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FRB: BOSTON.
STUDIES.

/

ADDRESSES.

RESEARCH
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I

THE COST OF PRICE CONTROL INBANKING
by
Frank E. Morris
President
Federal Reserve Bank of Boston

B

A paper given before the
Eastern Economic Association
May 10, 1979

The banking industry in the United States is unique in
its regulatory treatment in that, while banking has none of the
characteristics of a public utility which would render competition
socially wasteful, competition in banking is restrained under
Federal law both geographically and in terms of the interest
rates that may be paid on deposits.
Geographic restraints on banking competition go back to
the earliest days of our Republic and reflect a fear of concentration in finance.

The followers of Hamilton wanted a strong

national banking system which they felt was essential for the
development of a vigorous manufacturing industry.

However, the

followers of Jefferson, the farmers and the people of the frontier
states, felt that such a system would leave their destinies in
the hands of Eastern money-center bankers.

The Jeffersonians

won the issue and the uniquely decentralized banking system of
the United States resulted.

The pattern in all other industrial

nations is that ten or fewer commercial banks control 90 percent
or more of commercial bank deposits. 1 In the absence of restraints
on competition geographically, there is little reason to suppose
that our banking structure would have developed much differently.
The national political climate of concern about concentration
in banking led to the primacy of the states in determining the
In

the United States, the top ten banks control only 35
percent of commercial bank deposits.

structure of banking within their boundaries and to the passage
of restrictive state laws, some of which had the effect of
2
encouraging local monopolies.
We have seen in recent years
the beginnings of some new thinking in the Congress questioning
whether, in seeking to avoid banking concentration nationally,
we have allowed too many restraints on competition and whether
a position somewhere between Jefferson and Hamilton might
produce better results for the consumer of banking services.
Politically, this issue is closely related to the issue of
restraints on price competition in banking.
Restraints on price competition have a much briefer
history, dating only to the early 1930s.

They were the product,

not of an y social or economic philosophy, such as we find in the
history of geographic restraints on competition; the y were, instead,
the products of reaction to crisis--the commercial banking crisis
of the early 1930s and the crisis of 1966 in the case of the
thrift institutions.
A mythology devel oped during the 1930s to the effect that

the massive bank failures of that era were caused by excessive
price competition for deposits.

The subsequent research on

this issue has not lent support to this thesis.
myths have their uses.

3

Nevertheless,

This one gave the Congress a basis for

2

Typical of these is Connecticut's Home Office Protection
Statute which prohibits any bank from establishing a branch in
any town which is the home office of another bank.
3

See George J. Benston, "Interest Payments on Demand
Deposits and Bank Investment Behavior," Journal of Political
Econornv, October 1964, and Albert H. Cox, Jr., Regulation of
Interest on Bank Deposits (Michigan Business Studies, Vol. XVII,
No. 4, 1966 ) .

-3-

moving against our most fundamental economic instincts and
passing legislation restraining price competition for deposits.
The real rationale for the legislation was quite different.

One of the principal objectives of the Administration and the
Congress was to pass legislation establishing deposit insurance.
The original deposit insurance plan e nacted in 1933 was very
expensive to the banks.

It called for an assessment of one-half

of one percent per dollar of deposits.

It Kas particularly

expensive in an era when short-term money rates had fallen to
very low levels.

The average 90 -day Treasury Bill rate in

1933 was 0.52 percent.

To accept this sizable new burden when

their earnings were so depressed and their capital had been
seriously eroded by loan losses the banks required some quid
The political tradeoff for deposit insurance was the
4
acceptance of legislated restraints on price c ornpetition.
Restraints on price competition among thrift institutions
were not imposed until 1966, when the vulnerability of those
institutions to sharply rising interest rates was first exposed.
Oddly enough, the objective was not so much to prevent excessive
price competition among thrifts, but to protect the thrifts
from the competition of commercial banks.
4

See "Interest on Demand Deposits," Golembe Re p orts,
Vol. 1975-10 (Carter H. Golembe Associates, I nc., Washington,
D. C.).

- 4-

Whenever restraints on competition are imposed by government, certain costs must be incurred.

In the case of price

control in banking, the costs are of two sorts:

first, that

the banking system operates less efficiently than it would
in the absence of price controls--less efficient in the sense
that the essential body of banking services is produced at a
higher cost; and second, that the controls discriminate against
the small depositor.
Some useful analogies may be drawn betKeen the stock
brokerage business, which prior to 1975 operated under minimun
commission restrictions, and the banking business.
Whenever minimum prices are established for the services
of an industry (as was formerly the case in the brokerage
industrv) or whenever maximum prices are established for the
raw materials used by an industry (such as in the banking
industry today), a shelter is created under which the inefficient firm may be able to survive.

Removing that shelter is

likely to result in some decline in the number of organi:ations
operating in an industry, with the survivors operating at a
lower average cost.
From 1968 (the peak year for the stock market) to 1977,
the number of member organizations on the New York Stock
Exchange declined by almost 27 percent.

s

Much of this decline

would have occurred even if the minimum commission system had
survived; as the long bear market in common stocks produced a

sNew

York Stock Exchange, Fact Book.

- 5-

much reduced participation of individuals in the market.

Indeed,

most of the decline occurred before competitive rates actually
began in 1975.

However, I think there is little doubt that

part of the decline represented the weeding out of a sizable
number of firms that could not survive in an environment of
competitive rates.

With fewer firms transactions on the New

York Stock Exchange are now being carried out at a substantially
lower average cost than in the pre-1975 era.
We have seen in the years since World War II a fairly
6
steady growth in the number of commercial banks.
I would
expect this trend to be reversed if the shelter of restraints
on price competition were removed.

The reversal would be even

more marked if some of the restraints on geographic competition
were also to be loosened.

However, the major improvement in

the efficiency of the banking industry is not going to come
from the elimination of inefficient banks, but from the elimination of socially wasteful forms of competition which always
arise when price competition is restrained.
When price compEtition is restrained, competition is
like y to be expressed in other forms.

In the case of the

banking industry, it is expressed primarily in giving away
costly services and in adding branch offices to compete by
offering greater convenience.
6

From the end of 1945 to the end of 1978, the number of
commercial banks increased by 5 percent.

The most important example of costly services given away
is the free checking account.
Since it costs about 30¢ to
clear _a check, 7 while to the customer it is a free good, it
is clear that the value of the check-writing service to the
marginal user is going to be substantially less than the cost
of production.

The average consumer would be better off with

an unbundled system under which he is paid a market rate of
interest on his deposit and is charged a fee for writing checks
based on the cost of producing that service.
Prior to the establishment of competitive brokerage rates,
the rates paid on large transactions were so extremely profitable
that brokers offered all sorts of free services to institutional
investors for so-called "soft dollars."

The fact that the

cost of production of these services vastly exceeded their
value to the marginal user is demonstrated by the fact that
few of these services have survived the initiation of competitive
brokerage rates.
Another socially wasteful

form

of competition in banking

under a price control regime takes the form of a proliferation
of branch offices.

From 195 7 to 19 7 7, the number of commercial

banks in the United States grew by about 6 percent, but the
number of branches more than quadrupled from about 8,000 to
more than 32,000.

8

Since the countr y grew substantially during

see
Paul S. Anderson, ''The Costs and Profitability of
Bank Functions," New England Economic Review, March / April 1979.
8 Federal Deposit Insurance Corporation, Annual Report.

- 7-

those years, there was undoubtedly an economic need for some
additional branches, but the quadrupling of the number of
branches must largely reflect an uneconomic form of competition.
A study recently published by the Federal Reserve Bank

of Boston attempted to identify the increase in branching that
was associated with the imposition of restraints on price
9
competition.
Because most of the savings banks 1n Massachusetts
are not Federally insured, they did not become subject to interest
rate ceilings until January 1970.

A model was constructed

describing the behavior of the Massachusetts savings banks during
the decade of the Sixties.

The model generated, among other

things, the interest rates paid relative to market rates, the
growth in branches and the growth in operating expenses.
The model estimated that, in the absence of restraints,
Massachusetts savings banks would have paid an average deposit
rate 1n 1975 of 6.73 percent, rather than the actual
rate of 5.73 percent.

average

The estimated interest loss to depositors

at mutual savings banks in Massachusetts during the years 19701975 amounted to $527 million.

The branching practices of the

Mas s a ch use t ts s av in gs banks ch an g e d a 1 rn o s t i mm e di at e 1 y f o 11 owin g
the imposition of rate ceilings.

During the period 1970-1975,

84 more branches were established than the model would have
projected based on the pre-control experience of the 1960s.
These 84 branches constituted almost
bank offices in 1975.
9

16 oercent of total savings

In large part due to the additional

Rogert A. Taggart, Jr. and Geoffrey Woglom
"Savings Bank
Reactions to Rate Ceilings and Rising Market Rates," New England
Economic Review, Federal Reserve Bank of Boston, SeptemberOctober 19 78.

- 8-

branches, total operating expenses for the period 1970-1975
were $93 million higher than the model would have estimated.
The ad_ditional operating expenses in the year 1975 equaled
25 percent of total operating expenses.
I think it is clear that the removal of restraints on
price competition wo uld lead to a substantial decline in the
number of branch offices of both commercial banks and thrift
institutions.

There is another, independent force which is

also pushing in this direction; that is, electronic funds
transfer which is likely to make the grocery store a more
convenient place to bank than the branch bank.
In addition to its negative impact on the efficiency of
the banking business, price control in banking has, in effect,

mandated discrimination against the small depositor.

The large

depositor has many options open to him which assure his ability
to get the going market rate on his funds; the small depositor
does not and, consequently, it is the small depositor that must
bear the cost of rate ceilings.

If he happens to be a depositor

in a commercial bank, he receives an extra dose of discrimination
due to the one-quarter of one percent differential on ceiling
rates enjoyed by the thrift institutions.
The dependence of the poorer segment of our society on
the ordinary savings account as an investment medium is documented
in recent work by Edward Kane.

He found that 88 percent of the

wealth of households with total wealth of $1,000 or less is
lodged

1n

rate-regulated financial assets.

This percentage drops

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to 40 percent for households with $1,000-$5,000, to 20 percent
for those with wealth of $5,000-$10,000, and ultimately, to
10
5 percent for those enjoying wealth in excess of $250,000,
It may seem surpr1s1ng that this legislated discrimination
against the small saver could have persisted so long without
some consumer group rising in protest.

Yet until 1978, when

t ]1 e Gray Pant he rs to o k up the i s sue , consumer groups were s i 1 en t .
The answer, it seems to me, lies in the fact that rate ceilings
produced one significant benefit--lower mortgage rates than
a free market would have produced.
To return to the study of the behavior of Massachusetts
savings banks cited earlier, you will remember that it was
estimated that the interest loss to depositors due to controls
during the 1970-1975 period was $527 million.

It was also

estimated that operating expenses were $93 million higher than
they would have been in the absence of controls, due in large
part to the proliferation of branches.
remaining $434 million?

What happened to the

Since there was no above-trend rise

in the earnings of Massachusetts savings banks during this
period, it seems clear that the $434 million was primarily
reflected in lower mortgage interest rates.
Thus, the savings depositor was subsidizing the home
buyer.

While this would be difficult to defend on equity

Edward
J. Kane, Testimony before the United States
Senate Committee on Banking, Housing and Urban Affairs,
April 12, 1979. The numbers quoted above pertain to maleheaded white households.

-10-

grounds, particularly since it has been shown that the average
income of the savings depositor is substantially below the
income of people wwho take out mortgages, 11 it ..was a

average

result that the housing lobhy applauded.

Whether explicitly

or implicitly, consumer groups (until the Gray Panthers came
al c ng) sided with the housing lobby.
In the case of minimum commission rates for brokers,
controls were first eroded by the action of the market, and
legislation follo¼ed eliminating the controls.

It appears that

the same sequence 1s likely to be followed with price controls
1n banking.
In the case of stock trading, the principal market response
was the development of the "third market" in which large transactions were executed off the exchanges at commission rates
substantially below the minimum schedule.

The strains generated

•

by the "third market" v.:ere such that Congress ultimately
responded by outlawing the minimum commission schedule.
The market has been responding gradually to price controls
1n banking for many years; but the pace of the response has
accelerated in recent years and it has so eroded the control
system that Congressional action is likely to be forthcoming
1n the not too distant future.
In the case of the prohibition of the payment of interest
on demand deposits, banks have long offered to large corporate
11

see Projector and Weiss, Surve y of Financial Characteristics
of Consumers, Board of Governors o f t h e Fe d eral Reserve System,
Was h ington, D.C., 1966.

-11-

customers the device of the repurchase agreement--the sale of
a security by a bank with an agreement to buy it back at a
set price--a device which enables the bank to pay interest on
overnight money.

Nonbank corporate repurchase agreements

totalled some $42 billion at the end of March 1979.

The

corresponding figure for March 1975 was $13 billion.
In the case of individuals, the market (sometimes with
and sometimes without the blessings of the regulatory authorities)
has created various ways of transforming a savings account on
which interest can be paid into a transactions account.

The

h i c h em e r g e d
f i r s t o f th e s e d e v i c e s wa s t he Now a c c o u n t , wh
1972.

1

n

This was followed by the credit union share draft, the

automatic transfer account and the so-called "remote services
un i t '' o f the savings and l o an as soc i at i on , a 11 of

Whi

ch have

had the practical effect of paying, interest on individual
transaction accounts.
Challenging the ceilings on savings and time deposit rates
are a growing variety of nonbank institutions which are offering
attractive investment alternatives to consumers.

The largest

of the alternatives at the moment are the money market mutual
funds which currently have some $20 billion in funds.
other emerging alternatives are:

Among the

the Merrill Lynch Cash Manage-

ment Plan and other similar plans offered by brokers; the
action of the State of Massachusetts in offering state bonds
with denominations as low as $500, an action which other states
might emulate; and the proposed move of Sears Roebuck to offer

-12small denomination securities to its millions of customers.

The

Sears proposal was followed just this week by the Green Mountain
Power Company of Burlington, Vermont which plans to offer

its

securities in denominations as low as $500 to Vermont residents
at rates substantially higher than Regulation Q ceilings.
Undoubtedly, the greatest catalyst

for Congressional

action was a recent decision of the United States Court of
12
Appeals for the District of Columbia
in which the Court
ruled that automatic funds transfers, credit union share drafts
and the savings and loan associations "remote service units''
were all in violation of existing Federal statutes.

The Court

stayed the execution of its order until January 1, 1980 so that
the Congress would have time to deal with these issues.
Since the Congress rarely takes away a valued privilege
which the consumer has been enjoying for some time and since
the Congress usually acts to eliminate

controls that have been

badly eroded by the action of the marketplace, it is possible
that we will see this year Congressional action to eliminate
the prohibition of interest on demand deposits and action to
phase out, probably over a period of several years, ceiling
rates on savings and time deposits.

When and if this takes

place, market forces will be set in motion which will generate
a more efficient banking system and one which will no longer
discriminate against the small depositor.
12 september Term 1978, Civil Action No. 77-2102.