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For release on delivery
9:30 a.m.,
• r E.D.T.
October 5, 1987

Testimony by
Alan Greenspan
Chairman, Board of Governors of the Federal Reserve System

before the
Subcommittee on Telecommunications and Finance
Committee on Energy and Commerce
United States House of Representatives
October 5, 1987

Mr. Chairman and members of the Committee, I welcome this
opportunity

to

appear

Telecommunications

and

financial

services

framework

that

want

the

Finance

industry

applies

to express my

and focusing

before

with

appreciation

Subcommittee

explore
an

to banking

the attention

important

to

the
the

emphasis

and

structure
on

the

securities

to you

on

of

the

regulatory

activities.

for calling

this

I

hearing

of the Congress and this Committee on

issue of the basic

rules that

should

apply

to the

in a speech that you made recently

in San

financial services industries.
Mr. Chairman,
Francisco,

you

expressed

increasing

unease

that

the

financial

system has evolved beyond the terms of our laws and is functioning
without effective legislative guidelines.
must be

at the

center,

You said that

not the sidelines,

"Congress

of the development

of

the policy for structuring our financial industry."
I
view.

It

difficult
new

would
is

like

essential

decisions

circumstances

considerable

to

express
that

my

strong

Congress

come

agreement
to

that must be made to update
of

technology

frustration

that

and

grips
our

competition.

Congress

has not

with

acted

with

that
the

laws to the
We

all

and

feel

I very

much welcome the pledge made by both the House of Representatives
and

the

earlier

Senate
this

expansion,

a

in

the

year

to review

not

Competitive
to

Equality

extend

our banking

and

the

Banking

moratorium

financial

Act

adopted

on

banking

laws and to

make

-2-

decisions

on

the

need

for

financial

restructuring

legislation

before the moratorium expires.
Before turning to the questions of financial structure, I
believe

it

is

important

to

reflect

on

our

starting

point.

We

have the strongest, most competitive and innovative capital market
in

the

world.

Our

improvements

to

competitive
capital

environment
strength.

is

assure

world

market

job

its

preserve
role

marketplace.
structure

this

to

industry

has

in

Banking

and

its
a

and

make

substantially

is a vital

despite

shown

strengths

a

part

of

difficult

extraordinary

more
this

economic

resilience

and

It has carried a special burden in the transition to a

less inflationary economic climate as some of the major sectors it
has

financed —

real estate —
transition,
down

in

have been

experiencing

the

prices.

agriculture,

rate

of

The banking

developing

seriously

and

countries,

adversely

energy,

affected

by the

in some cases not only a relative

inflation,
industry

but

actual

is coming

sharp

through

and

slow-

declines

this

in

experience

wiser and stronger.
While
depressed,

profitability

regional

strengthened

banks have been

themselves

in the

interstate banking arrangements.
development

of

a

levels

broad

interstate

profitable

remain
and

years through

banking
framework.

full interstate banking,

it

transition

period

banks

have

regional

In the future, I anticipate the

have adopted
a

many

strongly

last three

arrangements evolve into a national

after

for

and

system

as

regional

Already 10 states

13 states have provided
8

additional

states

for

permit

-3-

interstate
trend,

acquisition

especially

of

when

troubled

fully

banks.

developed,

This

will

constructive

result

in

better

service to customers and a strengthened banking system.
Securities
change.
variety

The
of

explosion

markets

global

marketplace

securities

in

also

complex

is

new

now

are

adjusting

to

involving

24-hour

reality.

There

a

products

and

services

trading
has

posing

and putting a new emphasis on capital adequacy.
attention has focused on a deterioration

substantial
in a

been
new

an

risks

And, here at home

in ethical standards and

the possible need to take corrective action.
All

of

these

focus on how our
Francisco

concerns

financial

speech

pointed

competition,

of

rates

fields
versa.

and

traditionally
All

of

structure
to

international
interest

some

has

fifty

thought

reflect what

of

I believe

Your

a new

improved.

these

issues,

products,

organization

as

and

banking

searching
Your

San

including

deregulation

expansion

vice

a very

much

for banking, while at the same

time

have

amounted

a regulatory

statement

is a widespread

services

into

and

frozen within
ago.

to

can be
of

nonbanking

these developments

been
years

many

led

new securitized

more competitive environment
banking

have

and

to

structure

those

feeling

fashioned

of many

that our

others

existing

structure is too rigid, limiting efficient service to the users of
financial

services,

hampering competition

unfair and anomalous results.

in a way that

produces

Senator Proxmire's consideration of

a proposal to repeal the Glass-Steagall Act is another example of
this serious reevaluation of our financial laws.

-4-

Among all these changes there

is one development

that I

believe is of particular importance and is now a permanent
of the financial environment.

feature

This is the erosion of the role of

banks as intermediaries in the credit granting process as a result
of

major

developments

technology.

in

processing

and

telecommunications

These changes have taken the form of improvements in

productivity permitting
of

data

transactions,

the

the efficient

linking

of

processing

geographically

and a substantial reduction of costs.

whose function it is to substitute
ultimate

result

of

careful

has provided
have

been

borrower.

This

credit

bank

and

—

intermediation

intermediation,

diversification

of

lenders more secure investments than would

possible

ultimate borrower.
and a core element

through

direct

markets

credit for the credit of

traditional

analysis

separate

These, in turn, have had a

marked impact on the traditional role of banks

the

of large volumes

loans

from

a

the
risk,

otherwise

lender

to

an

In this process, the value added by the bank
of its comparative advantage,

is its

superior

information about the creditworthiness of the borrower.
Now
capacity
market
make

and

result

own

evaluation

that
and

almost

analysis

complex
is

on-line

data

telecommunication

information

its

execute

extensive

trading
the

bases,

facilities

instantaneously,

of

basic

products

diversification

than they were ten years ago.

of

to

hedge

provided
risk

—

computation

provide

credit

and

allowing the lender to

creditworthiness,

strategies

powerful

and

to

develop

and

risk.

The

against
by
are

banks
less

—

credit

competitive

These fundamental changes will have

-5-

a

permanent

effect

institutions

and

on

will

the

expand

competitiveness
the

competitive

of

depository

advantage

of

the

market for securitized assets.
The
due

to

impact

of these

technological

innovation

simultaneous

development.

changes

come

has

affected many

at

of the

changes

a

has

The

time

in relative
been

full

when

accelerated

force

market

sectors to which

institutions have made significant

competitiveness

of

the

forces

by

technological
have

and

regulatory

banking

financial commitments.

already significant

administrative

adversely

a large number of

the growing cost advantage of avoiding the depository
intermediary,

another

Thus,

institution

in terms of both a reduction in

costs,

widened

as

a result

of

the

market downgrading of many banks.
As
changes,
paper

we

one

important

have

market

as

seen
a

a

example

of

remarkable

substitute

for

the

expansion
direct

banks to the most creditworthy borrowers.
has more

than

doubled

—

rising

consequences

from

of

of

the

short-term

these

commercial
lending

by

Since 1980, this market

$31 billion

at the

end

of

types

of

that year to $78 billion at mid-year 1987.
The
lending

kind

of

securitization

proceeded

apace

mortgages to automobile

loans.

in

the

exceeded

has

same

mortgage

where

involving

mortgage

has more

debt.

recently

other

everything

from

Expansion has been most
mortgage

pass-through

$600 billion at mid-year 1987 or about

residential
security

market

of many

The

concept

been extended

of

home

dramatic

securities

one-third of all
the

to other

pass-through
claims

on

the

-6-

household

sector,

notably

automobile

receivables, which stood at about
development

of this market

loans

and

credit

card

$15 billion at mid-year.

which substitutes

securities

The

for

bank

loans is now reaching down below the top industrial and commercial
firms to
have

a broader

not

been

extension

of

segment

able

their

to

of the

economy.

participate

own

natural

As you

fully

markets

in

because

know,

banks

servicing

this

of

regulatory

now

prevalent

restrictions.
These

same

technological

throughout the world.

forces

are

To remain viable in this highly competitive

and innovative environment,

financial

institutions are seeking to

have the broadest range of products available to meet the changing
needs

of

provide

their

customers.

traditional

Thus,

banking

financing,

and

banking

banks that

are under

we

have

services,

firms,

such

including

regulatory

seen

short-term

American

constraints

broadly in securities markets overseas.

as

investment

at home,

in

these

overseas

markets

for

bridge

Japanese

participate

As an aside, I would note

that the successful and substantial participation
firms

and

firms

debt

of U.S. banking

securities

certainly

raises important questions about the need for the restrictions on
lenders doing the same thing at home.

It is considerations of the

kind I have outlined above that have led the British and
Governments

to

adopt

previously segmented
financial

service

or

in

their

financial systems to allow banking and

other

firms

propose

to

substantial

provide

single world financial market.

integrated

changes

Canadian

services

in

the

-7-

As I have
our

segmented

stressed,

financial

we do need to make

structure

to make

some changes

it more

effective, both domestically and internationally,
to this

in a moment.

to

competitively

and I will

turn

One thing I do not think we need to do is

follow a deliberate policy of allowing our financial
to become larger for the specific purpose of meeting

institutions
international

competition.
One argument that is put forward for this proposition is
the fact that

of the top 25 banks

in the world

in 1986,

sixteen

were Japanese and only two were based here, in contrast with

1981

when

were

four

Japanese.

were

American

including

the

top

two,

while

ten

At the same time, we must ask ourselves whether

these

changes in the relative ranking of Japanese firms can be explained
largely by Japan's rather highly concentrated banking system,
appreciated currency,
savings.

its

its trade surpluses, and very high

domestic

It is no surprise that in these circumstances

Japanese

institutions

would

be

growing

rapidly,

particularly

in terms

of

dollars.
But

there

is

no

evidence

that

extraordinary

necessary for successful international competition.
countries

other

international

than

our

marketplace

own

Many banks in

successfully

the

smaller than those of their American counterparts.

Clearly, many

American

size

have

that

in

significantly

institutions

assets

is

are

financial

with

compete

size

reached

the

that

necessary for effective participation in international markets.

is

-8-

On the
important
which

other hand,

ingredient

does

Reserve

require

has

uniform
based

in the
a

begun

supervisors both
system

I would

deal

more

effort,

in

for measuring

competitive

adequacy

progress

is

banking

agreement on a

focused

being

an

Federal

with

to achieve

as

environment
The

cooperation

capital

Considerable

adequacy

attention.

at home and overseas,

standard.

capital

international

great
an

rate

on a risk-

made

toward

an

agreement, which I hope will be completed by the end of this year.
An agreement of this kind will both strengthen the banking
worldwide

and

assure

greater

equity

in

the

system

competitive

environment.
I

would

like

should go about
the

problems

performance.

to

turn

restructuring

that

I

Mr.

think

now
the

we

Chairman,

to

financial
all

you

consideration

agree

have

system
are

suggested

of

how

we

to deal

with

hampering

its

the

fundamental

test for determining the kind and scope of the required changes is
what we

will

need

to do

interest.

You

point

removal

some

or

of

out

all

securities

firms we have

questions,

including:

from

securities

safety

and

securities
interest

markets;

serve
that

of

and

in

the

(a) how

of,

better
the

our

barriers

can

(b) how

and

of

can

of

separating

we

confidence
we

resources?

banking

insured

ensure

To

the

in,

prevent

economic

considering

a number of

insulate

can

public

(c) how

concentration

we

nation's

process

to ask ourselves

activities;

soundness

and

to

important
deposits
continued

banking
conflicts

these

considerations I would add the corollary that our basic

and

and
of

important
objective

-9-

must be to promote
customers

large

competition.
points that

As

and

small

part

of

in

this

environment

analysis,

that

I would

efficiently,

and

in

which

(b) maintains

monetary
the

the

add

two

other

(a) we

system

to

promotes

but are also of vital concern to the economy as a whole:
a

importance

services to

Reserve

have

of particular

a

efficient

Federal

must

are

a system which provides

policy

integrity

of

can

function

the

nation's

payment system.
There is, I believe, wide agreement on these goals.
We accept
of

banking

and

as basic to our thinking that any

combination

other

within

firms

should

take

place

an

organizational structure which separates the bank in such a manner
as to assure that only the bank has the benefit of the support of
the federal safety net which includes deposit insurance and access
to Federal Reserve lending.

There are various ways in which this

separation could be accomplished.

The three main proposals

that

have been put before the Congress involve the following ideas:
(1) Require that
enterprise

take

place

company.

This

holding

all nonbanking

in

the

activities

subsidiary

company

could

of

be

an

of a

banking

overall

holding

subject

to

the

same

regulatory framework that we have now for holding companies.

This

proposal, put forward by the President of the Federal Reserve Bank
of New York,
should not

suggests

that

extend beyond

the powers of bank holding

securities and

companies

insurance activities

and

that traditional holding company regulation is appropriate in this
context.

-10-

(2)
regulation

In

should

contrast,
be

applied

others

suggest

to

of

each

the

that

functional

different

kinds

of

activities owned by a holding company parent, but there should be
little if any regulatory authority over the parent enterprise.

recently

(3) Finally,

suggestions have been made,

put

in

forward

appropriate

to

an

FDIC

expand

staff

paper,

nonbanking

including

that

activities

it

those

would

of

be

banking

institutions within the subsidiary of banks themselves without any
regulation at all at the holding company level.
While we have yet to come to definitive conclusions about
these
that

implementation
the

most

financial

options,

effective

or commercial

our

experience

insulation
activities

of

a

thus

bank

is achieved

far

suggests

from

affiliated

through

a holding

company structure, though we welcome debate on other alternatives.
We also agree that attention must be given

to the

range of relationships between a bank and its affiliated
to

assure

that

confidence

in banks

conflicts of interest are avoided.
such issues as

is not

compromised

need

premises;

and

that

(a) the need for limitations on loans by a bank to

for

adequate

separation

(c) restrictions

information,

(d) the

(e) rules

intercorporate

on

entities

In addition, we are addressing

affiliated enterprises or to customers of affiliated
(b) the

whole

scope

on
of

of

the

directors,
flow

permissible

provision

of

of
joint

services,

need for public disclosure of affiliate relationships.

enterprises;
officers

and

confidential
marketing,
and

(f) the

-11-

As a result of this review we at the Board hope to be in
a position
changes

to

that

advise
we

see

financial system
expect

to

have

the

Congress

are

needed

to

We

insulation,

soundness,

prevention

on
of

the

on

how

maintenance

conflicts

of

assure

best
of

all

these

competitors

that

recommendations

proceeds
financial

with

its

system

are

will

similarly
be

interest,

consideration

and

that

our

situated.

valuable
of

to

the

to

the

We

on

unavailable
hope

Congress

will

and

and

restructuring

recommendations

achieve

safety

avoidance of conferring competitive benefits that are
to

the

continues to serve our public policy goals.
recommendations

to

implement

the

bank-affiliate
on

urgently

best

that

specific

so

on how

that
as

it

of

our

enable

the

American financial system to remain competitive, serving the needs
of customers here and abroad without compromising the strength or
stability of our financial markets.

Board of Governors of the
Federal Reserve System
Washington, D.C. 20551
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