Taming wildcat stablecoins …

… is the title of an interesting paper by Gary Gorton and Jeffrey Zhang which argues that:

  • Cryptocurrency, or stablecoins to be more precise, can be viewed as the latest variation in a long history of privately produced money
  • The experience of the United States during the Free Banking Era of the 19th century suggests that ” … privately produced monies are not an effective medium of exchange because they are not always accepted at par and are subject to bank runs”
  • Stablecoins are not as yet a systemic issue but could be, so policymakers need to adjust the regulatory framework now to be ready as these new forms of private money grow and and potentially evolve into something that can’t be ignored
  • Policy responses include regulating stablecoin issuers as banks and issuing a central bank digital currency
So what?

I am not convinced that a central bank digital currency is the solution. I can see a case for greater regulation of stablecoins but you need to be clear about exactly what type of stablecoin requires a policy response. Gorton and Zhang distinguish three categories …

The first includes cryptocurrencies that are not backed by anything, like Bitcoin. We call these “fiat cryptocurrencies.” Their defining feature is that they have no intrinsic value. Second, there are specialized “utility coins,” like the JPMorgan coin that is limited to internal use with large clients. Finally, there are “stablecoins,” which aspire to be used as a form of private money and so are allegedly backed one-for-one with government fiat currency (e.g., U.S. dollars)

I am yet to see a completely satisfactory taxonomy of stablecoins but at a minimum I would break the third category down further to distinguish the ways in which the peg is maintained. The (relatively few?) stablecoins that actually hold high quality USD assets on a 1:1 basis are different from those which hold material amounts of commercial paper in their reserve asset pool and different again from those which employ algorithmic protocols to maintain the peg.

However, you do not necessarily have to agree with their taxonomy, assessments or policy suggestions to get value from the paper – three things I found useful and interesting:

  1. The “no-questions-asked ” principle for anything that functions or aims to function as money
  2. Some technical insights into the economic and legal properties of stablecoins and stablecoin issuers
  3. Lessons to be learned from history, in particular the Free Banking Era of the 19th century
The “no-questions-asked” principle.

Money is conventionally defined in terms of three properties; a store of value, a unit of account and a medium of exchange. Gorton and Zhang argue that “The property that’s most obvious, yet not explicitly presented, is that money also must satisfy the no-questions-asked (“NQA”) principle, which requires the money be accepted in a transaction without due diligence on its value“. They freely admit that they have borrowed this idea from Bengt Holmstrom though I think he actually uses the term “information insensitive” as opposed to the more colloquial NQA principle.

Previous posts on this blog have looked at both Holmstrom’s paper and other work that Gorton has co-authored on the optimal level of information that different types of bank stakeholders require. If I understood Holmstrom correctly, he seemed to extend his thesis on the value of being able to trade on an “information insensitive” basis to argue that “opacity” in the debt market is something to be embraced rather than eliminated. I struggle with embracing opacity in this way but that in no way diminishes the validity of the distinction he draws between the relative value of information in debt and equity markets and its impact on liquidity.

Gorton and Zhang emphasise the importance of deposit insurance in underwriting confidence in and the liquidity of bank deposits as the primary form of private money. I think that is true in the sense that most bank deposit holders do not understand the mechanics of the preferred claim they have on the assets of the bank they have lent to but it seems to me that over-collateralisation is equally as important in underwriting the economics of bank deposits.

If I have not lost you at this point, you can explore this question further via this link to a post I did titled “Bank deposits – turning unsecured loans to highly leveraged companies into (mostly) risk free assets – an Australian perspective“. From my perspective, the idea that any form of money has to be designed to be “information insensitive” or NQA rings very true.

Insights drawn from a technical analysis of stablecoins and stablecoin issuers.

The paper delves in a reasonable amount of detail into the technicalities of whether stablecoins are economically or legally equivalent to demand deposits and the related question of whether stablecoin issuers might be considered to be banks. The distinction between the economic and the legal status is I think especially useful for understanding how banking regulators might engage with the stablecoin challenge.

The over arching point is that stablecoins that look and function like bank demand deposits should face equivalent levels of regulation. That does not necessarily mean exactly the same set of rules but something functionally equivalent.

One practical outcome of this analysis that I had not considered previously is that they deem Tether to be based on an “equity contract” relationship with its users whereas the other stablecoins they analyse are “debt contracts” (see below). The link between Tether and a money market fund and the risk of “breaking the buck” has been widely canvassed but I had not previously seen the issue framed in these legal terms.

This technical analysis is summarised in two tables (Table 2: Stablecoins and their Contracts as of June 30, 2021 and Table 3: Stablecoins, Redemptions, and Fiat Money as of June 30. 2021) that offer a useful reference point for understanding the mechanics and details of some of the major stablecoins issued to date. In addition, the appendix to the paper offers links to the sources used in the tables.

Lessons to be learned from history

It may have been repeated to the point of cliche but the idea that “those who cannot remember the past are condemned to repeat it” (George Santayana generally gets the credit for this but variations are attributed to Edmund Burke and Sir Winston Churchill) resonates strongly with me. The general argument proposed by Gorton and Zhang is that lots of the ideas being tried out in stablecoin design and DeFi are variations on general principles that were similarly employed in the lightly regulated Free Banking Era but found wanting.

Even if you disagree with the conclusions they draw, the general principle of using economic history to explore what can be learned and what mistakes to avoid remains a useful discipline for any practitioner of the dark arts of banking and money creation.

Summing up in the authors’ own words

The paper is long (41 pages excluding the Appendix) but I will wrap up this post with an extract that gives you the essence of their argument in their own words.

Tony – From the Outside

Conclusion 

The more things change, the more they stay the same. It is still the case that regulation is being outpaced by innovation—thereby creating an uneven playing field—as it is easier and cheaper for more technologically advanced firms to offer similar products and services. 

In this case, it is also true that the problems associated with privately produced money are the same as they were one hundred and fifty years ago. We stress three points from our review of history. First, the use of private bank notes was a failure because they did not satisfy the NQA principle. Second, the U.S. government took control of the monetary system under the National Bank Act and subsequent legislation in order to eliminate the private bank note system in favor of a uniform currency—namely, national bank notes. Third, runs on demand deposits only ended with deposit insurance in 1934. 

Currently, it does not appear that stablecoins are used as money. But, as stablecoins evolve further, the stablecoin world will look increasingly like an unregulated version of the Free Banking Era—a world of wildcat banking. During the Free Banking Era, private bank monies circulated at time-varying discounts based on geography and the perceived risk of the issuing bank. Stablecoin prices are independent of geography but not independent of the perceived risk of their backing assets. If they succeed in differentiating themselves from fiat cryptocurrencies and become used as money, then they will likely trade at time-varying discounts as well. Policymakers have a couple of ways to address this development, and they better get going. 

A bank run in CryptoLand

In my last post I flagged a great article from Marc Rubinstein using MakerDAO to explain some of the principles of Decentralised Finance (DeFi). One of the points I found especially interesting was the parallels that Rubinstein noted between 21st century DeFi and the free banking systems that evolved during the 18th and 19th centuries

I wound up confessing that while I am a long way from claiming any real DeFi expertise, I did believe that it would be useful to reflect on why free banking is no longer the way the conventional banking system operates.

In that spirit, it appears that the IRON stablecoin has the honour of recording the first bank run in cryptoland.

We never thought it would happen, but it just did. We just experienced the world’s first large-scale crypto bank run.

https://ironfinance.medium.com/iron-finance-post-mortem-17-june-2021-6a4e9ccf23f5

No doubt there will be plenty written on this but Matt Levine’s Bloomberg column offers a quick summary of what happened.

The core of an algorithmic stablecoin is that you have some other token that is not meant to be stable, but that is meant to support the stablecoin by being arbitrarily issuable. It doesn’t matter if Titanium is worth $65 or $0.65, as long as you can always issue a few million dollars’ worth of it. But you can’t, not always, and that does matter.

Money Stuff by Matt Levine 18 June 2021

Algorithmic is of course just one approach to stablecoin mechanics. I hope to do a deeper dive into stablecoins in a future post.

Tony – From the Outside

Money and banking in CryptoLand

Marc Rubinstein (Net Interest) recently wrote an interesting post titled “My Adventures in CryptoLand” that I found very helpful in helping me better understand what is going on in this new area of decentralised finance (DeFi). He has followed up with a post titled “Reinventing the Financial System” which explores how MakerDAO is building a “decentralised bank”. I am a bit uncomfortable with applying the term “bank” to the financial entity that MakerDAO is building but I don’t want to derail the discussion with what may be perceived as semantics so I will run wth the term for the purposes of this post.

What is interesting for students of banking is the parallels that Rubinstein notes between MakerDAO and the free banking systems that evolved during the 18th and 19th centuries. Scotland is one of the poster children of this style of banking and we can see a legacy of that system (albeit much more regulated and so not true free banking) in the form of the private bank notes that the three Scottish banks still issue in their own name. He quotes Rune Christensen (founder of MakerDAO) describing the way in which his project accidentally developed a form of fractional reserve banking”

In the very beginning of the project, I remember we didn’t even realise, in the beginning of Maker, that we were essentially just building a protocol that did the same things as fractional reserve banking, did something very similar to how a banking balance sheet works and we were just implementing that as a blockchain protocol. We thought we were doing something completely, totally different from how money usually worked in the traditional sense.” (source)

“Reinventing the Financial System” Marc Rubinstein Net Interest Newsletter, 12 June 2021

This statement should be qualified by the fact that they can only do this (i.e. replicate fractional reserve banking) because the currency of the decentralised bank is a form of money called Dai. Fractional Reserve Banking has proved to be a risky form of financial technology in the conventional banking system which has developed a range of tools to manage that risk (e.g. capital adequacy and liquidity requirements, deposit preference arrangements often coupled with deposit insurance to insulate the “money” part of the bank balance sheet from risk, high levels of supervision and other restrictions on the types of assets a bank can lend against).

MakerDAO has a stabilisation mechanism that employs “smart contracts” that manage the price of Dai by managing its supply and demand. The pros and cons of the various stabilisation mechanisms that underpin stable coins like Dai is a topic for another day.

Rubinstein describes the MakerDAO lending and “money” creation process as follows:

The bank he devised to create his money … works like this:

An investor comes into Maker DAO for a loan. He (yep, usually he) has some collateral he’s happy to keep locked in a vault. Right now, that collateral is usually a crypto asset like Ethereum. For every $100 worth of crypto assets, Maker is typically prepared to lend $66 – the gap adding a buffer of protection against a possible fall in the value of the collateral. Maker accepts the collateral and advances a loan, which it does by issuing its Dai money. 

So what?

At this stage I am not sure where this is headed. It is not clear, for example, if the purpose of this “bank” is simply to create more Dai via trading in crypto-assets or to build something that translate outside CryptoLand. Rubinstein quotes Rune Christensen himself stating that

I don’t think that it will necessarily replace everything… The traditional financial system will actually largely remain the way it is. It will just replace certain parts of it that right now are really bad and really old… those things will be replaced with DeFi and blockchain, but the actual bank itself probably will remain.”

I am a long way from figuring this out but Marc’s post is I think worth reading for anyone who want to understand where these new (or possibly reinvented) forms of finance are heading. To the extent that DeFi is reinventing things that have been tried before, I suspect it would be useful to reflect on why free banking is no longer the way the conventional banking system operates. That is another topic for another day.

Tony – From the Outside

Tether offers a bit more detail on the composition of its reserves

… but Jemima Kelly at FT Alphaville remains a sceptic. I think the FT headline is a bit harsh (“Tether says its reserves are  backed by cash to the tune of . . .  2.9%”). Real banks don’t hold a lot of “cash” either but the securities they hold in their liquid asset portfolios will tend to be a lot better quality than the securities that Tether disclosed.

The role of real banks in the financial system may well be shrinking but the lesson I take from this FT opinion piece is that understanding the difference between these financial innovations and real banks remains a useful insight as we navigate the evolving new financial system.

Let me know what I am missing …

Tony – From the Outside

Digital money – FT Alphaville

FT Alphaville is one of my go to sources for information and insight. The Alphaville post flagged below discusses the discussion paper recently released by the Bank of England on the pros and cons of a Central Bank Digital Currency. It is obviously a technical issue but worth at least scanning if you have any interest in banking and ways in which the concept of “money” may be evolving.

Read on ftalphaville.ft.com/2020/03/12/1584053069000/Digital-stimulus/

Banks may be asked to absorb more than their contractual share of the economic fallout of the Coronavirus

We have already seen signs that the Australian banks recognise that they need to absorb some of the fallout from the economic impact of the Coronavirus. This commentator writing out of the UK makes an interesting argument on how much extra cost banks and landlords should volunteer to absorb.

Richard Murphy on tax, accounting and political economy
— Read on www.taxresearch.org.uk/Blog/2020/03/04/banks-and-landlords-have-to-pick-up-the-costs-of-the-epidemic-to-come-if-the-the-economy-is-to-have-a-chance-of-surviving/

I am not saying banks should not do this but two themes to reflect on:

1) This can be seen as part of the price of rebuilding trust with the community

2) it reinforces the cyclicality of the risk that bank shareholders are required to absorb which then speaks to what is a fair “Through the Cycle” ROE for that risk

I have long struggled with the “banks are a simple utility ” argument and this reinforces my belief that you need a higher ROE to compensate for this risk

Tony

Too much information

This post is possibly (ok probably) a bit technical but touches on what I think is an important issue in understanding how the financial system operates. The conventional wisdom as I understand it is that markets thrive on information. I think that is true in some cases but it may not be necessarily true for all markets. If the conventional wisdom is wrong then there are important areas of market and bank regulation that probably need to be reconsidered.

I have written on this topic before in relation to papers by Gary Gorton and Bengt Holmstrom. These papers developed an analytical argument in favour of certain assets (or markets) being “information insensitive”. That argument makes intuitive sense to me and I have used these arguments in a couple of previous posts; one titled “Why banks are different” and another titled “Deposit insurance and moral hazard“.

I hope to eventually do a longer piece where I can bring all these ideas together but the purpose today is simply to flag an interesting post (and associated paper) I came across that offers some empirical evidence in favour of the thesis. The post is titled “(When) Does Transparency Reduce Liquidity” and you can find the paper of the same name here.

This extract from the blog post I think captures the key ideas:

“To sum up, our findings can be grouped under two headings. The first is that more information in financial markets is not always beneficial. It can reduce rather than increase trading and liquidity.

The second is that one size does not fit all in terms of gauging the impact of transparency on liquidity. For the safest of the MBS securities, the impact of transparency is negligible, while for the riskiest, transparency enhances liquidity. It is in the broad middle of the risk spectrum that liquidity is negatively impacted.

Our findings ought to be of interest to regulators on both sides of the Atlantic. In order to promote transparency and to bolster market discipline, supervisors have imposed various loan-level requirements in both Europe and the United States. The assumption seems to be that more transparency is always a good thing.

In such a climate, there has been insufficient investigation or understanding of the effects, including the negative effects, of such requirements on MBS market liquidity. Our work, we believe, begins to put this right.

“(When) Does Transparency Reduce Liquidity?” by professors Karthik Balakrishnan at Rice University, Aytekin Ertan at London Business School, and Yun Lee at Singapore Management University and London Business School. Posted on “The CLS Blue Sky Blog” October 30 2019

Summing up

If this thesis is correct (i.e. that there are certain types of funding that should be “information insensitive” by design and that it is a mistake to apply to money markets the lessons and logic of stock markets) then this has implications for:

  • thinking about the way that bank capital structure should be designed,
  • questions like deposit preference and deposit insurance, and
  • how we reconcile the need to impose market discipline on banks while ensuring that their liquidity is not adversely impacted.

I have not as yet managed to integrate all of these ideas into something worth sharing but the post referenced above and the associated paper are definitely worth reading if you are engaged with the same questions. If you think I am missing something then please let me know.

Tony

The rise of digital money

Given the central role that money plays in our economy, understanding how the rise of digital money will play out is becoming increasingly important. There is a lot being written on this topic but today’s post is simply intended to flag a paper titled “The Rise of Digital Money” that is one of the more useful pieces of analysis that I have come across. The paper is not overly long (20 pages) but the authors (Tobias Adrian and Tommaso Mancini-Griffoli) have also published a short summary of the paper here on the VOX website maintained by the Centre for Economic Policy Research.

Part of the problem with thinking about the rise of digital money is being clear about how to classify the various forms. The authors offer the following framework that they refer to as a Money Tree.

Adrian, T, and T Mancini-Griffoli (2019), “The rise of digital currency”, IMF Fintech Note 19/01.

This taxonomy identifies four key features that distinguish the various types of money (physical and digital):

  1. Type – is it a “claim” or an “object”?
  2. Value – is it the “unit of account” employed in the financial system, a fixed value in that unit of account, or a variable value?
  3. Backstop – if there is a fixed value redemption, is that value “backstopped” by the government or does it rely solely on private mechanisms to support the fixed exchange rate?
  4. Technology – centralised or decentralised?

Using this framework, the authors discuss the rise of stablecoins

“Adoption of new forms of money will depend on their attractiveness as a store of value and means of payment. Cash fares well on the first count, and bank deposits on both. So why hold stablecoins? Why are stablecoins taking off? Why did USD Coin recently launch in 85 countries,1 Facebook invest heavily in Libra, and centralised variants of the stablecoin business model become so widespread? Consider that 90% of Kenyans over the age of 14 use M-Pesa and the value of Alipay and WeChat Pay transactions in China surpasses that of Visa and Mastercard worldwide combined.

The question is all the more intriguing as stablecoins are not an especially stable store of value. As discussed, they are a claim on a private institution whose viability could prevent it from honouring its pledge to redeem coins at face value. Stablecoin providers must generate trust through the prudent and transparent management of safe and liquid assets, as well as sound legal structures. In a way, this class of stablecoins is akin to constant net asset value funds which can break the buck – i.e. pay out less than their face value – as we found out during the global financial crisis. 

However, the strength of stablecoins is their attractiveness as a means of payment. Low costs, global reach, and speed are all huge potential benefits. Also, stablecoins could allow seamless payments of blockchain-based assets and can be embedded into digital applications by an active developer community given their open architecture, as opposed to the proprietary legacy systems of banks. 

And, in many countries, stablecoins may be issued by firms benefitting from greater public trust than banks. Several of these advantages exist even when compared to cutting-edge payment solutions offered by banks called fast-payments.2 

But the real enticement comes from the networks that promise to make transacting as easy as using social media. Economists beware: payments are not the mere act of extinguishing a debt. They are a fundamentally social experience tying people together. Stablecoins are better integrated into our digital lives and designed by firms that live and breathe user-centric design. 

And they may be issued by large technology firms that already benefit from enormous global user bases over which new payment services could spread like wildfire. Network effects – the gains to a new user growing exponentially with the number of users – can be staggering. Take WhatsApp, for instance, which grew to nearly 2 billion users in ten years without any advertisement, based only on word of mouth!”

“The rise of digital currency”, Tobias Adrian, Tommaso Mancini-Griffoli 09 September 2019 – Vox CEPR Policy Portal

The authors then list the risks associated with the rise of stablecoins:

  1. The potential disintermediation of banks
  2. The rise of new monopolies
  3. The threat to weak currencies
  4. The potential to offer new opportunities for money laundering and terrorist financing
  5. Loss of “seignorage” revenue
  6. Consumer protection and financial stability

These risks are not dealt with in much detail. The potential disintermediation of banks gets the most attention (the 20 page paper explores 3 scenarios for how the disintermediation risk might play out).

The authors conclude with a discussion of what role central banks play in the rise of digital currency. They note that many central banks are exploring the desirability of stepping into the game and developing a Central Bank Digital Currency (CBDC) but do not attempt to address the broader question of whether the overall idea of a CBDC is a good one. They do however explore how central banks could work with stablecoin providers to develop a “synthetic” form of central bank digital currency by requiring the “coins” to be backed with central bank reserves.

This is effectively bringing the disrupters into the fold by turning them into a “narrow bank”. Izabella Kaminska (FT Alphaville) has also written an article on the same issue here that is engagingly titled “Why dealing with fintechs is a bit like dealing with pirates”.

The merits of narrow banking lie outside the scope of this post but it a topic with a very rich history (search on the term “Chicago Plan”) and one that has received renewed support in the wake of the GFC. Mervyn King (who headed the Bank of England during the GFC), for example, is one prominent advocate.

Hopefully you found this useful, if not my summary then at least the links to some articles that have helped me think through some of the issues.

Tony

Bank funding costs and capital structure – what I missed

A recent post looked at a Bank of England paper that offered evidence that the cost of higher capital requirements will be mitigated by a reduction in leverage risk which translates into lower borrowing costs and a decline in the required return equity. My post set out some reasons why I struggled with this finding.

My argument was that,

  • in banking systems where the senior debt rating of banks assumed to be Too Big To Fail is supported by an implied assumption of government support (such as Australia),
  • increasing the level of subordinated debt could reduce the value of that implied support,
  • however, senior debt itself does not seem to be any less risky (the senior debt rating does not improve), and
  • the subordinated debt should in theory be more risky if it reduces the value of the assumption of government support.

Fortunately, I also qualified my observations with the caveat that it was possible that I was missing something. Recent issuance of Tier 2 debt by some Australian banks offers some more empirical evidence that does seem to suggest that the cost of senior debt can decline in response to the issuance of more junior securities and that the cost of subordinated debt does not seem to be responding in the way that the theory suggests.

My original argument was I think partly correct. The prospect of the large Australian banks substantially increasing the relative share of Tier 2 debt in their liability structure has not resulted in any improvement in the AA- senior debt rating of the banks subject to this Total Loss Absorbing Capital requirement. So senior debt does not seem to be any less risky.

What I missed was the impact of the supply demand dynamic in a low interest rate environment where safe assets are in very short supply.

The senior debt in my thesis is no less risky but the debt market appears to be factoring in the fact that the pool of AA- senior debt is likely to shrink relative to what was previously expected. Investors who have been struggling for some time to find relatively safe assets with a decent yield weigh up the options. A decent yield on safe assets like they used to get in the old days would obviously be preferable but that is not on offer so they pay up to get a share of what is on offer.

The subordinated debt issued by these banks might be more risky in theory to the extent that bail-in is now more credible but if you do the analysis and conclude that the bank is well managed and low risk then you discount the risk of being bailed-in and take the yield. Again the ultra low yield on very safe assets and the shortage of better options means that you probably bid strongly to get a share of the yield on offer.

Summing up. The impacts on borrowing costs described here may look the same as what would be expected if the Modigliani-Miller effect was in play but the underlying driver appears to be something else.

It remains possible that I am still missing something but hopefully this post moves me a bit closer to a correct understanding of how capital structure impacts bank funding costs …

Tony