,
particularly in the areas of monetary policy, financial stability, and financial
institution supervision, our major initiatives must be judged not only in terms of
cost but also in the context of risk management and the appropriate level of
resources to be devoted to each function

For example, Congress, in enacting the

Foreign Bank Supervision Enhancement Act in 1991, clearly concluded that the
additional costs of expanding the Federal Reserve's supervisory responsibilities for
U S operations of foreign banks were justified by the greater financial stability
and protection that the enhanced supervision would bring
We focus our banking examination resources based on risk
assessments, with the expectation that areas not covered extensively in the
examinations will not become serious problems

Had we devoted more resources

to Daiwa, and perhaps less elsewhere, would we have uncovered its wrongdoing
at an early stage? We can't know for sure, but the odds would have been higher
But, if we had the foresight to divert these resources from other activities, would
we have increased our risk exposure elsewhere?
As another example, the Federal Reserve's recent investment in a
major upgrade of our computer systems and personnel to adapt our surveillance
and payments technologies to the major changes that have occurred in private
financial markets was also driven in large part to improve risk management

While

-8the costs of these improvements were not trivial, they have enhanced our ability
to ensure the smooth functioning of the financial markets, even during periods of
financial or operational disruptions

To hold the risk of systemic crises to

acceptably low levels in both U.S markets and U S dollar markets abroad
requires some redundancy of resources

Given the vast scale of the value of

payment transactions that flow through our systems--our Fedwire volume alone
averages almost $1 5 trillion a day~we believe that the benefits of this
redundancy far exceed the associated incremental costs.
The risk-management decisions that we make concerning the way we
provide payment services to depository institutions are tested directly in the
marketplace

These services comprise more than one-third of the Federal Reserve

Banks' total budget and the Monetary Control Act requires that, over the long run,
we price these services to recover their costs, as well as costs that would be
borne by private businesses, such as taxes and a return on equity

If we provide

these services inefficiently, we price ourselves out of the market
Over the past decade, our track record has been good

The Reserve

Banks have recovered 101 percent of their total cost of providing priced services,
including the targeted return on equity

I should also note that, by recovering not

only our actual costs but also the imputed costs that a private firm would incur,
the Federal Reserve's priced services have consistently contributed to the amount
we have transferred to the Treasury. During the past decade, priced services

- 9revenue has exceed operating costs by almost $1 billion
Our fiscal agency services, which comprise another one-sixth of the
Reserve Banks' total budget, are provided at the direction of the Treasury and
other federal government agencies for whom we provide these services and
whose reimbursements to us are made primarily with appropriated funds
our difficulty has been in obtaining full reimbursement over the years

Here

We

understand that, as part of its FY97 funding request, the Treasury sought a
permanent indefinite appropriation, similar to that in place for the Bureau of the
Public Debt, for services provided to its Financial Management Service

The

Federal Reserve and our fiscal principals continue to work closely to identify and
implement initiatives that improve further the efficiency of these operations
With respect to staff compensation and some other aspects of our
infrastructure that are necessary to support our varied responsibilities, only
indirect market criteria are available to judge the Federal Reserve's costs

For

example, we try to set salary structures that can attract and retain the personnel
with skills necessary to run the Federal Reserve System in a highly effective
manner. In order to acquire and hold such personnel, we strive to provide salaries
and benefits competitive with local private and public sector markets, tempered
by the willingness of many professionals to accord a nonmonetary premium to
Federal Reserve employment

Although the GAO report suggests that the Federal

Reserve does not adequately review Federal Reserve employee salary and benefit

- 10levels to determine whether they continue to be justified, I can assure the
Committee that these costs are scrutinized regularly to ensure that they are
appropriate
We believe that the GAO's comparison of growth in Federal Reserve
employee benefits with those of the federal government is incorrect

The problem

is that while we accrue such benefits according to generally accepted accounting
principles (GAAP), the federal government does not. Were the federal
government to use accrual accounting, presumably the comparisons would be
straightforward

The federal government, however, employs an outmoded cash

accounting system, which makes it difficult for us to reverse our accruals in a
manner consistent with it

As best we can judge, when calculated on a

comparable basis using federal government accounting principles, the cost of
benefits per employee for the Federal Reserve and the federal government
increased by approximately the same percentage during the 1988 to 1994 period
-- 64 percent and 62 percent, respectively

We believe the GAO significantly

overstated the increase in Federal Reserve benefit costs by including the cost of
future pension benefits related to Federal Reserve early retirement plans on an
accrual basis without considering the associated future savings attributable to
those programs. Each of the early retirement programs has a positive net present
value, indicating a net cost savings from such plans

Including the present value

cost of early retirement plans without considering the present value of cost

-11 savings skews any comparison of the increase in total benefits costs for the
Federal Reserve and federal government
Applying peer analysis more broadly, during the 1988 to 1994 period
reviewed by the GAO, the increase in Federal Reserve operating costs was slightly
less than the 51 percent increase in federal discretionary non-defense spending,
which has been subject to increasing Congressional restraint in recent years
GAO makes this as one of its comparisons

The

The Federal Reserve effectively

contained its costs despite a significant expansion in its mandated responsibilities
and expanded resources required to monitor and contain the financial market
turmoil of that period

To also compare, however, as the GAO did in its report,

the rate of our expense increases with that of total federal discretionary outlays,
which are dominated by the major post-cold war retrenchment in defense, is
clearly inappropriate. Moreover, with the significant expansion of our computer
systems now close to completion and our adjustment to our expanded supervisory
mandates reaching fruition, our costs during the past two years and those
projected for the immediate future are definitely on a flattening trajectory
More generally, we believe that the GAO is mistaken in its notion that
the Federal Reserve does not regularly assess certain ongoing programs to
determine whether they are reasonable and justified

In particular, we do not use

a "current services" approach to develop the Board and Reserve Bank budgets
The significant reallocation of System resources among the various responsibility

- 12areas during recent years clearly demonstrates that this is not the case
In summary, although the Board believes that much of the GAO's
analysis and recommendations have merit, we take exception to the broad
implication of the GAO report that the Federal Reserve has not exercised
appropriate budget constraint and that it has not adequately addressed the
changing technological and financial environment in which it operates

In my

experience, the Federal Reserve is as well run an organization as any with which I
have been associated, private or public, over the decades
room for improvement7 Certainly
for which this is not the case

Is there nonetheless

I am not aware of any complex organization

In particular, the Board plans to review several

specific areas highlighted by the GAO related to management of health care
benefits. Reserve Bank procurement and contracting procedures, and Reserve
Bank travel reimbursement policies
The Federal Reserve Surplus
One area discussed in the GAO report-the elimination or reduction of
the Federal Reserve's surplus-has received substantial, and often misleading,
media coverage

I agree with the assessment of the Conference Report on the

FY97 budget resolution on this matter

The Report concluded that a transfer of

the Federal Reserve's surplus to the Treasury would be a "gimmick" that "has no
real economic impact on the deficit " While a transfer of Federal Reserve surplus
would increase "unified receipts" (because the Federal Reserve, for technical

- 13reasons, is not included in the unified budget), it would nonetheless be an
intra-governmental transfer that would not change the government's true
economic and financial position with respect to the private sector.
The Federal Reserve holds government securities as the asset
counterpart to its surplus, interest on which it returns to the Treasury

If the

Federal Reserve decreased its surplus, it would do so by selling government
securities and transferring the proceeds to the Treasury

Consequently, the

Federal Reserve's future payments to the Treasury would decline permanently by
the foregone amount of interest on the surplus funds transferred, exactly
offsetting the Treasury's savings on gross interest payments
The surplus is part of our capital account

In that context, I believe

retention by the Federal Reserve of some level of surplus is desirable, but I
acknowledge that the appropriate level of the Federal Reserve's surplus is
debatable

We would welcome the opportunity to work with Congress to review

this issue
Other Recent Inquiries
I would like to conclude my testimony by commenting on several
recent inquiries into certain aspects of the Reserve Banks' operations -specifically, the management of our Interdistrict Transportation System (ITS) and
cash statistical reporting problems experienced by the Los Angeles Branch of the
Federal Reserve Bank of San Francisco

- 14Earlier this year, Representative Henry Gonzalez issued a report on
the administration of the Federal Reserve's ITS network

The report asserts that

the Federal Reserve may have violated the Monetary Control Act to the extent
that it does not fully recover the costs of ITS through revenue attributable to its
use

The GAO and the courts reviewed this issue in the mid-1980s and concluded

that such cost recovery was not required by the Act
No integrated company in the private sector (such as one that
provides check collection services) prices individual segments of its operation to
achieve a uniform rate of return

Optimum profitability, i e , minimum

consolidated costs, is enhanced through transfer pricing flexibility

Even aside

from the imprecisions associated with allocating fixed costs, it would not make
sense for us to separately recover the costs of each input to a service, such as
transportation, data processing, or labor, as implied by Representative Gonzalez
Rather, all of the costs the Reserve Banks incur in providing check services to
depository institutions, including ITS costs (which represent less than 5 percent of
the costs of our check service), are recovered through fees for their various check
products.
Representative Gonzalez's report also alleges that certain contracting
practices used by the Boston Reserve Bank in managing ITS were improper and
wasteful

Administration of ITS requires Federal Reserve management to make

numerous, rapid, and complex business decisions every day, constantly balancing

- 15efforts to improve service, reduce float, and control operating costs

In hindsight,

are there some decisions that should have been made differently 7 Almost surely
But from a broad perspective, ITS has been managed effectively in our judgment
Finally, I would like to put in context the errors made by the Los
Angeles Branch of the Federal Reserve Bank of San Francisco in reporting certain
statistical cash information to the Federal Reserve Board

Unfortunately, the press

coverage of this matter, in our judgment, has significantly overstated the problem
First, these reports are used for informational purposes only
has been lost

No taxpayer money

No key decision-making has been compromised

The errors have

not affected the usefulness of the information derived from the Federal Reserve's
financial statements, nor have they affected the Federal Reserve's calculation of
the money supply, its conduct of monetary policy, or the amount of shipments of
currency and coin to or from the Branch.
Second, although there were reports of mistakes amounting to $178
million, the errors changed the Branch's reported production volume by less than
one-half of one percent

If the mistakes had not been discovered, at worst there

would have been slight errors in forecasting future currency demand, which could
have caused a slight increase to the Federal Reserve's order to the Treasury to
print new currency

The cost of this higher currency print order would have been

offset, however, by a lower print order in the following year
Third, the Los Angeles Branch had identified the problems internally

- 16and was in the process of resolving them before Representative Gonzalez began
his inquiry

The Los Angeles Branch is working diligently to ensure that all of the

data used to prepare the cash statistical reports transmitted to the Board are
accurate
In closing, let me state that we appreciate the GAO's review in that it
assists us in our ongoing evaluation of the Federal Reserve's structure and
functions and our efforts to continually improve operations. As I noted, many
recommendations are useful and we are pursuing them

In my opinion, however,

the general tenor of the report does not reflect the high level of effectiveness with
which the Federal Reserve has fulfilled its mission

While, as is likely the case

with any organization, the Federal Reserve has opportunities for further
improvement, I believe these opportunities should be put in the context of our
significant accomplishments