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For release on delivery
7:30 a.m. EST
March 18, 1993

Remarks of

Susan M. Phillips
Member, Board of Governors of the Federal Reserve System
at the
University of North Carolina's Annual
Chancellor's Seminar on Banking

March 18, 1993
Greensboro, N.C.

I am pleased to have the opportunity to talk with you today.
Although there are a number of things we could talk about, I thought I
would focus on the questions surrounding the alleged "credit crunch."
The availability of credit, and in particular, credit for
small businesses, is a topic of considerable interest to the Federal
Reserve.

Bank loans have been essentially flat for the past two

years, and there has been a substantial decline in the share of total
credit that comes through the banking sector.
troublesome.

This trend is

Many have cited this decline as an indication that there

is a "credit crunch."

To most of us the term "credit crunch" conveys

the sense that creditworthy borrowers find it unusually difficult, if
not impossible, to obtain credit at reasonable cost.

In the past,

credit crunches have typically been associated with periods of high
interest rates, monetary restraint and disintermediation.

But today

we are more likely to hear of tight credit standards, risk-based
capital requirements, and overly cautious regulators as the underlying
causes.
To shed light on whether there is indeed a credit crunch, and
whether policy prescriptions are needed, we need to disentangle the
various supply and demand factors that have interacted to produce the
recent weakness in bank lending.
My remarks today will focus on the three factors that I think
are the most important.

The first is the demand for credit by

businesses and households; the second is private lenders' efforts to
rebuild balance sheets and strengthen capital; the third is bank
regulation--both risk-based capital requirements and the examination
process.

These factors are clearly interrelated, but it may be

helpful to distinguish among them because each has different policy
implications.
Let me begin by noting that a number of positive signs have
begun to emerge in the banking sector.

Bank lending, after declining

through last summer, turned up a bit in the fall, although we have yet
to see sustained growth in business lending.

Bank capital positions

are stronger than they have been for many years, boosted by record
bank profits and new capital.

From a liquidity standpoint, banks

appear to be in a good position to increase lending given the
substantial amount of government securities that they hold.

We should

see more strength in bank lending, and in other types of credit, as
economic activity continues to pick up.
With that background, let me turn now to the credit crunch
and the demand for bank loans and credit more generally.

I believe

that weak demand for credit goes a long way toward explaining the slow
growth of bank loans and broader measures of debt in the 1990's.
Growth in credit demand has been blunted by the relatively slow pace
of the recovery.

Many factors have contributed to the weakness of the

recovery-- cuts in defense spending following the end of the cold war,
the restructuring of many large U.S. firms in response to increased
global competition, and large declines in commercial real estate
values following the overbuilding of the 1980s.

In short, coming out

of the decade of the 1980's there are substantial structural
impediments to growth and it will take time for the economy to work
off these imbalances.

I would cite commercial real estate as an area

that is likely to recuperate slowly.
The other factor limiting the demand for credit generally has
been the substantial effort of businesses and households to reduce the
debt burdens that they accumulated in the 1980s.

By 1990 household

debt

s e r v i c e o b l i g a t i o n s a m o u n t e d to m o r e t h a n 18 p e r c e n t

disposable personal income,
h i s t o r i c a l high in

1980.

2 percentage points above their previous

Similarly,

c o r p o r a t i o n s a m o u n t e d to almost
another

record.

interest

rates, but t h e y also

they had

40 percent

stabilized

p a y m e n t s by

of cash flow in 1990-reflected high

resulted f r o m large i n c r e a s e s

support h i g h e r

real e s t a t e p r i c e s
and h o u s e h o l d s

gross i n t e r e s t

In part t h e s e h e a v y debt b u r d e n s

fund m e r g e r s and

of

real e s t a t e p r i c e s in the

in debt to

1980s.

When

and, in some cases, d e c l i n e d , m a n y firms

found t h e m s e l v e s w i t h h i g h e r l e v e l s of l e v e r a g e than

intended.

Then,

slower g r o w t h in asset

in a d d i t i o n ,

for firms, w e a k sales and

prices increased

e x p o s u r e to h e a v y debt

payments.
Over t h e past two y e a r s , b o t h f i r m s and h o u s e h o l d s h a v e
sought to r e d u c e t h e i r debt b u r d e n s .
by the l a r g e d e c l i n e in i n t e r e s t

T h e i r e f f o r t s h a v e b e e n helped

rates over this p e r i o d .

have issued n e w lower - interest b o n d s and
in m a n y

last y e a r .

retirement

decline

factor

and

amounts,

repay b a n k l o a n s .

and

These

s l o w i n g b u s i n e s s loan growth

Indeed, a r e v i e w of p r o s p e c t u s e s by a U . S .

r e v e a l e d that debt
the

equity in record

cases the p r o c e e d s have b e e n used to

repayments probably were a major

L a r g e firms

investment bank

equity issues, h a v i n g as t h e i r p r i m a r y p u r p o s e

of b a n k debt, w e r e c o n s i d e r a b l y in e x c e s s of t h e

in b u s i n e s s loans at b a n k s in 1992.
H o u s e h o l d s h a v e used

to pay down h i g h - i n t e r e s t

low-yield

assets,

debts--contributing,

w e a k n e s s in the m o n e t a r y a g g r e g a t e s .

such as b a n k d e p o s i t s ,
i n c i d e n t a l l y , to the

Although household

debt b u r d e n s

in t e r m s of d i s p o s a b l e income

remain f a i r l y h i g h by h i s t o r i c a l

standards, they have declined

somewhat

recently.

M o r e o v e r , t h e recent

growth in c o n s u m p t i o n s p e n d i n g and i n d i c a t o r s of c o n s u m e r s e n t i m e n t

suggest that households may be more comfortable with current debt
levels.
Turning to the other side of the supply-demand equation, it
also appears that tighter supply conditions have contributed to the
weakness in bank credit.

Spreads between bank loan rates and money

market rates increased by a percentage point or more in 1990 and 1991,
and they have remained elevated since.

In addition, banks appear to

have imposed tighter non-price terms on loans and tougher underwriting
standards.

The results of the Board's quarterly survey of senior loan

officers at large banks suggest that non-price terms on commercial and
industrial loans tightened appreciably in 1990 and 1991.

The

tightening of terms included reducing the sizes of credit lines,
increasing commitment fees, requiring more collateral, and increasing
the use of loan covenants.

For the same period, the senior loan

officers also reported that they tightened the standards for approving
loan applications.

However, since late 1991 or early 1992, the senior

loan officers have reported little change in either terms or standards
for commercial and industrial lending.
In a traditional crunch, the bank lending mechanism breaks
down--either because of disintermediation or, as in 1980, because of
direct controls on the quantity of lending.

In the most recent

recession and recovery, there was no dramatic or obvious breakdown,
but rather a persistent, but hard to locate, slowdown.
credit from other sources has also slowed.

The flow of

For example, while bank

consumer installment lending fell by about 6-1/2 percent between 1990
and last fall, finance company consumer installment lending fell by
nearly twice as much.
also down.

Installment credit from all other sources was

Similarly, business loan growth at banks has been weak,

but so has business loan growth at finance companies.

This general

w e a k n e s s in s h o r t - t e r m credit
been weak.

s u g g e s t s that

o v e r a l l credit d e m a n d has

Or if s u p p l i e r s of credit h a v e t i g h t e n e d , t h e

retrenchment

has not b e e n l i m i t e d to b a n k s .
It is not hard to t h i n k of r e a s o n s w h y l e n d e r s m i g h t h a v e
c h o s e n to t i g h t e n u n d e r w r i t i n g s t a n d a r d s .
lenders to be m o r e

consequent

Second, m a n y l e n d e r s - - a n d

result

expect

c a r e f u l s i m p l y b e c a u s e of the s t a t e of t h e

m a c r o e c o n o m y , and the

c o m p a n i e s , and

F i r s t , one w o u l d

not

d e c l i n e s in c o l l a t e r a l v a l u e s .

just b a n k s , but also t h r i f t s ,

i n s u r a n c e c o m p a n i e s --have s u s t a i n e d

of o v e r - a g g r e s s i v e

l e n d i n g in the

levels of d e l i n q u e n c i e s and

charge-offs

1980's.

l a r g e l o s s e s as a
G i v e n the v e r y h i g h

in recent y e a r s , it w o u l d be

a s t o n i s h i n g if t h e s e i n s t i t u t i o n s did not
p r o c e d u r e s to avoid

alter t h e i r p r a c t i c e s and

s i m i l a r l o s s e s in the f u t u r e .

r e a c t i o n to i n c r e a s e d

finance

This n a t u r a l

loan losses may h a v e b e e n r e i n f o r c e d by

regulatory pressures.

played?

What

role h a v e b a n k i n g r e g u l a t i o n s and c a p i t a l

With

regard to c a p i t a l

the B a s l e r i s k - b a s e d
activity.

I do not b e l i e v e that

standards have been a major

The e v i d e n c e s i m p l y does not

most b a n k s the

constraint

on b a n k

support t h i s v i e w .

First,

s t a n d a r d s h a v e not b e e n b i n d i n g c o n s t r a i n t s ,

p a r t i c u l a r l y c l o s e to b i n d i n g .
the

requirements,

requirements

or even

In D e c e m b e r of 1990, p r e s u m a b l y w h e n

"capital c r u n c h " was in full swing, m o r e t h a n 95 p e r c e n t

b a n k s a l r e a d y met

the fully p h a s e d - i n

standards.

Moreover,

t h i r d s of b a n k a s s e t s w e r e held by b a n k s that b o t h met the
s t a n d a r d s and w e r e h i g h l y

for

of U . S .
about two

capital

rated by t h e i r e x a m i n e r s .

The B a s l e s t a n d a r d s , w h i l e p e r h a p s c o n t r i b u t i n g , are not the
most

important

ratios.

factor m o t i v a t i n g b a n k s to i n c r e a s e t h e i r c a p i t a l

Indeed, the b a n k s ' own e x p e r i e n c e s w i t h l a r g e loan l o s s e s and

p o r t f o l i o p r o b l e m s l i k e l y h a v e p r o m p t e d m a n y to

reassess their

appropriate levels of capital.

Moreover, banks recognize that there

are substantial market incentives for having higher capital.

In late

1990 and early 1991, some money center banks had to pay spreads of
more than 5 percentage points over Treasuries to issue subordinated
debt.

At the same time, the top 50 banking institutions' stock was

selling at an average discount to book value of 15 percent.

Clearly,

financial markets believed that these institutions were poorly
capitalized.

More recently, the improved capital positions of the

largest banks have contributed to the reduction in spreads on their
subordinated debt to less than 2 percent over Treasuries, and the
stock prices of the 50 largest banks are now more than 70 percent
above book value.
Risk-based capital standards would be expected to encourage
some banks to cut back on higher-risk loans and purchase more
government securities.

Indeed, the fraction of bank portfolios

invested in government securities has increased sharply.

But by

historical standards securities are still a modest fraction of bank
assets.

Granted times are different, but securities were more than

half of bank credit in the late 1950s.

Even as late as the mid-1970s

banks had about 30 percent of their portfolios invested in securities-much as they do today.
In any case, the increase in securities holdings does not
appear to be the result of the risk-based capital standards.

Some

evidence for this claim comes from observing the behavior of
institutions not constrained by capital standards.

For example,

consider banks with the strongest capitalization, say banks in the
well-capitalized zone under FDICIA that are also in the top 1 or 2
bank rating categories.

These banks cannot credibly be said to be

constrained by the risk-based standards.

As one would expect, these

institutions are the ones with the most rapid asset growth, yet the
bulk of that growth is coming from increased holdings of government
securities.
In addition, credit unions also tend to be quite well
capitalized, and indeed are not subject to. the risk-based capital
standards.

Nonetheless, loans by credit unions decreased from 66

percent of assets to 53 percent over the past few years, while the
share of government and agency securities has doubled.

These shifts

are somewhat larger than for banks, occurring at about the same
time--and they cannot be attributed to risk-based capital standards.
Evidently, the increase in bank securities investments by
well - capitalized banks and credit unions is the result of other
factors.

I have already pointed to weak credit demand and the

tightening of underwriting standards in response to increased loan
losses as possible explanations.

In addition, the steepness of the

yield curve may increase the appeal of some government securities.

As

an aside, however, it is worth noting that securities profits have not
contributed as much as one might have thought to bank profits.

In

1992 bank profits on securities were less than 15 percent of total
profits.
Should we conclude from all of this that the risk-based
capital standards have had no effect?

I hope not.

One of the goals

of the risk-based capital standards was to reduce the bias toward
risky investments caused by government deposit insurance and a single
capital standard.

This important objective contributes to the safety

and soundness of the banking system and reduces exposure to taxpayers.
Thus far I have focused almost exclusively on capital
standards.

What about other aspects of the regulatory process?

We

have heard that banks are skittish about making loans that might be

viewed as risky by the examiners or that cannot be documented
adequately.

The fact that banks have raised lending standards and

tightened credit terms in the past few years cannot be disputed.
I suspect that this increased caution has received additional
impetus from the supervisory process.

Examiners have become acutely

aware of the impact that asset quality can have on individual
institutions and on the banking system.

Although the Fed and other

agencies have sought to discourage examiners from overreacting to past
problems, it is natural human instinct to be more circumspect.

And if

bankers expect regulators to be more critical, they are likely to be
more conservative in their decision-making and record-keeping.

One

product of this process has been an increased trend toward greater
documentation which increases the cost of loans.

Recently enacted

laws, including FDICIA, have added to this trend. The merits of this
legislation can be debated, but it appears to have encouraged banks
and examiners to err on the side of caution in the lending process.
These tighter standards, whether prompted by bank or
regulator concerns or new laws, impose a cost on all borrowers but may
be especially burdensome for smaller businesses.

For example, many

small business loans are collateralized by real estate.

Any loan with

real estate collateral over $100,000 must contain an appraisal by a
licensed or certified appraiser.

This requirement was singled out by

respondents in the Fed's survey of senior loan officers at large banks
as a specific regulation that especially hurt small businesses.
The Federal Reserve and other regulatory agencies have been
working to identify statutory or regulatory requirements that may have
disproportionately affected small businesses and were not essential to
sound banking.

As you may be aware, the President announced last week

the preliminary results of this interagency effort.

The details of

- 9 -

the i n t e n d e d r e g u l a t o r y c h a n g e s r e m a i n to be w o r k e d
interagency

effort

out.

reflects the longstanding interest

R e s e r v e in r e d u c i n g the

This

of the F e d e r a l

r e g u l a t o r y b u r d e n on h e a l t h y b a n k s and

e n c o u r a g i n g l e n d i n g to c r e d i t w o r t h y small and m e d i u m - s i z e d
I b e l i e v e that two of the a n n o u n c e d
important.

First,

businesses.

c h a n g e s are p a r t i c u l a r l y

in order to r e d u c e the d o c u m e n t a t i o n b u r d e n on

small loans, the a g e n c i e s w i l l a l l o w strong and w e l l - m a n a g e d b a n k s and
t h r i f t s to carry a p o r t f o l i o

of c r e d i t w o r t h y small and m e d i u m - s i z e d

b u s i n e s s loans w i t h m i n i m a l d o c u m e n t a t i o n r e q u i r e m e n t s .
individual

loans i n c l u d e d

the o v e r a l l

done w i t h o u t
decision.

in this p o r t f o l i o w i l l be l i m i t e d ,

size of the p o r t f o l i o .

to a t t e m p t to ease the

rules

r e q u i r i n g a p p r a i s a l s w h e r e t h i s can be

of the loan size t h r e s h o l d

I b e l i e v e that t h e s e changes should h e l p

the f l o w of credit to

for

increase

small and m e d i u m - s i z e d b u s i n e s s e s .

In sum, c o n s i d e r a b l e
q u e s t i o n of a v a i l a b i l i t y .
credit

s o u n d n e s s of the credit

includes a reassessment

formal appraisals.

as w i l l

Second, the a g e n c i e s h a v e agreed

a f f e c t i n g the safety and

This

The size of

a t t e n t i o n is b e i n g d i r e c t e d to the

I t h i n k that to e x p l a i n the w e a k n e s s in

g r o w t h over the past two or t h r e e y e a r s , h o w e v e r , we need not

look m u c h b e y o n d the state of the e c o n o m y and e f f o r t s by b o t h
b o r r o w e r s and l e n d e r s to rebuild b a l a n c e sheets and
of the p r e v i o u s d e c a d e .

I would

i m p o s i t i o n of r i s k - b a s e d c a p i t a l

redress imbalances

a t t r i b u t e far less i m p o r t a n c e to the
s t a n d a r d s , w h i c h for t h e vast

m a j o r i t y of i n s t i t u t i o n s w e r e not

constraining.

Other a s p e c t s of the

s u p e r v i s o r y p r o c e s s are m o r e d i f f i c u l t to d i s e n t a n g l e .
e x a m i n e r s l i k e l y h a v e r e i n f o r c e d t h o s e of b a n k s ,
tougher lending

standards.

discourage overzealous

C o n c e r n s of

c o n t r i b u t i n g to

A l t h o u g h we have b e e n c a r e f u l to

regulation,

s c r u t i n y of f i n a n c i a l i n s t i t u t i o n s

by the p u b l i c , the C o n g r e s s , and the a g e n c i e s has l i k e l y created

an

-10-

environment more conducive to tighter standards and documentation
requirements.

The changes announced by the President show that the

supervisory agencies are aware of these difficulties.
What about the future?

I expect lenders will pursue more

Cautious policies than we saw in the preceding decade, but that their
willingness to lend will increase as the economy improves, regulatory
costs are reduced, and imbalances are worked off.

I think we are

seeing some evidence of progress at banks and among businesses and
households.
Finally, I would stress the important role that small
businesses play in our economy.

Although the Federal Reserve and

other agencies are acting to reduce the costs of small business loans,
we need to learn much more about the diverse credit needs of this
sector.

In order to improve our understanding in this area, the

Federal Reserve will be conducting a survey this year of small
businesses and will ask about the full range of their credit sources,
not just banks.

This survey should provide useful insights into

potential bottlenecks in the flow of credit to small businesses.
insights can assist in the development of appropriate policy
prescriptions.
Thank you.

Such