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For release on delivery
1:00 p.m., E.D.T.
June 19,1990
PAYI\,IENT STSIUVÍ RXSK AIVD FTNAI\¡CIAL
RFONU
W. Lee Ffoskins, President
Federal Reserve Bank of Cleveland
New York Association of Business Economists
New York, New York
|une 19,1990
PAYI,ÍH{T SYSTEM RXSK AIVD FINAIVCIAL RETRIVÍ
The gathering movement for financial reform in the United States is creating
controversy. Expanding the powers of commercial banks raises complex questions for
the potential legislative reworking of long-standing regulatory divisions between
commercial banking and investment banking, between banking and insurance,
between domestic and foreign financial instilutiorur, even between banking and
corunerce.
Financial reform, however, carutot be viewed simply as an enlightened attempt to
remove artificial restraints on the rational deployment of private capital across lines of
business. Over the past 60 years depository institutions in the United States have
become the beneficiaries of an expanding federal safety net which in effect has become
a taxpayer-backed substitute for private capital,
liquidity, and contractual
anangements to manage and resolve financial failure. To maintain the safety net as
banks engage in a wider range of lines of business clearly is inconsistent both with the
lessons we are learning from the uruaveling
thrift industry and, more generally, with
growing concerns about federal credit guarantee protrams. Ironically, dependence on
the safety net and regulatory restrictions to protect depositors appeaÌ to have
contributed to low capitalization and the competitive disadvantage of banks in
considering new lines of business.
What I want to talk about today, therefore, is not where to redraw the lines
between banking and other lines of business. Instead I want to talk about the
p¡eegn¿itlon for redrawing those lines. The precondition should be a matching reform
of the federal financial safety net ctrrrently serving as a backstop for the operations of
banks and other depository institutions. Reform
will require clarification of the
objectives of the safety net and how it relates to systemic
risk. I also want to review the
payment system risk problem as an example that illustrates the challenges involved in
meeting the safety net reform precondition for financial reform. The over-riding point
want to stress is that shrinking the existing safeby net, instead of tailoring it to exclude
new lines of business, will make financial reform possible.
I
-2-
Refornr
a¡d the Safety Net
For many economists, contemplating financial reform is synonymous with further
financial deregulation that picks up where elimination of Regulation Q and crumbling
barriers to interstate.banking have left off. Normally, we would expect that removing
further artificial barriers to competition would enhance efficiency, as the allocation of
financial and real resources more fully responds to the play of market signals.
In a free-market economy, property owners, operating within the social fabric of
the law, would be able to use their financial property in whatever way their ingenuily
or lack of it suggests
-
as long as they can expect to enjoy the
profits and suffer the
losses. A market system involves both profits and losses. We lose the power and the
safeguards of the market
if the safety
net intervenes to absorb losses or the risk of losses
and passes them along to the taxpayer. Patching up the system whenever trouble
arises, rather than allowing market arrangements to prevent or cope
with trouble,
skews decisions toward more risk.
Expanding the lines
of
business that banks can enter extends the realm of the
economy underwritten by the federal safety net. Alan Greerupan, in a recent speech,
put the significance of this federal underwriting in clea¡ perspective:
"While the historical data are rdmittedly distorted by a number of factors, it is still
instructive to no-te_that in 1840, the averâge U.S. banf<s' equity-capital-to-total-asset
ratio was around 50 percent.
Such high equiby capital ratios were not the choice of banke
result of marËet pïesiurd to provide comfort to
r to thei¡ side of thè
entive reinforce
'
nstrained, shengthenins the likely
.,Hl,lnfi,{åil;
The dri
to go from a.
set of
statuto:
s
permitte
in
reicent
atios in banking
ent in 1990 is tli'e
;1*:åu "
ted States to
,imply [arel
-3-
I define the safety net to include deposit insurance and access to both the discount
window and Fedwire. Access to the safety net assures that, regardless of managerial
imprudence or exogenous events, deposits are safe, and overnight financing and
intraday financing are assured.
Deposit insurance often is rationalized as a legislative effort to forestall bank runs,
in reaction to experience leading up to the bank holiday in 1933. But, had the Federal
Reserve discount
window and open market operations been managed differently in the
years beFween 7929 and7933, as in October'1,987 for example, those bank ruru probably
would not have happened, and if they had, they would not have produced the tragic
results of that earlier period.
Access to the discount window was designed in 1913 to provide elasticity to the
currency under the gold standard. Today, the Federal Reserve provides elasticity to
base money through open market operations. Adjustment borrowing mostly reflects
Reserve Bank rules made necessary by a subsidy discount rate.
Access to Fedwi¡e, in a formal seru¡e, is not part of the safety net, but it has become
100 percent payment iruurance for Fedwi¡e payments through automatic access
by
banks to free credit during the day. This component of the safefy net originated
inadvertently when telecom¡rrunications irurovations outstrippd the Fed's control of
Reserve Bank credit.
-+
Regardless how the safety net came to be pieced together, the fypical rationale for
maintaining this set of federal programs now is that, by protecting the individual
depositor and the individual bank, they protect society agairut financial panic and
collapse - - against systemic
risk.
Some minimal level of deposit insurance might be
socially convenient just to protect unsophisticated holders of small deposits against
credit risk. The discount window might be a convenient way to handle banks when
they are unexpectedly short of funds at the end of a day, although reliance on the
present penalty rate for overnight overdrafts might do the job just as well. Flowever,
it
would aPPear to be the specter of systemic risk that is the principal rationale for the
current expanded safefy net.
SystemicRisk
The systemic risk rationale is easy to state but diffictrlt to define. The image which
comes to mind is one of widespread failrr¡es of banks, where one bank's failure causes
other banks to fail, and so forth in a widerúng wave of failu¡es reflecting the intricate
interdependence of credit relationships in a modern banking and financial system.
"Failure," however, can have a variety of meanings. It might refer simply to a
delay in making a payment during the dan or perhaps to the premium an illiquid bank
lras to pay in selling illiquid assets to balance its books at the end of a day. On the other
hand, it might refer to the outright supervisory takeover of a troubled bank that lacks
enough capital to satisfy regulatory standards.
A cascade of failures is not the automatic result of the failure of an individual
bank. The systemic problem is more one of gaining time and information for the
resolution of potential losses than of a vast evaporation of capital through actual losses.
-5Exposure of the banking system to systemic risk depends on the prudential
holdings of cash,liquidiry, and capital of each bank. As Chairman Greenspan's words
remind us, systemic risk is created when the safety net is allowed to become a
substitute for capital and liquidiry and cash. Through moral hazard, the safery net
increases the very risk against which the safety net protects, and trarufers exposures
away from private market participants toward the taxpayer.
Another factor underlying systemic risk is the extent to which participants in the
banking and payment systems protect themselves agairut the risk of adverse
developments, by estimating and controlling their susceptibility to potential failures of
their counterparties even when those risks stem from the risk of failu¡e of others. The
myth that exposure to systemic risk can only be controlled by government intervention
is debunked by the extensive private clearinghouse and other private contractual
arrangements that, in the past, seem to have been successful in managing risk
exposures among interdependent counterparties.
In short, systemic risk need not be a catastrophic problem. In the United States, the
safety net has been substituted for private capital and liquidity and cash, making
it
aPPear that systemic risk would be extreme in the absence of the safety net. But, in the
absence of the safety net, rational managers of banks would hold larger cr¡shions
cash and
of
liquidity and capital, raising th¡esholds of payments gridlock and electronic
bank runs and inter-related banking insolvencies. Moreover, private risk-control
measures would be developed and adopted as rational bank managers seek to guard
against systemic risk by taking actions ahead of time that would assure the time and
contractual basis for dealíng with failures in an orderly way.
-6-
Fedwi¡e in the SafetyNet
Access to Fedwire is a useful case study both because it is little understood and
because
it illustrates the challenge of trying to limit the scope of the safety net,s
coverage. Fedwire provides receiver finaliky. This simply means that, upon receipt of a
Fedwire payment message, a bank acquires irrevocable ownership of an equivalent
deposit credit at a Federal Reserve Bank. Receiver finaliry, I would argue, was an
intentional feature of Fedwire, as we now call it, designed in 1918 to be the telegraphic
equivalent of the stage coach in carrying cash balances from one bank to another in
settlement of interbank obligations. This was fine when banlo' reserve bala¡rces were
far larger than daily Fedwi¡e payments. Fedwire simply provided a faster alternative
than physically moving cash or clearing official checks when banks wanted to use thei¡
balances on deposit at Federal Reserve Banks.
Starting about 25 years ago, the Fed began making Fedwire payments regardless of
whether the bank sending the payment had a sufficient balance in its Fed account at the
time it made the transfer. l¡Iow, with Fedwire volume near $1 trillion darly, the Federal
Reserve Banks automatically provide daylight overdrafts with peak values in excess of
$100
billion daily, trusting the overdrawn banta to top-up thei¡ accounts by the time
Fedwire closes and the banking day effectively comes to an end.
Providing daylight overdrafts to fund Fedwi¡e payrnents was an unintended
result. Apparently, the practice began when the Fed and its ctrstomers installed
on-line, real-time telecom¡runications technology, without redesigning procedures to
check each on-line Fedwire payment against the payor banks' deposit balance.
In
effect, we failed to notice that our stage coaches more and more frequently were
delivering our own credit to the paying bank before delivering the cash balance of the
paying bank.
-7-
This safety net feature has assumed growing importance as the fi¡st line of deferue
against failure and systemic
risk. It provides both time and the contrachral
basis for
resolution of potential losses when a bank unexpectedly runs into trouble. The
troubled bank can continue to make payments all day on Fedwire.
lf
the bank can't
balance its books at the end of the day, it is the Fed that is left holding the bag. The Fed
must choose between lending at the window or working with the deposit insurance
system to keep the bank open or to close
it.
The contractual basis for resolving failure
is that the smart money can run from the bank during the day, while the Fed lends to
the bank overnight, eliminating systemic risk.
If
the bank can't suwive, the remaining
uninsured creditors are left to work with the FDIC to determine their losses.
However, there is no reason why every conceivable transaction should be
promised a sameday payment guarantee by the federal government. The withdrawal
of that implicit promise would ctrrtail some transactio¡rs, but more importantly would
encourage private arrangements to reduce risk.
Pa¡rment System Risk Policy
The Federal Rese¡ve has been struggling with this issue and has recently adopted a
policy for dealing with daylight overdrafts. The poliqr is an attractive alternative for
dealing with failure and systemic risk becawe it discourages Fedwire daylight
overdrafts and has led to the development of private contractual arrangements for
dealing with failure.
-8-
Initiall¡
the Board of Governors' payment system risk policy was to reach an
agreement with each bank about the expected upper
limit on its daylight overdraft,
with supervisory remonstration if a bank did not seem to be taking the limit seriously.
Then, a year ago, the Board published for com¡nent a more complete set of proposals,
including a flat penalty fee of 25 basis points per dollar of daylight overdraft in excess
of 10 percent of
a
bank's capital. I should emphasize that this fee is not actuarially
determined and no actual or shadow reserve fund is contemplated. It is simply a
penalty designed to discourage Fedwire daylight overdrafts and encourage private
alternatives for dealing with faift¡¡e.
A more effective way to prevent Fedwire daylight overdrafts would be an outright,
real-time lock on Fedwire making it impossible for a bank to send a payment if that
would create an overdraft, or an overdraft in excess of some limit. We already do this
for certain institutions, including banks known to be in trouble, and there is no reason
it couldn't be done for all Fedwire users.
There is a more important
- indeed, critical - point about the safety net. If federal
supervisors act consistently to prevent large banks from failing, little can be gained by
reducing Fedwire daylight overdrafts. If the federal goverrunent stands ready to
assume the risks involved, there is little incentive for private markets to develop careful
counterparty risk scrutiny and effective loss sharing arrangements.
Shrinking the safety net requires a pervasive understanding that the Fed and FDIC
will not intervene when trouble arises, leaving participants in private payments
arrangements to bear the costs of failure. Supervision of private payments
arrangements to assure effective loss sharing creates the possibility that banks won't
fall into the safety net, and this is the route the Federal Reserve's policy seenìs to be
taking. A more effective way to assure an incentive for meaningful private contractual
arrangements to reduce systemic risk is precommitment by federal supervisors that the
risk of loss will fall on private market participants.
-9-
Private Contractual
Undoubtedly, there is a wide variety of possible private arrangements for dealing
with failure. For these to be effective, they must be based on the requirement that the
private counterparties deal with the problem when cash, or liquidifi, or capital runs
out. Let me mention just a few of the ways in which creating an incentive for private
contractual arrangements might influence the way we deal with payments.
One alternative to Fedwire daylight overdrafts is cash itself. The infallible
contrach¡al way to assure that banks don't fail to make payrrtents during the day is that
they hold enough cash. Several years ago, Governor Angell made a cogent proposal for
inducing banks to hold more cash, including the payment of interest on excess resetves,
but his proposal has not made much headway.
Banks could use the existing stock of cash more effectively during the day.
I think
many people still incorrectly understand this to be "slowing-down the flow of
payments," to avoid daylight overdrafts. Conceptually, that might be possible, but
it
would not be a major factor in avoiding systemic risk in the payments system.
Far more likely -- because examples already are in place
-
are contractual
agreements by wlúch counterparties condense thei¡ hansactions during the day into a
moving net obligation to be paid by one parfy to another at the end of the day. If the
payment can't be made, the transactions are still good, but the damage is limited
because only the smaller net debt of the overextended or failed party must be resolved.
Another avenue
this year
- with an important
-- is for banls to condense
example scheduled to begin in October of
the pay!ßeÅtÊ they make to one another during the
day into a single net settlement payment at the end of the day. In the event of failure,
the participants in the net settlement arrangement cover the failed position of their
troubled counterparty, buying time to work out resolutions of its problems and their
potential losses.
-10_
The example I refer to is clearing House Interbank Payment system (cHlps), the
electronic foreign exchange payments network operated by the New york
Clearinghouse, handling a volume of payments rivaling Fedwire funds transfers. In
October, CHIPS is scheduled to implement an agreement for loss-sharing, with a g4
billion pool of participants' liquid collateral to back that agreement.
The crucial feature of any private ¿urangement must be a contractual agreement
placing risk of loss squarely on the parties to the arrangement. Coruequently,
participants have an incentive to monitor the creditworthiness of their counterparties
and enforce standards that limit the risk being assumed. In addition, some of the
underlying financial market transactio¡rs that now generate payments may no longer be
feasible because private parties
will not be willing
to assume the risks of failure to
which they would be exposed on terms acceptable to the transacting parties.
Condr¡sion
I am encouraged because the payment system risk example demonstrates that it is
feasible to shrink the safety net and therefore meet the precondition for financial
reform. As long as the monetary authorities protect liquidify in the economy as¡ a
whole through appropriate open-market and discount window policies, protection
against failure and systemic risk can be handled by private contractual arrangements,
as demonstrated both historically and in emerging private payments arrangements.
The design of effective private arrangements for containing risk
will evolve from
market ingenuity -- with occasional lapses, of course -- when there is an incentive to do
so. Perhaps the biggest obstacle to shrinking the safety net, and therefore the biggest
obstacle to proceeding with financial reform,
will
be convincing beneficiaries and
custodians of the present safety net that it is in their interests to limit the net and avoid
the temptation to extend it in times of trouble. By removing this obstacle, we should be
in a position where banks can expand their lines of business without putting the
taxpayers at further risk.
@FedFRASER