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INI'ERNATIONAL BANKING
AND THE FED

An address· delivered by Robert P. Mayo,
President of the Federal Reserve Bank of Chicago
at the Annual Meeting of the Mid-Anerica Council
on International Banking, June 30, 1978

It is, indeed, a great pleasure for rre to be here with

you tonight.

In rey professional career in the Midwest that

spans sare fifteen years, I have been intimately involved-first as a banker, and for the past seven years as a public
servant-in praroting the growth of international banking
activities in the area.

Therefore, I feel a great affinity

with people who, like yourselves, have been an integral part
of that rrovernent.
Tonight, I would l.ike to share with you sore of r(¥
thought on ~C!]IUIIIMDI[ Ill ai •• in international banking in

the United States in general, and in the Midwest in particular.
Let ne, if I may, look at the overall picture first,
and start out with some figures to place tlle

banking trends in a perspective.

At

u. s. international

the end of 1977 camercial

banks of the ten major industrial countries had $657.3 billion
in foreign loans and other claims outstanding, an increase of
over $100 billion in a single year.

The U.S. canrcercial banks

have been in the forefront of this expansion.

Their total claims

on foreigners (including the claims booked through their foreign
branches), rose fran $61 billion in 1970 to aoout $347 billion


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at the end of 1977--a five-fold increase in seven years.
We at the Federal Reserve have, of course, watched

this develop:rent with great interest.

Our

response to it

has been a prcxluct of two sets of considerations: On one
hand, we have recognized that the trerrendous increase in the

international activities of U.S. banks was a constructive
response of these institutions to the rising need for credit
globally.

In part, this rising demand for credit was an

extension of a long-tenn trend reflecting rising aspiration
of peoples everywhere for improvements in their standard of
livin,g.

Investrt~.nt--and credit-have ah.,-ays beet---i an integral

part of that process.

But far

IOC>re inp:>rtant in this surge in

dew.and has been the "energy crisis" that surfaced in 1973~74~
The five-fold increase in the price of oil created trerrendous
disequilibria in the world balance of payments.

The huge bal-

ance of payments surpluses accruing to the OPEC countries had
their counterpart in large deficits by the oil-consuming nations.
These deficits had to be financed. if the \\Orld were to survive
the "energy shock. " The c.::ormercial banks around the vJOrld rose
to the challenge of the petrcx:1ollar recycling."
11

In that sense,

they have been perfonning a vital function of sustaining v.0rld's
econanic activities.by helping to finance--directly or indirectly-the oil-related deficits sustained by virtually every nonoil producing nation in the world.

As

an institution charged by Congress

with the responsibility of contributing to the econanic health
of the country, we at the Fed responded. p:::>sitively: Fran this


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perspective, the expansion of U.S. banks' activities abroad has
been viewed by us at the Fed as highly beneficial.
But there has been and.:her side to this coin:

The

tremen-

dous expansion in the foreign lending has considerably altered the
traditional loan/capital ratios of many participating banks, and
opened the banks to new risks.

As

an institution charged with the

responsibility of maintaining soLmdi viable banking industry in the
United States, the Fed, obviously, reacted with concern.

Of particular concern has been the dramatic increase in the
debts of the developing countries.

It has been estimated that the

debt of soire 70 non-OP:EC devalopit7.g countries

$160 billion at the end of last year.

aT■Ow-it:.ed

to s~.e

Of that total, alnost a

half--or sare $78 billion--was owed to private lenders, _pr~ily
cannercial banks in the industrial oountries of the 'vJOrld--an

increase of sare 150 percent since the end of 1973, following the
oil crisis.

Doubts emerged about the ability of ni.any of these

countries to service the debt.

There were fears of defaults, of

"dam.no effects" that could severely undennine the active strucb.lre
of world banking.
The Federal Reserve, in cooperation with the central banks
of other major countries, and with other

u . s. bank regulatory

agencies, took steps to guard,as much as possible against excesses
in the international activities of the U.S. banks that could lead
to such developnents.

In 1976, the Board of Governors of the

Federal Peserve System created a Car.mi.ttee on Foreign LeP..ding consisting of rranbers of the Boa.rd of Governors and of several pres-


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idents of individual Federal ReserVe banks, to study and appraise
the situation, and to reccmnend appropriate measures if need be.

The work of the camdttee has just been carpleted, and the
Federal Reserve, together with the Carptroller of the Currency,
and the FDIC, is

n<:M

in the process of implementing sane of the

measures that appeared desirable ..
One of the fiirst steps has been the effort to obtain, and
to make available to the ccmnercial banks engaged in international
activities, a better and nore corrprehensive data on international
ba.."'1ldng \;"Orld-wida.

We

Ww""lted

to provide the man.aga--nent of these

banks with best available information so that they themselves are

able to make rational decisions in respect to lending. _The fed
has always strongly felt that the exercise of prudence in banking

lies primarily with the management of individual banks.

Thus the

Systan's current efforts to assure the soundness of international
banking activities derive, in the first instance, fran that premise.

Going beyond this, the System is now in process of implerrenting a new supervisory, ba!l.k examination approach that would
incorporate sane precautions against credit over exposure on part
of individual banks in their foreign lending to individual countries.
I will not go into details of this approach.

It will be ccmnunicated

to your banks in due course.
What I wuuld like to anphasize, however, are some broad philosophical principles on which the approach is based.

It is not a

mechanical approach that v.0uld.tell banks where to Lend and where


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not to lend.

It has been fully recognized. that the "country

risk"encarpasses a whole spectrum of factors, eoonanic social,
political, and legal that cannot be analyzec. and evaluated
roochanically.
While sate "objective criteria" such the oountry's current
account imbalance, and the rate of its external debt acCUlllll.ation
will be used to "screen out" countries for in-depth analysis, the
final detennination of the "risk exposure" will be broadly based,
and will include such factors as the degree of ooncentration,
maturity structure--but above all other subjective criteria.
Imking

f:ruhl

a broad per~-c-~va at ti.11e overall posture cf

the Federal Reserve tONard the international activities of U.S.
banks, one may cane to a oonclusion that the p::,sture ha§.. ~ one

of being posed at the sharp edge between the efforts to prarote
the growth of international banking on one hand, and on the other
hand trying to rroderate it.

But

perhaps a very close look may

suggest that the dichotany does not really exist; after all, a
continued expansion of international banking can take place only
if the excesses that may threaten to und.ermi.ne it in the longrun are guarded against.

And that, I believe, is what the Fed

has been trying to achieve in fanning its attitude and policies
toward the international expansion of U.S. banks in general.
In trying to sketch out for you sore of the issues relating
to international banking, I have spoken, so far, as a member of
the nation-wide Federal Reserve System.

Let me

nCM

"switch the

hats," don a hat of the president of a regional Federal Reserve


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bank, and focus briefly on sane of the issues relating to international banking activities in the Seventh Federal Reserve district, and the Midwest in general.
When I came to the .Midwest in 1962 I soon became aware of
the glaring gap between, on one hand, the extensive international
orientation of the business and agriculture in the Mid-West, and
on the other hand, the still rather nodest and timid involvement
of a great majority of the mid-western banks in international
banking.

For e.xarcple, in 1960, when the five Midwest states

that canprise the Seventh Federal Reserve district were exporting
over $3.0 billion L, rranuf~~ed goods

(sane

21 percent of the

national total) and alrrost $800 million (or some 17 percent of
the total) in agricultural products-a total of almost $4 . . 0 billion
of exports originating here--the exp::,rt financing bankerst acceptances--the major financial instrument traditionally used to

finance exports--outstanding at all the district banks arrounted,
at the beginning of that year to--would you believe it--$8.3
million!

Indeed, the total claims on foreigners by all these

banks amounted to $100 million at that time!

By 1970, the

situation improved sanewhat--but not dramatically.

Export-

financing acceptances were still only aoout $42 million even
through the volume of exports originating here expanded to $8 1/2
billion.

But the total claims on foreigners, including those

booked fran

by

these established foreign branches of several

district banks amountel to over $5 billion--a fifty-fold increase

in just 10 years.


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What was particularly significant about this expansion that
took place during the sixties was the fact that it took place under
the severe limitations imposed on the international activities of
the district banks by the Voluntary Foreign Credit Restraint pro-

gram imposed in 1965 for purposes of shoring up the countcy's balance of paynents.

Under that program-which many

of you in this

audience still painfully remember, I am sure--the nation's banks
were confined in their foreign lending activities to the arrounts
that were only a percentage of an early sixties base paricxl.

The

program was particularly painful for the district banks because
it caught then L"1 an ~-pansionar,t phase of their international

activities, and thus with a relatively small base.

Irrleed, the

total claims on foreigners booked at the head offices of...the_
district banks remained virtually frozen at around .p900 million

level between 1964 and 1970; the expansion in foreign lending
that I previously mEmtioned took place aJrnost exclusively at
the foreign branches of these banks.

Incidentally, this develop-

rrent highlights what may be viewed as a "r:ositive" side of the
program.

The VFCR program, pain.&."7.11 as it was for the Midwest

banks in restricting their head-office foreign activities, pro-

vided an impetus for an expansion of the district banks'
activities abroad. Many of the district's banks set up or
expanded their foreign branches and subsidiaries so as to be

able to meet the needs of their custaners for international
banking services without the encumbrance of the program that

made it difficult for them to meet these needs fran their head


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offices.

While in the early sixties, there were no foreign bran-

ches of the district banks, by the end of 1977, the district banks
were maintaining rrore than 70 banking facilities abroad.
Finally, in 1973, a new dircension of international banking
activities in the Midwest emerged.

Foreign banks came to Chicago.

Recognizing finally the long-standing importance of the Midwest
as a heart-land of America's industrial, agricultural-and exportactivities, and recognizing the emerging importance of the Midwest
as an international financial center, the foreign banks t(X)k advantage of the 1973 State Banking Law, and 31 of them opened their
offices here in Chicago.
The changes in the complexion of banking in the Seventh
Federal Reserve district implicit in the figures that I just cited,
brought with them new dirrensions to our functions at the Federal
Reserve Bank of Chicago.

Many of our traditional activities that

we perfonn as a regional banking regulatory authority had to adjust
to these profound changes:

Our

people in the Reserve Analysis

Division of our Bank had to learn to cope with the intricacies of
assessing the legal reserve requirements of EtJ.rodollar transactions
of our member banks; our Bank Examination people had to learn to
evaluate banks' international assets that were unfamilia~--to them;
our Statistical Section had to learn to decifer statistical reports
on our banks' activities in places that they never heard of; and
I could go on, citing examples of the adjustments we had to make in
our responding to the developnents in international ban.1<ing in the
district.


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But in a way, these responses, important as they have been

-9-

in our overall operation, have been only a small part of the pro-

found changes that have taken place at the Federal Reserve Bank
of Chicago.
Our

We have not only responded.

We had to becane initiators.

initiative has evolved essentially on two planes:

One

was "internal" to the Federal Reserve System as a whole, the other
was "external" as it has related to our manber banks.
On t.."1e internal plane, our efforts can i;.ierhaps best be
characterized as efforts to decentralize System's regulatory policy
making processes as they relate to international banking.

For many

years, when U.S. international banking was concentrated a.lnost
exclusively on the Eastern Seabcard, regulations

afftCe/;'t;f

~~

-inter-

national activities of U.S. banks were initiated and pranulgated,
quite logically, by the Federal Reserve District1 in that---region •As the U.S. international banking began to nove to the :Midwest,

we at the Federal Reserve Bank of Chicago felt that we must share
in the internal processes by which regulations affecting international
activities of U.S. banks are developed and prarulgated--so that the
peculiarities of operations of banks in our district in their awn
I

international activities may eventually be given recognition in
structuring the regulation.

For example, we worked hard for the

rocxiification of the Voluntary Foreign Credit Restraint program that
caught our banks at the initial stages of their international expansion)and thus with a very small base to work £ran in their international lending.

We fought for, and invariably obtained repre-

sentation on various special System's canrnittees, both on the staff
level and at the principal level, dealing with various aspects of


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U.S. international banking.

For example, we at the Federal Reserve
. .~
4 d.<:.t l , v

Ban.1<. of Chicago were represented on the System's Task Force on

(./4-~ -f

. L t ' ~ '1t-L-c/ a,,-/-

~

Foreign Operations of U.S. Banks in 1972) I, and sane members of

rqy

s taff were members of the System s Comrru.ttee on Foreign Banks RegI

•

t>
a.-£,,C-

-CG. ,

•

a,,,~~

ti

/2

/

~ 4 ,t_ ,._

~ ~

~ eut,'4L,.t".,

ulation that examined the operations of foreign banks in the United
States and drafted the legislative proposal nCM before Congress; I
1
and members of~ staff have been members of the System's Steering
Ccmnittee on Foreign Lending that, am:>ng other things, is

nCM

in the

process of drafting examination standards for the international
operations of U.S. banks.

These are just few examples of our efforts

within the Federal Reserve System where we have tried to project the
international orientation of our banks into the overall policy making
processes.
On what I have referred to earlier as the 11 external 11 plane
our activity relating to the international orientation of our district has also been quite extensive.

Just to- rrention a few of these,

back in the early 1970, we launched the publication of a weekly
"International Letter" to provide comprehensive, concise sun:mary of
t

significant inter.national econanic developrents to the general public so as to increase their awareness of irnfx:>rtant issues in the
international financial area .

We have devoted a considerable arrount

of resources in exploring the ·possibility of changes in the international payrca1ts-clearing procedures with the ultimate objective
being the breaking up of the virtual "rronopoly" of New York City
in these transactions due to · the peculiarities of the Clearing
House settlements procedures.


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We have been, and we are working

J

-11-

hard in the area of bankers' acceptances.

This area has been viewed

\Its

by;.as being of particular importance because it touches rrost inti-

mately on that bothersane "gap" I mentioned earlier, a gap between
the international orientation of business, ccncterce and agriculture
in our district on one hand/and the supporting financial activities
of our banks.

We published several articles on bankers acceptances

designed to familiarize the general public with that instrument; we
have been supportive of efforts to provide for better and rcore easy
rna.rketing of bankers' acceptances of the district banks--including
the exploration of the possibilities of establishing a market in
bankers ' acceptances in Qricago--so as to make the usage of that
instrument IIDre attractive to the Midwest banks; we are currently

involved in restructuring our internal procedures in handling questions und interpretation of regulations dealing with bankers
acceptances.

We are 'WOrking ta.,.,ard a goal of creating a System--

wide infonnation clearing system whereby interpretation of regulations on bankers' acceptances rendered, say, by the r~ew York Fed
to one of its banks will be made available to all banks, including
those in our district.

I

We expect that this will eliminate the

situations we encountered in the past where banks in sane regions
of the country were issuing eligible bankers acceptances in financing transactions that banks •in other regions of the country believed
would be ineligible, and thus excluded themselves from such financing.

(/I Well, I supfX)se I could go on--but you, I am sure, are
to resune this evenings activities.

by noil

anxious

So let me close my remakrs by

surnmarizing--and enphasizing --the underlying philosophy of all those


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things I talked about tonight:
efforts to

~~d

I want you to Jmav that in your

international banking activities in the Midwest 1

you have friends at the Federal Reserve Bank of Chicago.


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