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For Release on Delivery
8:45 AM, P.D.T. (11:45 A M , E . D . T . )
May 9, 1988

THE • I N T E R N A T I O N A L I Z A T I O N OF WORLD FINANCIAL M A R K E T S -IT'S A SMALL WORLD

H. Robert Heller
M e m b e r , Board of G o v e r n o r s of the Federal Reserve System

1988 Financial A n a l y s t s Federation Annual Conference
San F r a n c i s c o , California
May 9, 1988

THE INTERNATIONALIZATION OF WORLD FINANCIAL MARKETS ~
IT'S A SHALL WORLD
By
H, Robert Heller

All of us here today will agree that the globalization
of world financial markets is indeed a reality.

I want

to talk to you about what that reality means, for
banks, for their regulators, and for you as financial
analysts.

The concept of the internationalization of financial
markets is increasingly taken into account by financial
organizations in their strategic planning.
makes this a necessity for most major banks.

Competition
And all

banks will soon have to meet safety and soundness
requirements that have been developed by the regulators
to respond to the internationalization of banking
markets.

In the context of these developments, anyone who looks
at banks only in terms of national markets will be left
behind.

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What has happened to the foreign exchange market in the
past decade is indicative of the overall trends.
Turnover in the foreign exchange market has grown 10to 12-fold in the past decade.

At the same time, many

new players have entered the market.

The total value

of global foreign exchange transactions is now in the
neighborhood of $400 billion per day - which is almost
twice as much as our annual export volume.

The currency range of the market has also expanded.
The yen has assumed a key role in foreign exchange
markets —

along wit'h the dollar and the mark.

And

currencies such as the Australian dollar have become
more widely traded as their use in capital market
transactions has expanded.

Another very significant change that has occurred only
recently is the arrival of the 24-hour foreign exchange
market.

With the development of new Asian trading

centers that bridge the gap in business hours between
Tokyo and London, around-the-clock trading is now a
reality.

I want to focus my remarks today on two important
questions:

first, what are the implications of the

globalization of financial markets for U.S. banks, and
second, what kind of regulatory framework is
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appropriate in a global banking environment.

For an American observer, some of the trends that have
accompanied the internationalization of financial
markets are worrisome.

American banks once dominated

world financial markets.

Now, they concede significant

parts of that turf to foreign competitors.

The 1970s brought rapid overseas expansion by the major
U.S. banking organizations and tremendous growth in
overseas lending, particularly to developing countries.

In contrast, it seems that in the 1980s American
bankers are falling behind their foreign competitors.
U.S. banks, are no longer aggressively pursuing international lending business; however, foreign banks are
increasing rapidly their role in the U.S. commercial
lending market.

The U.S. banks that are active in the international
arena tend to focus on international investment and
foreign currency activities, rather than on traditional
commercial banking activities.

Here are the facts:

In 1972, the 3 largest banks in

the world, ranked by deposits, were U.S. based.
the largest U.S. bank ranks only number 17 in the
3

Now,

world.

The rise in the value of the dollar in the

first half of the 1980s and the relative decline of the
currencies of our key competitor countries temporarily
masked the underlying trends.

But, with the return of

the dollar to a more realistic value, the decline of
the relative position of American banks has become
obvious.

American banks have not only declined in relative
position against their foreign competitors, but also in
the absolute size of their foreign presence.

Foreign

branch assets of American banks grew from about $10
billion in 1965 to a peak level of $391 billion in
1981, before declining to $331 billion by the end of
last year.

The same trend is also apparent in the physical
presence of American banks abroad.

Foreign branches of

U.S. banks quadrupled from 211 branches in 1965 to 917
branches by 1984.

Since then, the number of foreign

branches declined to 899 by the end of last year.

At the same time that we have seen this decline in the
importance of international lending activities by U.S.
banks, foreign banks have substantially increased their
share of the U.S. commercial lending market.

In 1978,

foreign-controlled U.S. banking offices held $33
4

billion in loans to U.S. commercial and industrial
borrowers, representing about 13 percent of the U.S.
business loan market.

By 1986, the volume of lending

by the foreign bank offices to U.S. businesses had
grown to $127 billion, representing 23 percent of the
market.

By this, foreign bank offices have roughly

doubled their share of the U.S. business loan market
during the last decade.

Should we be concerned about these trends and
developments? I believe that the increasing presence of
foreign banks in the United States not only benefits
American consumers and business, but also reflects the
ever increasing globalization of international
financial markets.

It benefits us if we become a

marketplace for the world.

However, the declining presence of U.S. banks abroad
represents a more worrisome trend.

First, over the

decades, U.S. banks have gained a vast amount of
knowledge and experience in international banking.
This investment in human resources should not be
allowed to go to waste.

Second, banks with an international presence tend to
have large investments in buildings, offices, computers
and other facilities.
5

Once these fixed costs have been

incurred, a cutback in the operating rate may actually
increase per-unit costs.

Third, it takes many years to assemble a global network,
which is much more valuable than the sum of its parts.
Banking is a regulated industry in every country of the
world.

Entry is frequently restricted and banking

licenses in many countries are not freely available.
Once banking licenses have been obtained, they cannot
be returned to the national authorities for cash.
Furthermore, it is unlikely that a bank can dispose of
its international network intact.

Laws and regula-

tions in the various countries may stand in the way of
a transfer of the respective banking licenses to a
single buyer.

The buyer, in turn, may already have a

significant foreign presence and purchasing the entire
network may therefore not be attractive.

Consequently,

the going-concern value of an international banking
network is likely to exceed its liquidation value.

Fourth, American exporters need international banking
services.

It has been argued many times that "finance

follows trade".

On the other hand, if trade-finance is

unavailable because American banks disengage from the
international arena, American businessmen will have to
conquer new export markets without an important ally in
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the form of their own banker.

The loss of that extra

competitive edge may be costly in terms of foregone
sales.

Fifth, foreign trade is now the fastest growing sector
in the American economy, and American banks stand to
lose important profit opportunities if they choose not
to finance that sector.

Also, as a long-term

proposition it stands to reason that foreign trade will
expand more rapidly than national economic activity in
general.

Thus, international banking should be a

strategically important sector.

Finally, international banking offers important opportunities for portfolio and earnings diversification
that cannot be achieved within the national borders.
Indeed, due to the interstate banking restrictions that
prevent American banks from achieving the full benefits
from portfolio diversification at home, the possibility
of international diversification may be all the more
important.

What caused the decline in international banking
activity by American banks?

The answer to this

question lies both in certain competitive inequalities
based in existing law and regulation as well as in the
impact of the LDC debt crisis.
7

We will therefore have to ask ourselves what can be
done to improve the competitiveness of U.S. banks in
the international arena?

The banks, the regulators and

Congress can cooperate to reduce and, hopefully,
eliminate any remaining international competitive
inequities.

While there are many complex and diverse

issues to be faced, a few problems stand out.

American bankers have complained for a long time about
geographical and product-line restrictions in the
United States that limit the formation of a broad home
base upon which to build their international activities.

If we are to improve the international competi-

tiveness of U.S. banks, we need to reduce these
product-line and geographical barriers to banking in
the United States.

Congress is well along in its considerations of the
Financial Modernization Act, which would grant banks
the right to offer a broader product range; a range
that more closely approximates the types of services
that foreign banks are able to offer their customers.

Interstate banking restrictions constitute another
barrier toward building a strong base upon which to
build an international banking presence.

The states

have taken the lead in reducing the barriers to

8

interstate banking.

Some 40 states have adopted some

form of legislation pertaining to the issue, but the
remaining patchwork quilt of regional and reciprocal
interstate banking privileges constitutes a cumbersome and irrational arrangement that needs Congressional attention.

The interstate commerce clause of

the Constitution brought national markets and
prosperity to commerce and industry.

Let's apply the

same principle to banking!

Another problem that may have handicapped American
banks in their international activities is that
American capital requirements are more stringent than
those of some other countries.

It should be pointed out that banks domiciled in still
other countries where capital requirements are even
stiffer seem to have suffered few ill effects from
these capital requirements.

Indeed, their strong

capital bases may have enabled them to attract those
foreign deposits looking for a very high degree of
safety and they may have been able to raise funds at
advantageous rates due to their high credit ratings.

Nevertheless, high capital requirements that apply to
all asset categories may discourage banks from engaging
in certain types of business.
9

For instance, some

internationally active American banks reduced their
interbank credit lines in the early 1980s, after the
current regulations regarding primary capital were put
into place.

Given the very thin margins prevailing in

the interbank business, these exposures simply could
not generate enough of a profit margin to justify the
capital requirements.

As banking markets become increasingly globalized, a
primary task for the bank regulators is to bring about
the harmonization of the competitive environment.

This

is the goal of the new risk-based capital framework
proposed by the Basle group of 12 regulators.

This

international framework for evaluating capital adequacy
will provide the same definition of capital, the same
risk classes and the same leverage ratios for all
internationally active banks.

The risk-based standards tentatively agreed to in Basle
identify specific capital ratio targets for year-end
1990 and for year-end 1992.

In the meantime, banking

organizations should be expected as a minimum either to
meet the Board's current primary capital guidelines or
to have risk-based capital ratios that are consistent
with attaining the 1990 standards.

In keeping with the

Board's policy of national treatment this applies to
domestic as well as foreign banking institutions.
10

It is also true that many internationally active banks
were hit hard by the LDC debt crisis, which impacted a
major part of their portfolio.

Consequently, the

appetite for international lending was sharply reduced.
Due to the lingering of the debt service problem, new
lending continues to be sharply curtailed.

The regulators have tried to be helpful in the
resolution of the international debt service difficulties by working with both lenders and borrowers in
bringing about a constructive dialogue and resolution
to the problem.

Where there were regulations that

impeded progress, we have taken the necessary actions
to modify or remove such regulatory barriers —
all within the framework of safe-and-sound banking
practices.

The liberalization of Regulation K to make

debt-to-equity swaps easier is a prime example of such
pro-active regulatory action to ease the LDC debt
service burdens.

I cannot let this opportunity pass without mentioning
some points that the Federal Reserve considers
important at the present time.

We consider the capital

adequacy of banking organizations highly important in
these troubled times.

In particular, we look to the

bank holding company to be a source of strength for the
bank.
II

Also, along the same lines, in bank merger cases

there should be no weakening of the combined
organization's capital base.

That is, any cash paid

out in the transactions would need to be supported by
new issues of capital, not mere accounting adjustments.
This is particularly important when mergers of large
institutions are being considered.

Finally, the

Federal Reserve is concerned that dividend payouts by
banking organizations not be excessive, and be based on
the banks' actual earnings.

For many institutions,

retained earnings represent an advantageous way to
build capital and may obviate the necessity to go to
the market in situations where this is not desirable.

I would conclude that American banks face many new
challenges and opportunities in what has become a
global financial marketplace.

The world has changed

rapidly with the result that there are many competitive
inequities to be resolved.

The regulators have taken action to level the international playing field and to equate competitive
conditions among nations.

Within the framework of

sound banking practices, we have also removed, or
reduced, barriers and obstacles to international
business.

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For you as financial analysts, it is important to be
mindful of both the risks and opportunities present in
the international marketplace.

My parting thought for

you is that you should not only be conscious of the
risks inherent in international banking, but also
consider the diversification and profit opportunities
foregone by a bank that decides not to be a player in
the global arena.