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A Series of Occasional Papers in Draft Form Prepared by Members^

DEPOSIT STRATEGIES FOR MINIMIZING THE INTEREST
RATE RISK EXPOSURE OF S&Ls




Harvey Rosenblum
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82-1

Deposit Strategies for Minimizing the Interest
Rate Risk Exposure of S&Ls

Harvey Rosenblum*
Vice President and Economic Advisor
Federal Reserve Bank of Chicago

A Paper Presented at
Federal Home Loan Bank of San Francisco
Seventh Annual Conference
Managing Interest Rate Risk in the Thrift Industry
December 10-11, 1981

*The views expressed in this paper are the author’s and do not
necessarily represent the views of the Federal Reserve Bank of Chicago. I
would like to thank Robert Laurent, Philip Cummins, and Evelyn Carroll for
their comments on an earlier draft. Special thanks go to George G. Kaufman
for his intellectual motivation that provided the impetus for this paper.




Deposit Strategies for Minimizing the
Interest Rate Risk Exposure of S&Ls*

In recent years, the problems of thrift institutions have gained
widespread recognition.

These liquidity and solvency problems stem from a

maturity and interest rate imbalance, in part forced upon thrift
institutions by a variety of government regulations, tax incentives, and
subsidies.

This array of government rules has encouraged thrifts to be

heavily invested in long-term fixed rate assets that are funded with
short-term (and therefore variable rate) liabilities.

Most of the proposed

solutions to the maturity imbalance and cash flow problems have focused on
the asset side of the balance sheet and would shorten the effective
maturity of S&L assets by allowing consumer or business loans or by
encouraging adjustable rate mortgages.
These asset-side solutions are not likely to help significantly in the
short run.

The principle of adverse selection is likely to prevail if S&Ls

attempt to penetrate saturated markets, such as consumer and business
lending, in which industry personnel have little existing expertise.
Adjustable rate mortgages (ARMs) will help somewhat because they pass some
portion of the interest rate risk from the lender to the borrower.
However, the borrower may not be in a position to bear this risk.
Consequently, if rates are sufficiently volatile and the particular ARM
design does not insulate the borrowers' monthly payments from interest rate
movements, it is possible that the borrowers' interest rate risk will be

*The views expressed in this paper are solely those of the author and
do not necessarily represent the views of the Federal Reserve Bank of
Chicago or the Federal Reserve System.




2

translated into credit risk which will, in turn, be shifted back to the
lender.
Promising solutions to the maturity and interest rate imbalances and
the cash flow problems stemming from the inventory of old, low interest
rate mortgages can also be found on the liability side of the balance
sheet.

These solutions rely upon the traditional deposit-taking function

of S&Ls and on the existing knowledge base and marketing expertise of
incumbent personnel.

Moreover, the federal government and its regulatory

agencies are not involved except in an insurance company capacity.

The

liability side solutions allow (and indeed require) that S&Ls tailor their
deposit products to suit the needs of their local market customers.

A

complete solution to the thrift institution problem requires both asset and
liability adjustments; this paper emphasizes those adjustments that can be
made on the liability side.
AN OVERVIEW OF LIABILITY STRATEGIES
The essence of the liability strategy is that an S&L can insulate
itself against changes in interest rates by closing the excessively large
maturity gap that presently exists between its assets and its liabilities.
To do this requires marketing deposits with a maturity that is several
times that of the deposits most commonly sold in 1981.
Successful Deposit Design Requirements
In the aftermath of the introduction of Money Market Certificates
(MMCs) in June 1978, it has become clear that the one thing depositors want
most is a market rate of return.

Further, not all depositors desire

liquidity; if they did, money market mutual funds (MMFs) would have made
even greater inroads than they have.

The popularity of small saver

certificates suggests that depositors are willing to lengthen maturity when




3

return is adequate; further, many of these depositors are willing to have
their interest compound and do not require that it be withdrawn at
intervals —
maturity.

regular

in effect, there is no cash outflow until the deposit reaches

Thus a variety of deposit instruments can probably be designed

that would have the interest rate and liquidity properties desired by
depositors and that would, at the same time, allow an S&L to materially
increase the weighted average maturity of its liabilities.

Moreover, if

the cash outflows associated with these deposits can be deferred for a
considerable period of time, the likelihood of survival improves
considerably for those institutions with a large proportion of old, low
rate mortgages.*
Deposit Design Problems
There are four minor drawbacks to the liability side solution.

First,

S&Ls have little expertise in pricing deposits; in the past they merely
offered the limited array of deposits permitted by Regulation Q, generally
at the ceiling rate.

Innovative marketing involved toasters, smiling

tellers, stuffed animals, and attractive, convenient office locations.

The

phase-out of deposit interest ceilings required by the Depository
Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) opens
up a new world of pricing and marketing flexibility.

In spite of

complaints about the phase-out of Regulation Q from some segments of the
S&L industry, DIDMCA has given S&Ls an opportunity to compete for the types
of deposits they need to reduce their inherent riskiness in a world of rate
volatility.
A second problem arises in that, at least on the surface, the pricing
flexibility afforded by the phase-out of Q-ceilings may prove to be an
expensive opportunity.




Further, given the average return on assets of an

4

S&L carrying a large inventory of old, low rate mortgages, it would be
undersirable to insulate against changes in interest rates given the rates
that prevailed on deposits during 1981.

Indeed, one would then be locking

in a negative spread; the only benefit of such a strategy is that the
number of months until liquidation could be calculated precisely.
A third problem is that the phase-out of Q-ceilings is proceeding very
slowly and in fits and starts —

the opportunity afforded by flexibility in

deposit pricing and design is thus far an illusion and not a reality.

But

DIDMCA requires that deregulation of deposit interest rate ceilings will
become a reality; if they are to survive, S&Ls must learn how to turn this
fact of life to their advantage.

Fourth, and this is the only potentially

serious drawback, the public may not want the kind of deposit designs that
S&Ls need to close the maturity and cash flow imbalances inherent in their
current balance sheets.
THE THEORY AND APPLICATION OF IMMUNIZATION
Before turning to the details of new deposit designs, it is necessary
to discuss the theory on which they are based.

In their 1979 paper,

Professors Bierwag, Kaufman, and Toevs introduced the theoretical model
upon which this paper is based.

2

The two concepts that are crucial for

understanding interest rate risk are immunization and duration.
Immunization involves the elimination of interest rate risk by
selecting a portfolio of assets whose maturity and cash inflows match the
timing and dollar magnitude of liabilities that need to be discharged.
When an institution is immunized, changes in interest rates (in either
direction) have no impact upon the institution’s net worth.

This occurs

when the durations of assets and liabilities are equal; only in one polar
case would immunization occur when asset and liability maturities are




5

equal.

Duration is a measure that takes into account not only the maturity

of a security but the timing of the cash flows associated with it; duration
measures the average time at which all payments are made.
It is best to illustrate these concepts by way of a very simple
example.

Suppose one needs to have on hand a certain amount of money to

discharge a known contractual outflow at some future date.

Naturally, one

would wish to invest the funds currently on hand so as to have at least
enough to meet the outflow when it falls due.
someone $10,000 payable in six months.

For example, suppose you owe

One way to satisfy this obligation

would be to purchase a six-month Treasury bill with a maturity value of
$10,000.

Regardless of current market interest rates, you would know

exactly how much to invest in order to meet your obligation.

The solution

is greatly simplified by the existence of a debt instrument that first, can
be purchased having the same maturity as one’s future liability, and
second, can be purchased as a discount note, that is, with no coupons that
require reinvestment.
To be more realistic, it is necessary to complicate the problem.
Suppose that you owe someone $1 million due five years from today.

The

solution to the problem of how much to invest today, no more and no less,
to have that amount on hand in five years would be very simple if you could
purchase a five-year, default-free, discount note.

At the present time

securities having all three of these properties do not exist.
Other investment strategies must be utilized because of the absence of
default-free, zero-coupon securities of the right maturity.
other investment strategies may be pursued.
is a possibility.

At least three

First, the rollover strategy

Under the rollover strategy, one might choose to invest

in one-month CDs, rolling over the investment 59 times (or in three-month




6

commercial paper rolling over the investment 19 times, or in one-year bonds
rolling over the investment four times, etc.)*

Under this strategy, the

investor would be "flying blind" and would not know what sum to place in
the initial investment because the interest return for all but the first
investment period would be unknown.

One could infer the interest rate

during each future reinvestment period from the yield curve; however, based
on past experience the short-term forward rates embedded in the yield curve
would be realized only under fortuitous circumstances.

Under the rollover

strategy, all the risk is reinvestment risk (abstracting from default
possibilities).
As another alternative, one could follow a maturity strategy by buying
a five-year bond with a known value at maturity (again assuming no default
risk).

However, the return from investing the coupon income is not known

and some element of reinvestment risk remains; however, there is no price
risk under the maturity strategy since the bond's final value will be paid
at maturity.
The last possibility involves buying a bond with maturity longer than
the holding period, which has sometimes been called the naive strategy.
For example, one might purchase a bond with a ten-year maturity, planning
to sell it after five years.

But this strategy produces both price risk

and reinvestment risk because the price at which the bond will be sold at
the end of the holding period is unknown, as are the interest rates at
which the coupon income can be reinvested.

However, the price risk and

reinvestment risk are of opposite sign; an increase in interest rates will
lower the price of the bond but increase the coupon reinvestment return.
It turns out that there is a special case of the naive investment
strategy for which the price risk and the reinvestment risk are equal but




7

of opposite sign so that they cancel one another.

This strategy has come

to be known as the immunization strategy because it immunizes the investor
against changes in interest rates.
should be noted.

The limited meaning of immunization

Under this strategy, the investor should realize the

(before-tax) promised rate of return or yield to maturity, no more and no
less.

The investor eliminates the downside risk of loss of capital

stemming from increases in interest rates but foregoes any profitable
opportunities from changes in interest rates.

The immunization strategy is

equivalent to buying a zero-coupon bond with maturity equal to the holding
period— the investor knows exactly how much to invest so as to have the
needed amount on hand to discharge the future obligation.

(The first

example, which involved the purchase of a six-month Treasury bill, was an
immunization strategy.)

That is, the promised return will equal the

realized return regardless of the change in interest rates that takes place
following onefs investment.

For the other strategies, the promised and

realized returns will be equal only fortuitously.
Because zero-coupon bonds are not widely available, immunization must
be achieved in a round-about manner and will occur when the duration of the
investment is equal to the holding period.

Duration is a measure of the

average life of an income stream, measured in units of time, where each
payment is weighted by its present value.
duration (D) is:




The formula commonly given for

(1) D =

where

ftd + r)1
n
Ct
E - (l+r)t
t=l

Ct * interest and/or principal payment at
time t
(t) = length of time to the interest and/or
principal payments
n * length of time to final maturity
r * yield to maturity

The denominator is the present value of the interest and principal payments
while the numerator is the present value of the payments stream where each
payment is weighted by the time at which the payment is expected to be
received.

It follows that a discount (or zero-coupon) note, with only a

final payment, has a duration equal to its maturity.

For all coupon bonds,

duration is less than maturity and is shorter, the higher is the coupon
(since the large early payments are weighted more heavily than the later
payments).
Duration has other noteworthy properties.

First, it may be used as an

index of the variability of the price of a bond in response to a change in
interest rates, with price variability being directly proportional to a
3
bond's duration.

For small changes in interest rates (dr), the percentage

change in bond price (dP/P) is a function of duration (D) and is
approximated by:




9

Another property of duration is that, as a measure of the average maturity
of an income stream, it is an index number, and, as with most index
numbers, more than one may be calculated.

Different measures of duration

have been derived depending on the assumed stochastic process that governs
changes in interest rates.

The most common measure of duration, that

originally stated by Macaulay in 1938 and given above in equation (1), will
provide immunization if the yield curve is horizontal and shifts in a
parallel or additive fashion.

Fisher and Weil showed that bond portfolios

could be immunized— that is, the realized yield would be no less than the
4
promised yield— using Macaulay’s duration.

For complete immunization— or

using the terminology introduced by Bierwag, Kaufman, and Toevs, strong
form immunization— it is necessary to correctly specify the stochastic
process so that the correct measure of duration can be determined.

If the

stochastic nature of interest rates is not properly specified, only partial
(or weak form) immunization is possible.^

This may be particularly

important for S&Ls because assets and liabilities may respond to different
stochastic processes.
LONG DURATION LIABILITIES:

BALANCE SHEET CONSTRAINTS ON DEPOSIT DESIGN

One of the necessary conditions for a financial intermediary to
immunize itself against the adverse consequences of volatile interest rates
is that its planning horizon be known with certainty.

For this condition

to obtain, it is necessary that the duration of the institution’s
liabilities be known exactly.

Because a significant portion of the

liabilities are payable, de facto, on demand, this condition is not likely
to be satisfied.

Nevertheless, to the extent that deposit withdrawals

and/or mortgage prepayments do not occur in a completely randbm manner but
instead exhibit statistically quantifiable and predictable behavior, the




10

Table 1
Balance Sheet Composition of a Representative S&L, 1979

Percent
of Assets

Assets

Mortgages
Liquidity Portfolio
Fixed, Long-term Assets
Other Assets

82
7
3
8

Weighted average asset duration:

Liabilities

Savings Accounts
Passbook
Certificates
MMCs
Others of less
than $100,000
Jumbo Certificates
FHLB Advances
Net Worth
Other Liabilities

Percent of
Liabilities




5.0
0.5
10.0
(a) one day
(b) 40.0 ye;
(a) 4.435 years
(b) 7.635 years

Duration
(years)

21

.05

18

.40

34
4
7
6
10

Weighted average liability duration:

SOURCE:

Duration
(years)

2.50
.10
.50
5.00
(a) one day
(b) 20 years
(a) 1.276 years
(b) 3.276 years

United States League of Savings Associations, Savings and Loan Fact
Book 1980, Tables 47 and 71. The durations of assets and liabilities
are the author’s estimates.

11

duration of an intermediary’s assets and liabilities can be approximated
fairly closely.

Moreover, the extent of immunization which is possible is

directly proportional to the absolute difference between the immunizing
duration of an institution’s assets and liabilities.

Thus, if an

institution can closely estimate the duration of either its assets or its
liabilities, its ability to achieve or approximate an immunized position
depends upon its ability to choose a mix of assets whose duration is equal
to that of its liabilities (or vice versa).
Assume that the average S&L has a balance sheet composition similar to
that for the S&L industry as shown in Table 1.

With 82 percent of assets

invested in long-term mortgage loans and about 39 percent of liabilities
due in less than six months, this representative S&L obviously can be
buffeted about by changing rates because its deposit liabilities are
subject to repricing more often than its assets.

Making reasonable

assumptions about the durations or effective maturities of the various
balance sheet components suggests a duration imbalance of at least 3.2
years.
Table 2 shows one possible reconfiguration of the balance sheet that
would significantly reduce the interest rate risk exposure of our
representative S&L.

The duration imbalance has been reduced by decreasing

the reliance on short-term deposits and increasing the percentage of
long-term certificates.

If an S&L could offer a long-duration deposit like

a ten-year discount note and if this deposit instrument were to gain
acceptance in a competitive marketplace, then the S&L could substantially
increase the duration of its liabilities, particularly if passbook savings
and MMCs are the deposit categories that were shifted into the
long-duration deposit.




12

Table 2
Hypothetical Redistribution of S&L Assets and Liabilities

Assets

Mortgages
Consumer Loans
Liquidity Portfolio
Fixed Assets
Other Assets
Weighted average asset duration:

Liabilities

Savings Accounts
Passbook (25%)
Certificates (72%)
less than one year (15%)
1-2 years (10%)
2-4 years (10%)
greater than 4 years (37%)*
Other (3%)
FHLB Advances
Net Worth
Other Liabilities

Percent
of Assets

65
20
7
3
5

Duration
(years)
5.0
1.5
0.5
10.0
one day

3.885 years

Percent
of Liabilities

82

6
6
6

Duration
(years)
2.37
0.05
0.3
0.9
1.5
5.6
0.1
0.5
5.0
(a) one day
(b) 20 years

Weighted average liability duration: (a) 2.57 years
(b) 3.87 years
*Certificates composed as follows: 40 percent in 6-year, zero-coupon
certificates; 30 percent in 8-year zero-coupon certificates; 20 percent in
10-year, zero-coupon certificates; and 10 percent in 12-year, zero-coupon
certificates.




13

In Table 2 it is assumed that passbook accounts comprise 25 percent of
savings accounts and that certificates due in less than one year comprise
only 15 percent of savings accounts, not a substantially different
configuration from that shown in Table 1.

It is further assumed that

certificates of four years or longer are almost as important (37 percent as
compared to 40 percent) as savings of less than one year maturity.
Furthermore, it is assumed that the S&L is able to successfully offer
ten-year and twelve-year, zero-coupon certificates which make up 20 percent
and 10 percent, respectively, of deposits in the over four-year category.
On the basis of these assumptions, the weighted average duration of
deposits is 2.37 years.

Moreover, to the extent that an S&L has some

flexibility in choosing the duration of the "other liability" category,
ranging from 0-20 years, the weighted average duration of the liability
side of the balance sheet may fall between 2.57-3.87 years.

While a

liability duration of 3.87 years is still below the minimum asset duration
of 4.44 years shown in Table 1, the asset-liability duration gap is,
nevertheless, narrowed considerably.
Accomplishing such a redirection of savings flows would be a Herculean
feat unless an upward sloping yield curve persisted for several years.
Nevertheless, if asset duration could be reduced by the introduction of
consumer lending and increased acceptance of adjustable rate mortgages,
then immunization may be feasible.

Indeed, even without allowing for

reducing mortgage duration through ARMs, S&L weighted asset duration could
be reduced considerably, as shown in Table 2, by devoting 20 percent of S&L
assets to consumer lending.

In fact, if "other assets" are invested in

securities with very short maturity, the weighted asset duration approaches
the upper limit of the weighted liability duration given in




14

Table 2.

Thus the duration imbalance may disappear, particularly if

mortgage durations are shortened by widespread acceptance of flexible rate
mortgages.

It should be noted, however, that 20 percent of S&L assets

would comprise about $116 billion of consumer loans at year-end 1979.

This

was about 65 percent of the amount of consumer loans that commercial banks
had on their books at that time.

Clearly, S&Ls cannot gain market

penetration of this magnitude without a struggle.
The previous examples are based upon the average balance sheet makeup
of all S&Ls.

Clearly there is a great deal of variability across S&Ls in

general and across specific geographic groups of S&Ls in terms of their
ability to immunize.

Immunization of S&Ls in geographic regions with high

mortgage turnover rates may be particularly feasible if they could
successfully offer long-term, discount savings certificates.

Of course, it

is possible that those S&Ls with the shorter asset durations may be among
those that would encounter a difficult time marketing long-term, discount
savings certificates.
An exact matching of asset and liability durations may not be possible
since depositors and borrowers have the option to withdraw their funds or
prepay their loan obligations.

The price of exercising these options has

typically not been very high and has been outside the control of S&Ls,
being set by law, regulation or customary industry practice.

Complete

immunization may be very difficult but partial immunization is still
possible.

The smaller the duration gap between assets and liabilities, the

smaller is an institution's exposure to changes in interest rates.
In addition to not always being feasible, immunization is not always a
desirable strategy.

Immunizing a balance sheet will lock in the spread

between the return on assets and the cost of liabilities.



In 1981 this

15

spread was negative— clearly a bad time to follow an immunization strategy.
Had an immunization strategy been followed in 1978, however, many of the
earnings difficulties that haunted the S&L industry in 1981 would not have
materialized.

The choice of when and to what extent to immunize is clearly

a difficult management choice.

The phase-out of Q-ceilings has given S&L

managements discretion over the immunization decision.
immunization was not feasible for three reasons:

In 1978,

Regulation Q dictated the

menu of possible savings deposits instruments; diversifration into consumer
lending was allowed in only a few states; and federally chartered S&Ls were
not allowed to issue variable rate mortgages.
The Necessity for Zero-Coupon Deposits
To achieve immunization, an S&L must be able to drastically increase
its reliance on long duration liabilities.

It may be necessary, as well,

that the duration of assets be shortened at the same time.

Clearly, the

problem that must be addressed by the Depository Institutions Deregulation
Committee (DIDC) in establishing Q-ceilings, if immunization is to be at
all possible, is the redirection of deposit flows from MMCs to certificates
with four-year, six-year, eight-year and even longer maturities.
If the duration of S&L liabilities is to be increased, then, for any
given promised yield^(yield to maturity), savings deposits or other
liabilities of longer maturity or lower coupon need to be sold.

In order

to maximize the duration of a financial instrument, the mathematics of
duration requires that the instrument have a zero coupon, in which case the
instrument’s duration equals its maturity.

In the case of coupon

securities, duration can be lengthened— for any given yield to maturity,
coupon, and maturity— by decreasing the frequency of coupon payments.




16

Again, a zero-coupon security provides the upper limit to spreading out
coupon payments and maximizing duration.
If S&Ls could sell, for example, a ten-year, zero-coupon deposit, that
deposit would have a duration of ten years (regardless of the promised
yield).

If an S&L were to sell a ten-year savings certificate paying 8

percent semi-annually, that deposit would have a duration of 7.067 years.
Deposits with coupons less than the promised yield to maturity would
provide some income stream to the saver prior to maturity and would have a
duration of less than the instrument’s maturity, but greater than the
duration of a deposit that has a coupon equal to the promised yield (see
Table 3).

Zero-coupon liabilities, if they can be marketed successfully,

seem to offer the greatest potential for increasing liability duration.

Table 3
Duration of Ten-Year Savings Accounts
With Promised Yield of 8 Percent
(and Semiannual Coupons)
Coupon Rate
(percent)

Duration
(years)

0

10.000

2

8.762

4

7.986

6

7.454

8

7.067

Source: Fisher and Weil, "Coping with the Risk of Interest Rate
Fluctuations," Table 4.
The ability to find a market for long duration deposits has been
greatly enhanced by the early actions of the DIDC.

Beginning in December

1981, S&Ls were allowed to offer Individual Retirement Accounts (IRAs) and
Keogh accounts having a minimum maturity of lh years and with no




17

restrictions on the allowable interest rate.

Since IRA and Keogh accounts

are typically very long term in nature and interest is not really paid out
until maturity (or withdrawal of full principal), the deregulation of
Q-ceilings on these accounts provided an opportunity to increase average
deposit duration.

Because of intense competition from other financial

institutions for these kinds of accounts, S&Ls have had to promise IRA and
Keogh account holders attractive rates of return.

S&Ls have one principal

advantage over many of their competitors in attracting IRA and Keogh
accounts; they have a greater need for long-term funds than many of their
competitors.

As a result, many competitors will drop out of the bidding

race for these funds and concentrate on shorter-term funding.

Another DIDC

decision (overturned by the courts) to eliminate rate ceilings on deposits
with four years or longer maturity also would have been a boon to extension
of liability duration.
ADVANTAGES AND DISADVANTAGES OF LONG DURATION LIABILITIES
To achieve an immunized position, S&Ls may increase the average
duration of their liabilities by increasing the duration of their deposit
and/or nondeposit liabilities.

Both types of liabilities share many common

characteristics; consequently, the advantages and disadvantages of deposit
and nondeposit liabilities will be examined together.
Advantages
1.

ABSENCE OF COUPON REINVESTMENT RISK.

Because they generate no

cash payments to be reinvested, one principal advantage of all zero-coupon
instruments is that reinvestment risk disappears.

The initial discount on

the instrument accrues to capita] at the promised rate of return— no more
and no less.




Consequently, the realized rate of return will equal the

18

promised rate of return when the instrument’s maturity equals the planning
period.
Coupon instruments, on the other hand, offer no such guarantee.

An

investor’s realized return will equal the promised rate only if all coupons
are received on time and are immediately and fully reinvested at the
initial promised rate.

Given the volatility of interest rates during the

last 20 years, only under fortuitous circumstances would the average return
from investment of the coupons equal the initial promised rate of return.
Coupon securities will generate realized returns above, at, or below the
promised yield depending on the average reinvestment rate that is achieved.
Risk averse investors may attach a high cost to earning less than the
promised yield and may find zero-coupon securities appealing.
The advantage of zero reinvestment risk is important for depositors
with a long time horizon.

Deposit contracts generally specify that the

principal will compound at exactly the promised rate for the full maturity
of the deposit.

In a world without taxes, the depositor’s promised and

realized returns are equal.

However, depositors with an investment horizon

of five years who invest in six month MMCs incur considerable reinvestment
risk once their initial investment reaches maturity.

Similarly, investors

in money market funds must infer the promised rate of return from previous
yields and they are heavily burdened with reinvestment risk.

Holders of an

S&L’s nondeposit liabilities also have little reinvestment risk protection.
For them, the absence of reinvestment risk may be a particularly valuable
feature that would, other things equal, make an S&L’s long-term,
zero-coupon capital notes an attractive investment vehicle.
2.

ABSENCE OF COUPON REINVESTMENT COSTS.

In addition to the

uncertainty surrounding the interest rate at which coupon payments can be




19

invested, coupon securities suffer from another problem— their net yield is
reduced by the transactions costs and search costs associated with
investment of the proceeds from the coupon payments.

Search and

transactions costs may be significant relative to the amount to be
reinvested, particularly for small savers.

Because a zero-coupon security

has no coupon payments that require reinvestment, its owner is neither
faced with the costs of searching for the best coupon reinvestment
alternative nor any transactions costs for such investment.
Again, the nature of current day deposit instruments offered by
federally insured depository institutions renders academic the reinvestment
cost aspect of zero-coupon deposits.

Depositors are guaranteed that all

interest (i.e., coupon) payments will be compounded (i.e., reinvested)
without charge at the initial promised rate until maturity.

Holders of a

financial institution’s long-term capital notes, however, are faced with
coupon reinvestment costs and might find that zero-coupon capital notes
would increase their net return by eliminating search and transactions
costs.
3.

LONGER EFFECTIVE LIFE.

Zero-coupon securities have a longer

effective life than a coupon security with the same maturity because they
involve a single payment at maturity.

For savers and investors who desire

a security with a longer effective life than is available from a coupon
security (and who do not wish to invest in a security having a maturity
longer than the desired holding period), a zero-coupon security may fill an
existing void in the range of available investment vehicles.
At the present time there are only two zero-coupon securities that are
readily available to small investors— Treasury bills and U.S. Savings
Bonds.




Treasury bills have a minimum denomination of $10,000 and are

20

available in a very limited range of maturities ranging up to one year.
For someone seeking an investment with a ten-year effective life, Treasury
bills do not represent a satisfactory investment vehicle.
U.S. Savings Bonds are also not suitable investment alternatives for
someone with a ten-year time horizon.

Prior to 1980, savings bonds were

available in denominations that were multiples of $25, were sold with only
one maturity (five years), and there was a limitation of $7,500 on the
amount of savings bonds that could be purchased per year.

Since 1980,

savings bonds have been available in denominations that are in $25
multiples (minimum denomination, $50) originally with a maturity of 11
years and nine months and with an annual purchase limitation of $15,000.
The maturity has been reduced somewhat from increases by Congress in the
rate paid on savings bonds.
certainty.

The maturity has never been known with

For savings bonds as for Treasury bills, the ability of a saver

to achieve the desired effective maturity is very limited.

For such

savers, a zero-coupon deposit available in a wide range of maturities and
denominations might be an attractive savings vehicle.
For example, take the case of someone with an eight-year old child
wishing to set aside several thousand dollars to pay for the child’s
college education.

During the forthcoming ten-year period, no cash flow

from coupons is needed.

Other things being equal, such an investor would

prefer a ten-year, zero-coupon security to a coupon security offering the
same promised yield.
available.^

However, ten-year, zero-coupon securities are not

This hypothetical saver would likely find a ten-year discount

savings certificate an attractive investment.
Unfortunately, the saver in our hypothetical! example cannot turn to
his friendly S&L or commercial bank to purchase a financial instrument that




21

satisfies his needs.

Our hypothetical desired savings account is not on

the menu of savings accounts that are specified in Regulation Q.

Another

side effect of Q-ceilings is that it prevents financial intermediaries from
performing their essential function of issuing liabilities that are
tailored to the needs of savers and, hence, are more desirable to savers
than the primary securities issued by ultimate borrowers and available on
the open market.
Whether small savers would purchase long-term, zero-coupon deposits in
sufficient quantities to make them worth offering is an empirical question.
In and of itself, the discount feature of Treasury bills and savings bonds
has not hurt their sales.

Both of these discount instruments are issued by

the U.S. government, have zero credit risk, and have sold well when their
rates were competitive with alternative investments.

With deposit

insurance available to $100,000, there is no reason to believe that small
savers would eschew discount savings certificates that pay competitive
rates.
New instruments take time to be understood and accepted.

Money market

mutual funds took several years to catch on because they required savers to
become familiar with a new financial intermediary with which they had never
done business.

MMCs allowed savers to continue doing business with their

traditional financial intermediary and became a household word much more
quickly.

A zero-coupon (or discount) savings certificate, despite the new

name, does have familiar predecessors (Treasury bills and savings bonds)
and familiar sales outlets (banks and S&Ls).

Thus, unless discount savings

certificates become very complex securities because of a need to attach put
or call provisions, there is a good chance that their long duration will
g
not hurt their market acceptability with small savers.
Likewise,




22

investors in long-term capital notes of S&Ls and banks may find a
zero-coupon feature attractive.
4.

IMMUNIZATION.

Another advantage of zero-coupon savings

certificates is that their successful introduction may allow some S&Ls to
partially or fully immunize against interest rate movements.

For other

S&Ls, a significant narrowing in the duration of their assets and
liabilities will become possible.

For all such institutions, one of the

major risks of intermediation, that of changes in the level and structure
of interest rates, will have been decreased, minimized, or eliminated.
This should make the S&L industry less risky overall unless individual S&Ls
choose to offset this risk reduction by increasing their exposure to other
kinds of risk.

Presumably, S&Ls that attempt to immunize will do so in an

effort to reduce their overall risk exposure and are not likely to increase
other types of risk.
Immunization of a significant portion of the S&L industry will yield
additional social benefits.

The reduced risk in the industry should be

accompanied by a reduced need for regulation and would open the door to a
reduction of regulatory administrative and compliance costs.

The reduced

industry risk should allow a reduction in deposit insurance premiums or the
setting of premiums that are inversely proportional to the degree of
immunization that is attained by a financial institution.

Alternatively,

the deposit insurance agency could petition Congress for the power to
provide insurance coverage beyond $100,000 to cover interest payments on
discount certificates for institutions that achieve and maintain a given
degree of immunization.

By their very nature, long-term discount

certificates involve more interest than principal.

For example, an initial

deposit of $3,855 in a ten-year, zero-coupon savings account promising to




23

pay 10 percent would have a maturity value of $10,000.

An initial deposit

of $50,000 in this same account would have a value that exceeded the
$100,000 insurance limit prior to the maturity of the deposit.

A guarantee

of the full interest payment at maturity by the deposit insurance authority
would enchance the ability of S&Ls to market these deposits.

The insuring

authority should be willing to offer extended insurance coverage priced
according to degree of immunization.
5.

LOCALLY TAILORED SAVINGS INSTRUMENTS.

The design of savings

accounts that satisfies the needs of retail customers has become a lost art
in the S&L industry.

The phase-out of Q-ceilings enables and requires the

design of deposits that meet the needs of diverse sets of individual
customers.
Financial markets have become increasingly integrated in recent years;
nonetheless, each of the numerous local geographic retail markets for
savings in the United States retains some local idiosyncrasies.

Savings

instruments that would be a flop in Peoria, Illinois, may very well be
marketed successfully in Chicago, gain moderate acceptance in New York
City, and be marginally worth introducing in Newton, Iowa.

Savings

institutions can tailor zero-coupon certificates to fit the immunization
needs of their balance sheet and the investment desires and needs of their
customers, not the desires of customers hundreds of miles away or the
savings needs that financial institution regulators in Washington, D.C.
perceive that consumers desire.

Both parties to the transaction will be

better off from this increased freedom.
Disadvantages
1.

NO ANNUAL CASH FLOW.

provide no cash flow.




By definition, zero-coupon financial claims

Savers and investors that require a steady cash

24

inflow would find this drawback insurmountable and would continue to demand
coupon securities.

Those savers such as owners of Individual Retirement

Accounts and Keogh Accounts, with little need for continuous cash inflows
should not object to discount savings certificates and are likely to find
zero-coupon savings accounts advantageous if they are offered a slightly
higher return than on a savings account with comparable maturity but paying
interest on a regular schedule.

It must be kept in mind that IRAs and

Keoghs are arrangements whereby the interest income, whether paid or
accrued (but not withdrawn), is tax deferred.

Hence, the owner of such an

account has no tax liability during the life of the account and so requires
no cash flow for meeting tax payments.
2.

NEEDED TAX REFORM.

Savers who are not able to defer taxes would

find zero-coupon savings accounts unattractive in the absence of some
additional incentives.

One feature of a savings account that has added to

its attractiveness is that the before-tax promised and realized returns are
equal.

Any disparity between the promised and realized return on savings

accounts arises solely from the fact that the need to pay income tax (state
and federal) on the interest prevents full reinvestment of the coupon
payments.

All other investment media, with the exception of zero-coupon

financial claims, do not possess the feature that before-tax promised and
realized returns will be equal.

Savings accounts would become a more

attractive investment vehicle if the spread between after-tax promised and
realized returns were to be narrowed by allowing deferral of income tax
until the year in which the interest is actually, rather than
constructively, received by the account holder.

Long-term, zero-coupon

savings certificates would likely be very marketable instruments if the tax
laws were amended to provide for such a tax deferment.




25

The short-term loss of income to the U.S. Treasury that such an
amendment of the tax laws would entail requires some justification.
Probably the most compelling case that can be made for allowing taxes on
zero-coupon savings accounts to be deferred until maturity or withdrawal of
interest is that widespread consumer acceptance of these savings accounts
would help to stabilize the mortgage and housing markets.

Since this

happens to be a national goal or high social priority, mortgage market
stabilization may be worth subsidizing and tax deferral may be warranted.
Moreover, one of the larger subsidies to the housing sector is Regulation
Q, which has been experiencing a slow death for several years and which
will be phased out by March 1986.

It could be argued that tax deferral of

interest on long-term discount savings certificates should replace the
subsidy that has been provided by Q-ceilings.

9

Another reason for

providing a subsidy to discount savings certificates is that, to the extent
tax deferral increases the marketability of these accounts, there will be a
salutary effect on the ability of S&Ls to immunize against interest rate
risk.

This would have the additional benefit of reducing a major financial

and political constraint upon monetary policy.
The U.S. Treasury is likely to resist any attempt to allow tax
deferral on long-term, zero-coupon savings accounts for two reasons:

(1)

loss of tax revenue, and (2) it would become more difficult for the
Treasury to market its own securities to individuals because these proposed
new savings accounts would in some ways be superior to securities offered
by the Treasury.^

If long-term discount savings accounts had interest

income that were both tax deferred and insured by an agency of the U.S.
Government, they would be preferable to long-term Treasury securities which
currently lack the tax deferral feature be c a u s e intermediate and long-term




26

Treasury securities are issued at or near par value.

Hence, nearly all

income on Treasury securities is interest income (and is subject to tax in
the year received) and virtually no income is attributable to original
issue discount on which taxes can be deferred until the bond is sold or
matures, whichever comes first.^

Moreover, with Q-ceilings being phased

out, such deposit accounts will soon be paying competitive market rates
which would make them more attractive than U.S. Savings Bonds, the only
instrument sold by the Treasury that might be considered similar to a
long-term, zero-coupon savings account.

To be strictly comparable,

however, savings bonds would have to pay market rates, be made available in
a wider range of maturities and in larger denominations.
3.

INCREASED PRICE RISK.

Because the price risk of a security is

proportional to its duration, zero-coupon securities have greater price
volatility than coupon securities with the same maturity.

Risk averse

investors may not find this built-in feature very appealing.
drawback applies only to negotiable securities.

However; this

Most consumer-type savings

accounts are nonnegotiable; hence, price volatility is not an issue.

Price

risk may be an important drawback in the case of negotiable capital notes
and may therefore impose a serious limit on the maximum maturity of zero(or low-) coupon capital notes that can be sold.
4.

CRISIS AT MATURITY.

Because the issuer of a long-term,

zero-coupon security would be able to go a long number of years without
proving its creditworthiness by making interest payments in full and on
time to the holder of the security, it is possible that doubts may arise
concerning the ability of the issuer to redeem the debt and accrued
interest.

A zero-coupon security having a promised yield of 10 percent and

a maturity of eight years would have a final value composed of 46.7 percent




27

principal and 53.3 percent interest.

If the final value were less than the

maximum federal insurance on deposits (currently $100,000), there would be
no crisis at maturity.

For deposits whose final value exceeds the federal

insurance maximum then in force, a definite concern about the issuer’s
ability to repay could very well surface; it is likely that increased
disclosure requirements will have to be placed upon institutions issuing
long-term discount certificates.

Again, the nonnegotiability of savings

accounts renders academic the issue of increasing default risk premiums as
the deposit approaches its maturity date.

12

For negotiable subordinated

capital notes, however, the crisis-at-maturity question may be important.
The capital notes of most small financial institutions do not enjoy a good
secondary market; consequently, most purchasers of these capital notes plan
to hold the notes to maturity, and the crisis at maturity dilemma does not
apply.

Larger financial institutions whose capital notes trade in an

active secondary market may be faced with the issue of crisis at maturity
with zero-coupon capital notes.

Given the possible spillover effects of

such a (real or perceived) crisis atmosphere, larger financial institutions
may choose to avoid issuing long-term discount capital notes.
5.

COMPLEXITY OF THE INSTRUMENT.

As mentioned previously,

zero-coupon financial claims are not new; Treasury bills comprise about 35
percent of the marketable government debt, and savings bonds have been well
accepted when they paid competitive rates.

In and of themselves, fixed

rate, zero-coupon securities are probably less complex than comparable
coupon securities.

If zero-coupon securities were issued by private firms

such as S&Ls that previously issued only coupon securities, these savings
accounts may come to be viewed as being more complex than they really are.




28

In a volatile interest rate environment that reflected divergent
expectations about future inflation rates, it is possible that fixed rate,
zero-coupon securities would not find much of a market.

In these

circumstances, a variable rate discount certificate could be offered.

The

interest return for any given period would be paid at maturity but would be
tied to a short-term market interest rate or to some index of market rates.
As is discussed in the next section, this may be a convenient way of
getting around the Treasury Department’s regulations regarding the payment
of taxes on each year’s accrual of the original issue discount.
The complexity of a variable rate, zero-coupon savings account could
very well limit market acceptance for several reasons.
value of the account would be unknown.
unknown parameter.

First, the final

Second, the promised return is an

Third, the exposure of the issuing financial

institution to future payouts, while not unlimited, can still be
several-fold greater than with fixed rate liabilities and would dissuade
the institution from offering these instruments without call provisions in
the indenture.
complexity.

The callability feature would add to the instrument's

Fourth, the uncertainty of future rates would make suppliers

of funds desire a reverse call (or put) feature, adding further to the
instrument’s complexity.

Such put and call features are beyond the

understanding of many potential providers of funds to financial
institutions and would seriously limit the market for these complex
instruments.

This has been the case with floating rate notes issued by

bank holding companies in 1974-75 (and more recently by Citicorp in 1980).
And last, a variable rate discount security has a duration that is equal to
the period over which the coupon is fixed.

For example, if the rate were

changed every six months in accordance with some index of money market




29

rates, the duration of the security would be six months.

But the original

reason for suggesting a zero-coupon savings account was to permit an S&L to
apply immunization principles by issuing long duration deposits.
Consequently the original impetus for zero-coupon savings accounts would be
vitiated if it were necessary to offer variable rate, long-term savings
accounts.
6.

REDUCED PROFITABILITY.

By reducing one major component of

risk— the systematic risk associated with interest rate
movements— immunization should lower the overall riskiness of many
individual S&Ls and the S&L industry as a whole, unless S&Ls choose to
maintain the same overall risk exposure by bearing increased risk in other
areas.

Since lower risk is generally associated with lower profitability

(but not necessarily in proportion), the risk-return characteristics of the
industry would change as additional S&Ls attempted to immunize.
short run the return on capital will be reduced.

In the

The reduced profitability

will place additional limits on the rate at which capital is expanded and
will consequently reduce an institution’s ability to withstand shocks due
to causes other than interest rate movements.
7.

REDUCED COMPETITION BETWEEN BANKS AND S&Ls.

If both banks and

S&Ls make a sincere effort to immunize, it is likely that the differences
between the two types of institutions will become more pronounced rather
than blurred.

Given the short-term nature of their assets compared to

S&Ls, banks are likely to heavily promote MMCs or some other savings
account closely related to it.

S&Ls, on the other hand, should promote

long-term, zero-coupon savings accounts to match their long duration
assets.

Where the two institutions in the past have competed vigorously

and directly— namely, for retail savings accounts— they will, in the




30

future, compete to a lesser extent.
reduce their mortgage lending.

Banks wishing to immunize will likely

S&Ls wishing to immunize will also want to

reduce their mortgage lending, substituting short-term consumer loans.
Thus, there may be less competition in the origination of conventional,
one-to-four family mortgages as a result of industry-wide attempts by banks
and S&Ls to immunize.

Some of the forementioned reduction in competition

in the deposit-taking and mortgage lending areas is likely to be offset
somewhat by increased competition in consumer lending.
MARKETING ZERO-COUPON DEPOSITS
An S&L that attempts to market zero-coupon deposits by referring to
them by such an esoteric title will find few, if any, customers.

However,

with only modest creativity in disguising the name of the new account by
using euphemistic terminology, zero-coupon accounts have the potential to
gain a respectable share of the deposit market.

This can be seen by

evaluating the relative advantages and disadvantages of these accounts
discussed in the previous section.
Zero-coupon deposits— or perhaps they should be referred to as
deposits having interest paid at maturity— have few serious disadvantages,
most of which can be easily overcome, and they have many advantageous
characteristics as well. The primary disadvantage is the lack of cash flow
to the owner.

But the new, deregulated IRA/Keogh account approved by the

DIDC effective December 1, 1981 is an account that does not require a cash
flow.

The absence of a regular cash flow has never been a serious drawback

to sales of Series E or EE savings bonds; further, S&Ls and banks sold a
large volume of 4-year and 6-year certificates of deposit in the mid-1970s,
most of which allowed the interest to compound and be paid out at maturity




31

or the date of early withdrawal (at a penalty).

Short maturity and regular

cash flow are important to some but not all depositors.
The absence of cash flow could present a problem for long-term
deposits that do not offer the tax-deferral feature of IRA/Keogh accounts.
But the need for explicit tax-deferral is somewhat unclear.

As discussed

in footnote 11, each year’s amortization of a corporate security’s original
issue discount is subject to federal income tax.

The registration

statements provided by issuers of deep discount and zero-coupon corporate
bonds typically have a section containing standard verbiage describing the
applicable tax codes.

Whether these tax codes really apply to an S&L

deposit paying all interest at maturity is unclear.
The lack of clarity on this point leaves S&Ls with three options.
First, zero-coupon deposits can be sold to depositors who are clearly tax
exempt.

IRA/Keogh accounts are ideal in this regard.

Pension funds are

also tax exempt; and further, they enjoy the privilege of being able to
aggregate the FSLIC insurance protection across their membership
beneficiaries so that they are not limited by the $100,000 insurance
maximum of an individual.

13

Several S&Ls have begun to offer three-year

and longer zero-coupon accounts to pension funds at rates slightly above
market for a federally insured investment.
A second but risky way to issue long-term, zero-coupon accounts is to
tie the rate paid to a short-term index over which the S&L has no control.
Thus the depositor would only know, for the sake of example, that the rate
paid is the six-month Treasury bill rate plus 150 basis points; the rate
would change every six months; and that all interest would be paid at
maturity in four years or longer.

Because future reinvestment rates are

not known and final maturity date has not been established, the original




32

issue discount cannot be determined for tax purposes.

Even if the Internal

Revenue Service (IRS) were to go along with such an interpretation of the
tax codes, it seems clear that such deposits could only be marketed to a
sophisticated class of investors who understand the put and call options
and the Implications of variable rates.

Further, these investors need to

have control over the timing of their other tax liabilities; otherwise the
final receipt of interest at maturity could have very adverse tax
consequences.

Clearly this is a limited market and one that the IRS could

eliminate with a single, concise ruling on the tax status of zero-coupon
deposits.
A third option that should be explored is to lobby the Congress to
change legislation to permit some tax deferral on long-term savings.

Such

lobbying efforts have been going on for many years and will likely
continue.

Primary emphasis has been given to tax deferral of interest

income for specially earmarked savings to fund high social priority
investments such as the purchase of a first home or the financing of a
child’s college education.

Up to this point in time, the Congress has

resisted most of these lobbying efforts based largely on the fact that both
housing and education were already the recipient of numerous subsidies.

14

Since the economic logic behind tax incentives to boost savings is not
overly compelling, any decision to legislate such subsidies must be based
partially on political grounds.^

The fundamental decision that must be

addressed is whether it is less expensive to the U.S. Treasury to utilize a
shotgun approach by providing tax incentives to saving that benefit
individual taxpayers and some classes of financial institutions not in need
of a subsidy as opposed to using selective direct outlays for bailouts or




33

subidies of a few individuals or financial institutions that have the
greatest need for subsidization.
Considerable marketing effort will be necessary to convince the public
to purchase long-term savings accounts and other investments that do not
pay any interest for several years.

However, some segments of the public

desire accounts with these features and they have been ill-served by
Regulation Q restrictions of recent years that made these deposits
unpalatable.

Further, S&Ls have a strong incentive and need to issue these

deposits to lessen the impact of interest rate volatility.

All that is

necessary is for the suppliers and demanders of funds with this commonality
of interests to get together on terms.

The success of long-term,

zero-coupon deposits will then be an empirical matter.
CONCLUSIONS
In conclusion, the marketing of long-term, zero-coupon deposits will
allow S&Ls to increase the extent to which they may immunize themselves
against changes in interest rates and will postpone the cash flow crisis
now facing the S&L industry.

Further, if the Treasury can be convinced to

allow tax deferral of interest income on long-term, zero-coupon deposits
issued by S&Ls, then a more permanent and superior solution to the current
earnings and solvency problems of the industry can be found.

All Savers

Certificates, capital injections by the FSLIC, and other government
subsidies which do little to encourage long-term thrift or to solve the
interest rate risk dilemma faced by the S&L industry provide no long-term
relief and questionable short-term benefits to the industry or society.
In the more volatile interest rate environment that has existed since
the Federal Reserve changed its operating procedures for monetary policy on
October 6 , 1979, the desire and need on the part of S&Ls and other




34

financial institutions to partially or fully immunize has undoubtedly
increased.

Another benefit derived from protection against interest rate

changes is the renewed ability of an S&L to choose to remain a specialist
in home mortgage financing.

Footnotes

If the overall structure of interest rates does not fall considerably
below the rates generally prevailing in 1981, however, the deferral of cash
outflows will not improve an S&L's survival probability.
2

Gerald 0. Bierwag, George G. Kaufman, and Alden L. Toevs, "Management
Strategies for Savings and Loan Associations to Reduce Interest Rate Risk,"
in New Sources of Capital for the Savings and Loan Industry, Proceedings of
the Fifth Annual Conference, Federal Home Loan Bank of San Francisco,
December 1979.
3
Michael H. Hopewell and George G. Kaufman, "Bond Price Volatility and
Term of Maturity: A Generalized Respecification," American Economic
Review, September 1973.
^Lawrence Fisher and Roman L. Weil, "Coping with the Risk of Interest
Rate Fluctuations: Returns to Bondholders from Naive and Optimal
Strategies," Journal of Business, October 1971.
~*0ther conditions must be satisfied for either complete or partial
immunization to be obtained. The planning period must be known with
certainty and both assets and liabilities must be marked to market. See
Bierwag, Kaufman, and Toevs, "Management Strategies..."
^Bierwag, Kaufman, and Toevs, "Management Strategies...," Table 2, p.
186.
^Insurance companies may offer single-payment annuities that have many
of the characteristics of zero-coupon bonds. One noticeable difference is
that insurance companies generally charge a front-end load as well as an
annual administrative fee.
Beginning in March 1981, financial and nonfinancial films began
offering deep-discount and zero-coupon bonds. Through November 24, 1981
the 36 issues that entered the market had a face value of $8.5 billion and
netted $3.5 billion to the issuing corporations. Eleven of these 36 issues
were zero-coupon bonds. Among the issuers were J. C. Penney, G. M.
Acceptance Corp., IBM Credit Corp, CIT Financial Corporation, and Security
Pacific Corporation. See Moody1s Bond Survey, November 30, 1981, p.
884-885.




35

Footnotes (cont1d)

Even if small savers find difficulty comprehending discount savings
certificates, trust departments may find them to be a useful investment
vehicle, particularly for small trust accounts where transactions and
search costs need to be minimized. S&Ls may find the trust account powers
granted them by DIDMCA to be a useful adjunct in marketing discount
certificates.
9
Regulation Q is often thought of as a subsidy to the housing industry
but this need not always be the case. For example, when Q-ceilings are
binding and widespread disintermediation takes place, Regulation Q should
be regarded as a tax that reallocates expenditure away from housing to
other sectors of the economy. Even when Q-ceilings are not binding, the
existence of Q may reduce the flow of funds to all financial institutions
that are subject to Q, thereby decreasing the overall supply of funds
available to make mortgages. The important point is that Congress
perceives Q-ceilings as a subsidy to housing and would likely be amenable
to replacing one perceived subsidy with another. The proposal espoused in
this paper— namely allowing deferment of taxes on long-term, zero-coupon
savings accounts— would merely make explicit a congressionally intended
subsidy to the housing sector and replace the Regulation Q subsidy, which
has worked either poorly or perversely, with a subsidy that is more likely
to have the intended effect.
^ I f the Treasury desired to reduce the number of small tenders or
tenders from noninstitutional customers at its auctions, it might welcome
long-term, zero-coupon savings accounts as a politically convenient way
out. In this event, the Treasury might not object to the introduction of
tax deferred, zero-coupon savings accounts provided the interest rate were
tied to and were held below an index of comparable maturity Treasury
securities.
^According to Internal Revenue Service regulations, the original
issue discount on debt of the U.S. Treasury is subject to income tax as
ordinary income, but payment of the tax may be deferred until the sale or
maturity of the bond, whichever comes first. On corporate debt issued
after May 27, 1969, the ratable portion of the original issue discount
cannot be deferred and must be included in gross income each year. Under
existing tax law, the U.S. Treasury has a definite advantage in the ability
to sell discount bonds owing to the tax-deferral advantage.
12

For a discussion of default risk premiums as a debt instrument
approaches maturity, see James C. Van Horne, Financial Market Rates and
Flows, Prentice Hall, 1978, p. 164-172.
13

See United States League Federal Guide, Section L9-80.3 - Section
L9-80.5, United States League of Savings Associations, 1981. Plain
language examples of the underlying regulations and interpretations are
provided in Letter S#172, "Special Management Bulletin Re: Insurance of
Accounts Coverage of Pension and Other Trusteed Employee Benefit Plans,"
United States League of Savings Associations, March 17, 1978.




36

It has been estimated that housing will receive tax subsidies of
more than $39 billion in fiscal 1982, over two-thirds of which was
accounted for by the deductability of home mortgage interest payments.
U.S. Congressional Budget Office, The Tax Treatment of Homeownership:
Issues and Options, September 1981.
^ T h e economics of tax incentives for saving and deferral of tax on
savings account earnings is explored in U.S. Senate, Committee on Banking,
Housing, and Urban Affairs, The Report of the Interagency Task Force on
Thrift Institutions, July 1980, pp. 124-138.

POSTSCRIPT
Beginning in March 1982 several nonS&L competitors began to offer
retail, long-term, zero-coupon instruments designed specifically for
IRA/Keogh plans.

The first of these plans was sponsored by Paine, Webber,

Jackson and Curtis Incorporated as a unit investment trust that allowed
individuals to participate in a portfolio of corporate debt securities
originally issued at a discount, substantially all of which were
zero-coupon bonds.

Approximately one week later in a full page

advertisement in the March 15, 1982 Wall Street Journal, BankAmerica
Corporation, the holding company for the largest U.S. bank announced a $500
million issue of retail zero-coupon notes having three maturities:

one

that would double one’s investment in approximately 5 years and 8 months,
one that would triple one’s original investment in approximately 8 years
and 8 months, and one that would quadruple the original investment in 10
years and 10 months.

These ’’Money Multiplier Notes” would sell initially

for $500, $333.33 and $250 respectively and would all have a maturity value
of $1,000.
Also in mid-March 1982, Merrill Lynch & Co. began to market to their
IRA/Keogh customers zero-coupon CDs issued by Crocker National Bank.

These

certificates of deposit had maturities of five, eight, or ten years and




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were marketed nationwide through Merrill Lynch’s national distribution
network of approximately 440 sales offices.

The feature that distinguishes the

Merrill Lynch/Crocker zero-coupon instruments from those offered by Paine
Webber and BankAmerica Corporation is that Merrill Lynch is marketing an
investment instrument with up to $100,000 of federal deposit insurance.

As

quoted in the March 22, 1982 American Banker, Merrill Lynch would be happy
to act as a broker for similar zero-coupon deposits issued by other banks
or S&Ls.

It seems readily apparent that the time for zero-coupon deposits

has come; S&Ls need only follow the marketing strategies of their banking
and investment company competitors.