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For Release on D elivery
Expected
at 9:30 A.M.,

E.D.T.

Statement by

Lyle E. Gramley

Member, Board of Governors of the Federal Reserve System




before the

Subcommittee on Monopolies and Commercial Law

Committee on the Judiciary
United States House of Representatives
July 8, 1981

I am pleased to be here today, on behalf of the
Federal Reserve Board, to discuss issues of concern to this
Committee regarding recent mergers within the financial
services industry.

News reports of recent and proposed

affiliations suggest a rapid pace of change in the structure
of this industry.

You are not alone in being concerned with

these developments.

Commercial banks and thrift institutions

are uneasy about the increasing incursions into their traditional
domain.

The Federal Reserve Board is also keenly interested for

a number of reasons.

We are one of the financial regulatory

agencies charged--together with the Comptroller of the Currency
and the Federal Deposit Insurance Corporation--with responsibil­
ities for preserving healthy competition in the financial sector
and a safe and sound banking system.

In addition, we must be

alert to developments in financial markets that have a bearing
on our responsibilities for the conduct of monetary policy.

Public attention has recently been captured by a few
mergers of large firms in the financial services industry, and
by announcements of affiliations between brokerage firms and
firms providing "bank-like" services.
developments, however,

The significance of these

is perhaps better understood from a

longer-term perspective.

Let me therefore begin by reviewing

some major trends in the financial services industry over the past
quarter century.




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During that period, the rate of inflation has gone
up sharply, and carried interest rates to ever higher levels
in its wake.

The premium on maximizing the returns earned

on financial assets has therefore been greatly increased.
Households and businesses have paid increasing attention to
protecting the real value of their assets, and have become
increasingly sophisticated in cash management techniques.

The

rapid pace of technological change in the computer and communica­
tions fields contributed to these developments by opening new
opportunities for aggressive and competitive entrepreneurs to
make innovations in financial services.

And as economies of

major nations have become increasingly interlocked,

pressures

of foreign competition have encouraged changes in financial
institutions and the structure of financial markets.

Because of the increased sophistication of customers
and their heightened sensitivity to interest rate differentials,
depository institutions can no longer expect an automatic flow
of deposits into zerc-i.riterest checking and low-interest passbook
saving accounts.

Consequently,

these institutions have sought

to circumvent legislated or regulatory interest rate ceilings by
more extensive use of liabilities not subject to ceiling,

such

as large, negotiable certificates of Heposit, or by offering
imaginative new services,




such as auromatic transfer account-.

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New institutions,

such as the money market mutual funds, have

also sprung up.

Major regulatory changes--such as the author­

ization of money market certificates (MMCs) in 1978 and the
phasing out of deposit-rate ceilings just announced by the
Depository Institutions Deregulation Committee--have been made
in response to these circumstances.

As a result,

there has

been an enormous expansion in the variety of financial assets
available to savers.

As I noted earlier,

technological advances are playing

an important role in this changing structure of the financial
services industry.

Without advances in the computer and

telecommunication industries, automatic transfer, pay-by-phone
and similar services would be prohibitively expensive.

Automation

of data production and transmission will continue to have a major
role in shaping the financial industry.

An increasing volume

of financial transactions will be cleared electronically through
automated clearing houses, or transferred by wire.

These

technological developments will allow virtually instantaneous
flows of funds between financial instruments and institutions
at very low costs.




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Pressures to provide more and better financial
services have blurred the distinctions between classes of
financial institutions and between financial and nonfinancial
firms.

This develpment is still far from complete.

Differences

remain between banks and savings and loan associations,
although they are narrowing.

And the once firm boundaries

between depository institutions and other types of financial
firms, and between financial and nonfinancial businesses, are
also weakening.

The recent mergers are, thus, one more

illustration of a general trend under way for a number of years.

Viewed from the perspective of securities markets,
another important forerunner of recent affiliations between
brokerage firms and other financial.institutions was the intro­
duction of competitive brokerage rates on securities in 1975.
This change reduced the profit margins on traditional lines
of brokerage business, and encouraged aggressive firms to
diversify their activities.

Some firms could not survive and

a substantial number of mergers have occurred in the brokerage
industry.

This has not, however,

led to a diminution of

alternatives available to consumers.
has occurred.

In fact, just the opposite

A wide array of different types of retail

brokerage firms has come into existence.
a complete line of products,




Some firms provide

including investment research and

-

advice.

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Others provide securities transaction services at

sizable discounts»and very little else.

The result has been

an increase in the options available to the investor at lower
prices.

He can choose between full service or limited services,

high or low commissions, massive investment research or none
at all.

These developments in the brokerage industry help to
explain the shrinking differentiation between brokerage firms
and other financial institutions.

They also illustrate that

change and consolidation may result in increased competition,
new services, and lower prices for consumers in the financial
services industry.

Let me now turn to your question regarding the
possible effects of these trends on banks and thrift institutions,
and particularly on the small and medium-sized institutions.
How will these institutions fare in a world of increased
competition?

The record of the past two decades and longer,

when competition among financial institutions was steadily
increasing, attests to the basic strength of our nation's
depository institutions and their capacity to adapt to a
changing environment.




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Table 1 shows, for example,

that banks supplied 27

percent of the total credit borrowed by the nonfinancial sector
in the five years 1976 to 1980.

This was lower than the share

they provided in the 1960's and the first five years of the
1970's, but it is well above the 20 percent share that prevailed
in the 1950's.

The share of total credit supplied by mutual savings
banks, savings and loan associations, and credit unions, on the
other hand, has not changed markedly during the past 15 years,
but is below what it was in the 1950's and early I960's.

The share of total household savings in the form of
deposits and credit market instruments captured by commercial
banks has also decreased from the level of the ■960's, as
Table 2 indicates.
in the 1950's.

Again, however,

The thrift industry's share of hoiisehold

savings in these forms, however,
period.

it is higher chan it was

declined over die thirty-vear

These data do not, of course, reflect the influence

on deposit shares of NOW accounts and share draft accounts.
Moreover,

the gradual removal of Regulation Q interest rate

ceilings may help to reverse this downward trend at thrift
institutions.




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Further indication of the ability of commercial banks
to compete can be found in the history of their earnings.
Rates of return on assets and equity capital for the banking
industry are presented in Table 3.

For the industry as a

whole, profitability has risen over the past thirty years.
Evidently,

the commercial banking system has coped quite

successfully with innovation and change.

For most of the past decade,
also held their own (Table 4);
to those of earlier periods.

thrift institutions

their earnings were close
Earnings of thrift institutions,

however, are very sensitive to changes in rates of interest.
During the past year or so, the combined effects of rapid
increases in interest rates and the imbalance between the
maturity of their assets and their liabilities have sharply
reduced earnings in the thrift industry.

The thrifts will be

subject to earnings problems until they are able to make more
new, higher-yielding mortgage loans, and in other ways to
diversify their asset portfolios.

The earnings experience of all banks or thrifts, how­
ever, need not reflect the problems of smaller institutions.
Data for these smaller institutions is more difficult to obtain.




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Table 3, however, shows earnings of small banks over the past
decade.

Earnings were higher for the small banks in the second

half of the decade than in the first, and higher, also,
for large banks.

than

Indeed, even ratios of earnings to capital

for small banks exceed those for large banks, despite the fact
that ratios of capital to assets of small banks are roughly
double those of larger banks.

There is other evidence supporting the view that
small banks can survive in the current environment.

For 1980,

a detailed sample of small banks shows that, in 156 of 265
Standard Metropolitan Statistical Areas,

the smallest size

category of banks in each area earned a higher average return
on assets than the largest size group in each area.

Thus,

even in these large and highly competitive urban markets,
small banks have been competing effectively.

How is it possible for a small bank, with (say)
less than $100 million of assets,
multi-billion dollar banks?

to hold its own against

Part of the answer is that there

are relatively few economies of large scale operations in
commercial banking.

That conclusion has emerged from a number

of careful empirical studies.




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In addition,

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small banks offer many of the unique

services of the specialty shop.

A customer may be able to

talk directly to the senior bank officers,

rather than to a

branch manager who has limited decision making power.

Moreover,

if a customer requires a specialized bank service that cannot
be supplied by the small bank directly, arrangements can often
be made to provide it through one of the small bank's
correspondents.

I would hazard the guess that there will continue to
be a substantial demand for the specialized services that small
banks provide.
industries.

Consider for a moment the evidence from other
In the retail trade sector, we have giant chain

department stores offering a wide range of products in outlets
across the nation.

We also have small specialty shops

offering cne or two product lines.

Similarly, retail food

outlets differ markedly in their size and degree of specialization.
And, although there are high rates of business births and
deaths in retailing,

there are many examples of competition

among long-established stores of differing sizes.

Yet another,

more striking illustration can be found in the steel industry-where smaller firms, using new technology, are able to compete
effectively with industrial giants both here and abroad.




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Let me turn next to the question of how consumers
of financial services are affected by recent trends.

Thus

far, consumers have clearly benefited from the interwoven
effects of product innovation and institutional deregulation.
More firms are competing in the sale of more financial services
than before.

Some of them are old-line financial firms;

others are new, or predominately nonfinancial, firms offering
financial services.

The consumer has increased freedom to pick and
choose between institutions,
For example,

services, and pricing systems.

savers are able, more readily,

to obtain market

rates of return on a larger part of their financial assets.
Nationwide expansion of NOW accounts carries this process
another step by making it possible for households to receive
interest on checking accounts.

At the same time, consumers

are learning to shop among institutions imposing different
minimum balances and service charges.

Previously, many of

these charges were, in effect, netted against low or zero
interest payments on accounts rather than appearing
explicitly.




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Similarly, financial services increasingly are being
unbundled.
services,

Rather -than dealing with one institution for all
the consumer has the option to deal with a variety

of service vendors.

The services of a checking account may

be purchased from a commercial bank while the saver may, if
he chooses, place temporarily idle balances in a money market
mutual fund and obtain a consumer loan from yet another type
of financial institution.

One-stop-shopping may still appeal

to many consumers, but there are now other attractive
alternatives available as well.

Can we be sure that these benefits extend to all classes
of customers--including farmers,
and small businesses?

local communities, minorities

Or will their needs for credit and other

financial services be neglected?

The answer to that question

requires weighing benefits and costs.
the ledger,

On the benefit side of

these specific groups of customers can expect to

gain, much as consumers in general, from heightened competition,
from the ability to obtain market rates of interest on financial
assets, and from the unbundling and more explicit pricing of
services.

In addition, business and household borrowers

generally can expect "to gain because more and more banks are
entering new market areas, by opening loan production offices,
Edge Act affiliates, and commercial lending subsidiaries.
thrift institutions are beginning to offer types of loans
previously available primarily only at commercial banks.




Also,

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Recent changes in financial practices have also altered
significantly the way in which a limited supply of credit is
allocated among potential borrowers.

Interest rates have

increasingly replaced non-price limitations
rationing the available amount of credit.

as a means of
Before the authoriza­

tion of money market certificates and the subsequent additional
modifications in deposit interest rate ceilings,

individuals

would divert funds from depository institutions to market
securities in periods of sharply rising interest rates.

This

shift in savings flows would result in a sharply reduced
availability of loans--for mortgage and construction financing,
and for farmers,

small businesses,

and others.

Recent

regulatory changes and financial innovations have substantially
reduced the extent to which monetary restraint results in sharp
reductions in the availability of credit to particular borrowers.
But it has done so at the expense of much higher interest rates
to these borrowers.

This point can be illustrated as it relates to credit
costs and availability to local communities and the agricultural
sector.

Before the 6-month MMCs

were introduced in the middle

of 1978, small rural banks found that they often lost deposit's
to the pull of higher interest rates in the central money markers,




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and they sometimes had great difficulty in meeting the loan
demands of their regular customers.

The MMC has enabled

agricultural banks to remain more competitive in the market
for savings--and they have played a particularly important role
in enabling rural banks to compete against money market mutual
funds which may tend to divert funds to urban areas.

By

March of this year-1slightly less than three years after the
MMC was introduced--it accounted for 27 percent of the total
resources of agricultural banks.

The shift into MMCs from passbook savings and other
low-rate instruments, however, has resulted in a marked increase
in the average cost of funds at these banks, and it has made
their costs much more responsive to swings in money market rates.
Consequently, farm loan rates have risen sharply, and now tend
to fluctuate in response to changes in the overall level of
interest rates.

Thus, when financial markets provide savers with more
opportunities to earn market interest rates, credit flows more
freely to borrowers.

Financial markets operate more efficiently

in channeling funds to the highest bidder.

But, when inflation

pushes interest rates to extremely high levels,

this market

efficiency imposes severe cost increases on those sectors of the
economy most dependent on credit.




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What conclusions for anti-trust policy flow from
this assessment of developments in the financial services
industry?

Let me point out, first,

that we see hundreds of

mergers and acquisitions in banking each year.

Fortunately,

however, hundreds of new banks are also established, and the
number of banking organizations has changed very little in
the past decade.

Actually,

the proportion of total bank

deposits held by the largest banks has declined slightly over
the years.

Will these highly publicized recent mergers between
nonbank financial firms squeeze out competitors?

To do so,

they must, first, produce successful operational entitites.
It is still too early to tell whether this will happen.
Many mergers do not produce the expected cost reductions or
profit growth.

The results are sometimes disappointing,

even when the merging firms produce the same or closely related
products.

In other cases, it is years before the benefits of

the merger are realized.

For example, in the 1960's,there was great concern about
industrial conglomerates, but many of those conglomerate firms
never achieved the expected profit results and, in some cases,
acquired firms were later divested.




the

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The success of recent financial conglomerates has
yet to be proven.

Can a salesperson in a brokerage office

be as knowledgeable about money market funds, life insurance
and real estate as he is about stocks and bonds?
not clear.

That is

The specialist in each of these areas may have

an advantage in information and experience.

In addition,

the commission system may orient the salesperson towards
his major product, rather than other less remunerative lines.

Market factor« frequently result in the market share
of a combined firm being less than the sum of the market shares
of the merging firms.

For example,

the merger between American

Express and Shearson may cause some banks to regard American
Express as a major competitor, and reduce their willingness
to purchase services supplied to banks by American E x nr e ss .
Moreover,

if a particular merger is successful, new entry by

competitors will be encouraged into the most proficable service
1ines.

These considerations suggest that recent trends in
the structure of the financial services industry do not raise
immediate alarms about the resulting effects on the pricing and




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availability of financial services to the public.

The

developing pattern of conglomerate mergers bears watching,
but it is much too early to suggest a need for policy actions.
These developments do raise questions for the Federal Reserve,
however, regarding how to preserve equitable competition among
different types of financial institutions, while maintaining
their safety and soundness
monetary policy.

and the effective operation of

I would like to discuss these issues briefly.

One important question is how to achieve an equitable
environment for competition among commercial banks,

thrift

institutions, and other producers of financial services.

The

Monetary Control Act of 1980 set in motion some important steps
toward this goal.

Reserve requirements will be adjusted so

as ultimately to impose a uniform requirement on all regulated
institutions.

The Act also required the Federal Reserve to

charge explicit prices that cover costs for the financial
services it provides, and to permit private firms to compete
with it in providing check clearing and other services.

The

schedule for phasing out interest rate ceilings adopted by the
Depository Institutions Deregulation Committee at its June 25th
meeting provides a program for adjusting interest rates to market
levels.

Now, institutions can plan their full transition to

the new deregulated environment.




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Banks and thrift institutions, nevertheless,

remain

more closely regulated than other financial institutions with
which they now compete.

Questions arise, therefore, concerning

the constraints on geographic expansion by depository in­
stitutions.

When money funds and nonbank providers of financial

services can operate nationwide,

is it equitable to restrain

banks to states or smaller areas?

Limitations on the security underwriting activities
of commercial banks and other similar limitations imposed by
the Glass-Steagall Act may also need to be reexamined.

A

proper balance between the safety and soundness of financial
institutions, on the one hand, and the advantages of unfettered
competition, on the other, may entail a different range of
commercial bank activities today than it appeared to permit when
the Glass-Steagall Act was passed in the 193 0 's.

Similarly,

the question of the appropriate mix of activities now applies to
the broader class of institutions that provides bank-like services.

Finally, recent developments also have implications
for monetary policy.

As Chairman Volcker testified on June 25th,

measurement and control of the monetary aggregates is complicated
by the existence of money market mutual funds.




The Board

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believes that legislation would be desirable authorizing the
Federal Reserve to impose reserve requirements on those money
market fund shares that serve as the functional equivalent of
transaction balances, and to enforce a cleaner distinction
between transaction balances and other liquid savings.
addition, we believe,

In

the Federal Reserve should have the

authority to define transactions accounts for purposes of
reserve requirements so as to include the many new types of
plans with transactions capability that may develop.

In concluding,

I would like to emphasize that the

Board of Governors believes that recent developments in the
financial service industry have, on balance,

enhanced

competition despite the other complicated regulatory questions
they raise.

These innovations are a sign of a healthy, dynamic

and innovative financial sector.

To be sure, we need to

monitor developments carefully to ensure that changes such as
the recent conglomerate mergers do not result in the development
of monopolies or monopoly power at some time in the future.
But the principal questions these developments now raise
relate less to the maintenance of competitive markets for
financial services than to the need to provide for a more level
playing field for depository institutions and their competitors,
to maintain appropriate standards of prudence and safety, and
to ensure that the monetary controls of the Federal Reserve are
not undermined.




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Table 1
Bank and T h r i f t Credit Supplied to Nonfinancial Se c t o rs
as a Percentage of Total Borrowing by Nonfinancial
Sectors
( 5 - y e a r averages*)

Commercial Banks

MSBs & S&Ls

1951-55

20.0%

18.8%

0.9%

195 6- 6 0

20.8%

22.1%

1.4%

1961-65

31.4%

23.3%

1.2%

196 6 -70

31.2%

13.1%

1.4%

1971-75

29.5%

18.5%

1.6%

197 6- 8 0

26.9%

15.6%

1.6%

1.

Credit Unions

All data based on annual f l ow s, excluding e q u i t i e s .

Source:

Flow of Funds Data, Federal Reserve Board.

Table 2
Bank and T h r i f t Acquisition of Deposits
From the Household Sec tor as a Percentage
of Total Household Acquis iti on s of Deposits
and Credit Market Instruments
( 5 - y e a r averages*)
Credit Unions

Commercial Banksi.

MSBs & S&Ls

1951-55

32.4%

39.5%

2.4%

1956-60

25.5%

38.6%

2.6%

1961-65

43.3%

38.5%

2.6%

1966-70

43.3%

22.8%

2.6%

1971-75

39.1%

34.3%

3.4%

197 6-80

34.2%

29.6%

3.3%

1.
2.

All data based on annual flows.
Includes demand, savings and time de pos its .

Source:




Flow of Funds Data, Federal Reserve Board.

Table 3
F i v e - Y e a r Averages of Commercial Bank
P r o f i t Data

Years

Ratio of
Net Income
to Total Assets
All Banks
Small Banks

Ratio of
Net Income to
Total Equity Capital
All Banks
Small Banks

1951-55

0.58

8.03

1956-60

0.68

8.50

1961-65

0.72

8.8 0

1966-70

0.78

10.80

1971-75

0. 8 3

0.95

12.36

12.52

1976-80

0.78

1.06

12.56

13.16

1.

Small bank s e r i e s includes a l l FDIC insured banks with a s s e t s
l e s s than $1 00 million and excludes new banks in the y e a r of
t h e i r formation.
Data s e r i e s i s not a v a i l a b l e pr io r to 1970.

Source:




Federal

Reserve Board.




Table 4
Net Income to Average A ss ets
for Thrift Institutions
( 5 - y e a r averages)

S&Lsi

MSBs

1961-1965

0.80

0. 4 5

19 6 6 - 1 9 7 0

0.56

0.30

1971-1975

0.65

0.47

1 97 6- 1 9 8 0

0.61

0.40

1979

0.67

0.47

1980

0.14

-0.10

1.

Data i s f o r FSLIC-insured
S&Ls pr ior to 1976.
All S&Ls
included f o r 1976 and sub­
sequent y e a r s.

So u rce s:

National A ss oc ia ti o n
of Mutual Savings
Banks and Federal Home
Loan Bank Board.