Matt Levine on the FTX balance sheet

There is obviously a lot being written about FTX at the moment but Matt Levine continues to be my favourite source of insight in a very complex and confusing corner of the market.

Matt’s latest Money Stuff column, titled “FTX’s Balance Sheet Was Bad”, is I think worth reading to get an understanding of just how bad it seems to be. The link above might be behind the Bloomberg paywall but you can access Matt’s column by signing up to his daily email. The FTT token has been getting a lot of the press to date but this is first place I have encountered a discussion of the role of Serum in this sorry mess …

And then the basic question is, how bad is the mismatch. Like, $16 billion of dollar liabilities and $16 billion of liquid dollar-denominated assets? Sure, great. $16 billion of dollar liabilities and $16 billion worth of Bitcoin assets? Not ideal, incredibly risky, but in some broad sense understandable. $16 billion of dollar liabilities and assets consisting entirely of some magic beans that you bought in the market for $16 billion? Very bad. $16 billion of dollar liabilities and assets consisting mostly of some magic beans that you invented yourself and acquired for zero dollars? WHAT? Never mind the valuation of the beans; where did the money go? What happened to the $16 billion? Spending $5 billion of customer money on Serum would have been horrible, but FTX didn’t do that, and couldn’t have, because there wasn’t $5 billion of Serum available to buy. FTX shot its customer money into some still-unexplained reaches of the astral plane and was like “well we do have $5 billion of this Serum token we made up, that’s something?” No it isn’t!

Matt also draws on a now-infamous April 2022 episode of Bloomberg’s Odd Lots podcast in which he asked Sam Bankman-Fried a question about yield farming, and in the course of his answer SBF said:

You start with a company that builds a box and in practice this box, they probably dress it up to look like a life-changing, you know, world-altering protocol that’s gonna replace all the big banks in 38 days or whatever. Maybe for now actually ignore what it does or pretend it does literally nothing. It’s just a box. So what this protocol is, it’s called ‘Protocol X,’ it’s a box, and you take a token. …

So you’ve got this box and it’s kind of dumb, but like what’s the end game, right? This box is worth zero obviously. … But on the other hand, if everyone kind of now thinks that this box token is worth about a billion dollar market cap, that’s what people are pricing it at and sort of has that market cap. Everyone’s gonna mark to market. In fact, you can even finance this, right? You put X token in a borrow lending protocol and borrow dollars with it. If you think it’s worth like less than two thirds of that, you could even just like put some in there, take the dollars out. Never, you know, give the dollars back. You just get liquidated eventually. And it is sort of like real monetizable stuff in some senses.

Tony – From the Outside

Margin calls …

… seem to be on the increase.

This post by Marc Rubinstein offers a short but detailed summary of what has been going on, why and what it means for markets. Read the whole post but one of the key issues for me is increased procyclicality…

The drawback of a heavily collateralized market, though, is its tendency to inject procyclicality into the system. Periods of market turbulence can drive sharply higher collateral requirements, which can prompt more turbulence if that leads to forced selling – such as we saw in the UK last week.

Marc Rubinstein, “Net Interest” Blog – 8 October 2022

Tony – From the Outside

Molly White on cryptocurrency “market caps” and notional value

Good post from Molly White discussing the topical issue of how the numbers used to describe the rise and fall of the crypto market are constructed. The post is not long and worth reading in full but here are a few extracts.

Molly starts with a bare bones outline of how the valuation numbers you read in the news are typically generated …

To get the dollar value of a pile of crypto tokens, we take the price of that cryptocurrency on an exchange and multiply it by the quantity of tokens in the pile. To get the market cap, we take the price of that cryptocurrency on an exchange and multiply it by the total number of tokens in circulation. To get the total market cap of all cryptocurrencies, we sum up all of their market caps. There are many cryptocurrency exchanges, trackers, defi platforms, and other projects out there that show the market cap of various tokens. Each of them calculates it in roughly this way, although there are variations: some use total supply or fully diluted supply to represent the number of tokens, and some employ various strategies to try to filter outlier data. CoinMarketCap is a popular tracker, and is widely cited in both crypto-specific and mainstream media when referring to specific cryptocurrencies’ market caps and the market cap of crypto as a whole, so I refer to it throughout.

She then discusses three of her primary concerns with crypto valuation

  • price
  • liquidity
  • wash trading ...

…. and most importantly the question of why does this matter

The “market cap” measurement has become ubiquitous within and outside of crypto, and it is almost always taken at face value. Thoughtful readers might see such headlines and ask questions like “how did a ‘$2 trillion market’ tumble without impacting traditional finance?”, but I suspect most accept the number.

When crypto projects are hacked, there are headlines about hackers stealing “$166 million worth” of tokens that in reality amounted to 2% of that amount (around $3 million) after hackers’ attempts to sell illiquid tokens caused the price to crash.15 I know because I’ve written some myself—it’s an easy habit to slip into.

When NFTs are stolen, large numbers are thrown around without any clarity as to whether they are the original prices paid by the victims for the NFTs, the prices netted by the thiefs when flipping them, the floor prices, or some other value.

All of this serves to legitimize cryptocurrency as though it is a much bigger industry than it is, with far more money floating around than there is. It serves to perpetuate the narratives that NFTs are “worth” far more than they could likely fetch at auction, or tend to appreciate in value quickly, encouraging more people to buy in to projects that are likely to result in losses. Stories about “crypto-millionaires” and -billionaires encourage more people to put their real money into the system—something it desperately needs—not realizing that they may be exchanging it for “gains” on a screen that can never translate into reality.

Maybe there will be greater care on the part of the journalists writing the stories you read about the exciting times in the crypto markets and maybe some greater regulation of valuation and disclosure practices – maybe not. In the interim, Molly offers a good introduction to the questions you might ask yourself as you read the news.

Let me know what I am missing

Tony – From the Outside

The Stablecoin TRUST Act

Stablecoin regulation is one of my perennial favourite topics. Yes I know – I need to get out more but getting this stuff right does truly matter. I have gone down this particular rabbit hole more than a couple of times already. This has partly been about the question of how much we can rely on existing disclosure regarding reserves (here and here for example ) but the bigger issue (I think) is to determine what is the right regulatory model that ensures a level playing field with existing participants in the provision of payment services while still allowing scope for innovation and competition.

JP Koning has been a reliable source of comment and insight on the questions posed above (see here and here for example). Dan Awrey also wrote an interesting paper on the topic (covered here) which argues that the a state based regulatory model (such as the money transmitter licensing regime) is not the answer. There is another strand of commentary that focuses on the lessons to be learned from the Free Banking Era of the 19th century, most notably Gorton and Zhang’s paper titled “Taming Wildcat Stablecoins” which I covered here.

Although not always stated explicitly, the focus of regulatory interest has largely been confined to “payment stablecoins” and that particular variation is the focus of this post. At the risk of over-simplifying, the trend of stablecoin regulation appears to have been leaning towards some kind of banking regulation model. This was the model favoured in the “Report on Stablecoins” published in November 2021 by the President’s Working Group on Financial Markets (PWG). I flagged at the time (here and here) that the Report did not appear to have a considered the option of allowing stablecoin issuers to structure themselves as 100% reserve banks (aka “narrow banks”).

Against that background, it has been interesting to see that United States Senator Toomey (a member of the Senate Banking Committee) has introduced a discussion draft for a bill to provide a regulatory framework for payment stablecoins that does envisage a 100% reserve model for regulation. Before diving into some of the detail, it has to be said that the bill does pass the first test in that it has a good acronym (Stablecoin TRUST Act where TRUST is short for “Transparency of Reserves and Uniform Safe Transactions”.

There is not a lot of detail that I can find so let me just list some questions:

  • The reserve requirements must be 100% High Quality Liquid Assets (HQLA) which by definition are low return so that will put pressure on the issuer’s business model which relies on this income to cover expenses. I am not familiar with the details of the US system but assume the HQLA definition adopted in the Act is the same as that applied to the Liquidity Coverage Ratio (LCR) for depositary institutions.
  • Capital requirements are very low (at most 6 months operating expenses) based I assume on the premise that HQLA have no risk – the obvious question here is how does this compare to the operational risk capital that a regulated depositary institution would be required to hold for the same kind of payment services business activity
  • Stablecoin payment issuers do not appear to be required to meet a Leverage Ratio requirement such as that applied to depositary institutions. That might be ok (given the low risk of HQLA) subject to the other questions about capital posed above being addressed and not watered down in the interests of making the payment stablecoin business model profitable.
  • However, in the interest of a level playing field, I assume that depositary institutions that wanted to set up a payment stablecoin subsidiary would not be disadvantaged by the Leverage Ratio being applied on a consolidated basis?

None of the questions posed above should be construed to suggest that I am anti stablecoins or financial innovation. A business model that may be found to rely on a regulatory arbitrage is however an obvious concern and I can’t find anything that addresses the questions I have posed. I am perfectly happy to stand corrected but it would have been useful to see this bill supported by an analysis that compared the proposed liquidity and capital requirements to the existing requirements applied to:

  • Prime money market funds
  • Payment service providers
  • Deposit taking institutions

Let me know what I am missing

Tony – From the Outside

Note – this post was revised on 14 April 2022

  1. The question posed about haircuts applied to HQLA for the purposes of calculating the Liquidity Coverage Ratio requirement for banks was removed after a fact check. In my defence I did flag that the question needed to be fact checked. Based on the Australian version of the LCR, it seems that the haircuts are only applied to lower quality forms of liquid assets. The question of haircuts remains relevant for stablecoins like Tether that have higher risk assets in their reserve pool but should not be an issue for payment stablecoins so long as the reserves requirement prescribed by the Stablecoin TRUST Act continues to be based on HQLA criteria.
  2. While updating the post, I also introduced a question about whether the leverage ratio requirement on depositary institutions might create an un-level playing field since it does not appear to be required of payment stablecoin issuers

Stablecoin regulation

The question of whether, or alternatively how, stablecoins should be regulated is getting a lot of attention at the moment. My bias (and yes maybe I am just too institutionalised after four decades in banking) is that regulation is probably desirable for anything that functions as a form of money. We can also observe that some stablecoin issuers seem to be engaging pro actively with the question of how best to do this. There is of course a much wider debate about the regulation of digital assets but this post will confine itself to the questions associated with the rise of a new generation of money like digital instruments which are collectively referred to as stablecoins.

My last post linked to a useful summary that Bennett Tomlin published laying out what is currently playing out in the USA on the stablecoin regulation front. Tomlin concluded that the future of stablecoins appeared to lie in some form of bank like regulation. J.P. Koning has also collated a nice summary of the range of regulatory strategies adopted by stablecoin issuers to date.

Dan Awrey proposes another model for stablecoin regulation

Against that background, a paper titled “Bad Money” by Dan Awrey (Law Professor at Cornell Law School) offers another perspective. One of the chief virtues of his paper (refer Section III.B) is that it offers a comprehensive overview of the existing state regulatory framework that governs the operation of many of the stablecoins operating as “Money Service Businesses” (MSB). The way forward is up for debate but I think that Awrey offers a convincing case for why the state based regulatory model is not part of the solution.

This survey of state MSB laws paints a bleak picture. MSBs do not benefit from the robust prudential regulation, deposit guarantee schemes, lender of last resort facilities, or special resolution regimes enjoyed by conventional deposit-taking banks. Nor are they subject to the same type of tight investment restrictions or favorable regulatory or accounting treatment as MMFs. Most importantly, the regulatory frameworks to which these institutions actually are subject are extremely heterogeneous and often fail to provide customers with a fundamentally credible promise to hold, transfer, or return customer funds on demand.

Awrey, Dan, Bad Money (February 5, 202o). 106.1 Cornell Law Review 1 (2020); Cornell Legal Studies Research Paper No 20-38
Awrey also rejects the banking regulation model …

… PayPal, Libra, and the new breed of aspiring monetary institutions simply do not look like banks. MSBs are essentially financial intermediaries: aggregating funds from their customers and then using these funds to make investments. They do not “create” money in the same way that banks do when they extend loans to their customers; nor is there compelling evidence to suggest that their portfolios are concentrated in the type of longer term, risky, and illiquid loans that have historically been the staple of conventional deposit-taking banks

… and looks to Money Market Funds (MMFs) as the right starting point for a MSB regulatory framework that could encompass stablecoins

So what existing financial institutions, if any, do these new monetary institutions actually resemble? The answer is MMFs. While MSBs technically do not qualify as MMFs, they nevertheless share a number of important institutional and functional similarities. As a preliminary matter, both MSBs and MMFs issue monetary liabilities: accepting funds from customers in exchange for a contractual promise to return these funds at a fixed value on demand. Both MSBs and MMFs then use the proceeds raised through the issuance of these monetary liabilities to invest in a range of financial instruments. This combination of monetary and intermediation functions exposes MSBs and MMFs to the same fundamental risk: that any material decrease in the market value of their investment portfolios will expose them to potential liquidity problems, that these liquidity problems will escalate into more fundamental bank-ruptcy problems, and that—faced with bankruptcy—they will be unable to honor their contractual commitments. Finally, in terms of mitigating this risk, neither MSBs nor MMFs have ex ante access to the lender of last resort facilities, deposit guarantee schemes, or special resolution regimes available to conventional deposit-taking banks.

In theory, therefore, the regulatory framework that currently governs MMFs might provide us with some useful insights into how better regulation can transform the monetary liabilities of MSBs into good money.

Awrey’s preferred model is to restructure the OCC to create three distinct categories of financial institution

The first category would remain conventional deposit-taking banks. The second category—let’s call them monetary institutions—would include firms such as PayPal that issued monetary liabilities but did not otherwise “create” money and were prohibited from investing in longer-term, risky, or illiquid loans or other financial instruments. Conversely, the third category—lending institutions—would be permitted to make loans and invest in risky financial instruments but expressly prohibited from financing these investments through the issuance of monetary liabilities

Stablecoins would fall under the second category (Monetary Institutions) in his proposed tripartite licensing regime and the regulations to be applied to them would be based on the regulatory model currently applied to Money Market Funds (MMF).

Awrey, Dan, Bad Money (February 5, 2020). 106.1 Cornell Law Review 1 (2020); Cornell Legal Studies Research Paper No 20-38
What does Awrey’s paper contribute to the stablecoin regulation debate?
  • Awrey frames the case for stablecoin regulation around the experience of the Free Banking Era
  • This is not new in itself (see Gorton for example) but, rather than framing this as a lawless Wild West which is the conventional narrative, Awrey highlights the fact that these so called “free banks” were in fact subject to State government regulations
  • The problem with the Free Banking model, in his analysis, is that differences in the State based regulations created differences in the credit worthiness of the bank notes issued under the different approaches which impacted the value of the notes (this is not the only factor but it is the most relevant one for the purposes of the lessons to be applied to stablecoin regulation)

Finally, the value of bank notes depended on the strength of the regulatory frameworks that governed note issuing banks. Notes issued by banks in New York, or that were members of the Suffolk Banking system, for example, tended to change hands closer to face value than those of banks located in states where the regulatory regimes offered noteholders lower levels of protection against issuer default. Even amongst free banking states, the value of bank notes could differ on the basis of subtle but important differences between the relevant requirements to post government bonds as security against the issuance of notes bank notes.

  • If we want stablecoins to reliably exchange at par value to their underlying fiat currency then he argues we need a national system of regulation applying robust and consistent requirements to all issuers of stablecoin arrangements
  • Awrey then discusses the ways in which regulation currently “enhances the credibility of the monetary liabilities issued by banks and MMFs to set up a discussion of how the credibility of the monetary promises of the new breed of monetary institutions might similarly be enhanced
  • He proposes that the OCC be made accountable for regulating these “monetary institutions” (a term that includes other payment service providers like PayPal) but that the regulations be based on those applied to MMFs other than simply bringing them under the OCC’s existing banking regulations
  • The paper is long (90 pages including appendices) but hopefully the summary above captures the essence of it – for me the key takeaways were to:
    • Firstly to understand the problems with the existing state based MSB regulations that currently seem to be the default regulatory arrangement for a US based stablecoin issuer
    • Secondly the issues he raises (legitimate I think) with pursuing the bank regulation based model that some issuers have turned to
    • Finally, the idea that a MMF based regulatory model is another approach we should be considering
I will wrap up with Awrey’s conclusion …

Money is, always and everywhere, a legal phenomenon. This is not to suggest that money is only a legal phenomenon. Yet it is impossible to deny that the law plays a myriad of important and often poorly understood roles that either enhance or undercut the credibility of the promises that we call money. In the case of banks and MMFs, the law goes to great lengths to transform their monetary liabilities into good money. In the case of proprietary P2P payment platforms, stablecoin issuers, and other aspiring monetary institutions, the anti-quated, fragmented, and heterogenous regulatory frameworks that currently, or might in future, govern them do far, far less to support the credibility of their commitments. This state of affairs—with good money increasingly circulating alongside bad—poses significant dangers for the customers of these new monetary institutions. In time, it may also undermine the in-tegrity and stability of the wider financial system. Together, these dangers provide a compelling rationale for adopting a new approach to the regulation of private money: one that strengthens and harmonizes the regulatory frameworks governing monetary institutions and supports the development of a more level competitive playing field. 

Tony – From the Outside

What stablecoins might become

Bennett Tomlin offers a useful summary here of what is currently playing out in the USA on the regulation of stablecoins. His conclusion is that the future of stablecoins lies in some form of bank like regulation.

It is difficult to say exactly how all of this will play out. My intuition is that a new type of banking charter will be created that will allow stablecoin issuers to access Fed master accounts and there will be an expectation that stablecoins will hold their reserves there. It also seems reasonably likely that the Treasury gets its way and stablecoin issuers will need to register with the Treasury. I expect that securities regulations may be part of the cudgel that will be used to help ensure that the only stablecoins are the “approved” stablecoins.

The end result of this will likely be that any stablecoin issuer that wants to continue operating would need to become a bank and is going to have significantly less flexibility with what they can do with their reserves. Those that choose not to register or are not approved are likely to have difficulty accessing the U.S. banking system. They may have trouble servicing redemptions, and may perhaps even find themselves aggressively pursued by regulators.

https://www.coindesk.com/policy/2021/10/20/what-stablecoins-might-become/

Who knows if the end game is a bank charter but the regulatory solution will undoubtedly shape what stablecoins become. The best solution (I think) will recognise that there is in fact a variety of types of stablecoins offering their users different kinds of promises.

If the answer proposed is a bank charter then it will be interesting to see how bank liquidity requirements might apply to a 100% reserved stablecoin arrangement. The kinds of haircuts that bank liquidity rules apply to liquid assets (other than funds held at a central bank) seem to be completely missing in the approaches currently applied in fiat backed stablecoin arrangements.

Tony – From the Outside

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

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

Another reason why monetary authorities might not like stablecoins

Marc Rubinstein’s post (here) on Facebook’s attempt to create an alternative payment mechanism offers a useful summary of the state of play for anyone who has not had the time, nor the inclination, to follow the detail. It includes a short summary of its history, where the initiative currently stands and where it might be headed.

What caught my attention was his discussion of why central banks do not seem to be keen to support private sector initiatives in this domain. Marc noted that Facebook have elected to base their proposed currency (initially the “Libre” but relabelled a “Diem” in a revised proposal issued in December 2020) on a stable coin approach. There are variety of stable coin mechanisms (fiat-backed, commodity backed, cryptocurrency backed, seignorage-style) but in the case of the Diem, the value of the instrument is proposed to be based on an underlying pool of low risk fiat currency assets.

A stable value is great if the aim for the instrument is to facilitate payments for goods and services but it also creates concerns for policy makers. Marc cites a couple of issues …

But this is where policymakers started to get jumpy. They started to worry that if payments and financial transactions shift over to the Libra, they might lose control over their domestic monetary policy, all the more so if their currency isn’t represented in the basket. They worried too about the governance of the Libra Association and about its compliance framework. Perhaps if any other company had been behind it, they would have dismissed the threat, but they’d learned not to underestimate Facebook.”

“Facebook’s Big Diem”, Marc Rubinstein – https://netinterest.substack.com/p/facebooks-big-diem
One more reason why stable coins might be problematic for policy makers responsible for monetary policy and bank supervision?

Initiatives like Diem obviously represent a source of competition and indeed disruption for conventional banks. As a rule, policy makers tend to welcome competition, notwithstanding the potential for competition to undermine financial stability. However “fiat-backed” stable coin based initiatives also compete indirectly with banks in a less obvious way via their demand for the same pool of risk free assets that banks are required to hold for Basel III prudential liquidity requirements.

So central banks might prefer that the stock of government securities be available to fund the liquidity requirements of the banks they are responsible for, as opposed to alternative money systems that they are not responsible for nor have any direct control over.

I know a bit about banking but not a lot about cryptocurrency so it is entirely possible I am missing something here. If so then feedback welcome.

Tony – From the Outside

Why the real economy needs a prudential authority too

Isabella Kaminska (FT Alphaville) offers an interesting perspective on ways in which prudential initiatives in the areas of capital, liquidity and bail-in that have strengthened the banking sector post GFC might be applied to the “real economy”.

The global financial crisis taught us that laissez-faire finance, when left to its own devices, tends to encourage extreme fragility by under capitalising the system for efficiency’s sake and making it far more systemically interdependent.

Pre-2008, banks operated on the thinnest of capital layers while taking extreme liquidity risk due to the presumption that wholesale liquidity markets would always be open and available to them. It was in this way that they saved on capital and liquidity costs and increased their return on equity.  

Regulatory responses to the crisis understandably focused on boosting resilience by hiking capital buffers, liquidity ratios and also by introducing new types of loss absorbing structures. While it’s still too early to claim regulatory efforts were a definitive success, it does seem by and large the measures have worked to stymie a greater financial crisis this time around.

But what the 2008 crisis response may have overlooked is that bolstering banks to protect the economy means very little if the underlying real economy remains as thinly spread and interconnected as the financial sector always used to be.

The assessment that these banking initiatives “means very little” is possibly overstating the case.  The problems we are facing today would be an order of magnitude greater if the banking system was not able to plays its part in the solution.

The core point, however, I think is absolutely on the money, the focus on efficiency comes at the expense of resilience. More importantly, a free market system, populated by economic agents pursuing their own interests shaped by a focus on relatively short term time horizons, does not seem to be well adapted for dealing with this problem on its own. The lessons prudential regulators learned about the limits of efficient markets and market discipline also apply in the real world.

Isabella looks at the way prudential capital and liquidity requirements operate in banking and draws analogies in the real economy. With respect to liquidity, she notes for example,

“… the just-in-time supply chain system can be viewed as the real economy’s version of a fractional reserve system, with reserves substitutable for inventories.  

Meanwhile, the real economy’s presumption that additional inventories can be sourced from third party wholesale suppliers at a price as and when demand dictates, is equivalent to the banking sector’s presumption that liquidity can always be sourced from wholesale markets.

Though there is obviously one important difference.

Unlike the banking sector, the real economy has no lender of last resort that can magically conjure up more intensive care beds or toilet paper at the stroke of a keyboard when runs on such resources manifest unexpectedly.  

So what are our options? Companies could increase their inventories (analogous to holding more liquid assets) or build excess capacity (analogous to building up a capital buffer) but it is very difficult for companies acting independently to do this if their competitors choose the short term cost efficient play and undercut them on price. The Prisoner’s Dilemma trumps market discipline and playing the long game.

Isabella frames the problem as follows:

short-term supply shortages can only be responded to with real world manufacturing capability, which itself is constrained by physical availability To that extent crisis responses can only really take two forms: 1) immediate investment in the build-up of new manufacturing capacity that can address the specific system shortages or, 2) the temporary reallocation of existing resources (with some adaptation cost) to new production purposes.

The problem with the first option is that it is not necessarily time efficient. Not every country has the capability to build two new hospitals from scratch in just 10 days. Nor the capacity to create unexpected supply just-in-time to deal with the problem.

New investment may not be economically optimal either. What happens to those hospitals when the crisis abates? Do they stand empty and idle? Do they get repurposed? Who will fund their maintenance and upkeep if they go unused? And at what cost to other vital services and goods?

Isabella’s proposal …

That leaves the reallocation of existing assets as the only sensible and economically efficient mitigatory response to surge-demand related crises like pandemic flu. But it’s clear that on that front we can be smarter about how we anticipate and prepare for such reallocation shocks. An obvious thing to do is to take a leaf out of banking regulators’ books, especially with regards to bail-inable capital, capital ratios and liquidity profiles.

Isabella offers two examples to illustrate her argument; one is power companies and the other is the health system.

She notes that power utilities manage demand-surge or supply-shock risk with interruptible contracts to industrial clients. She argues that these contracts equate to a type of bail-inable capital buffer, since the contracts allow utilities to temporarily suspend services to clients (at their cost) if and when critical needs are triggered elsewhere and supplies must be diverted.

I think she has a good point about the value of real options but I am less sure that bail-in is the right analogy. Bail-in is a permanent adjustment to the capital structure in which debt is converted to equity or written off. Preferably the former in order to maintain the loss hierarchy that would otherwise apply in liquidation. A contract that enables a temporary adjustment to expenses is a valuable option but not really a bail-in style option.

What she is identifying in this power utility example is more a company buying real options from its customers that reduces operating leverage by enabling the company to reduce the supply of service when it becomes expensive to supply. Companies that have high operating leverage have high fixed costs versus revenue and will, all other things being equal, tend to need to run more conservative financial leverage than companies with low operating leverage. So reduced operating leverage is a substitute for needing to hold more capital.

Isabella then explores the ways in which the liquidity, capital and bail-in analogies might be applied in healthcare. I can quibble with some of the analogies she draws to prudential capital and liquidity requirements. As an example of a capital requirement being applied to health care she proposes that …

“… governments could mandate makers of non-perishable emergency goods (such as medicines, toilet paper, face masks, hand sanitiser) to always keep two-weeks’ worth of additional supply on hand. And companies could also be mandated to maintain some share of total supply chain production capability entirely domestically, making them more resilient to globalised shocks”

 Two weeks supply looks more like a liquidity buffer than a capital buffer but that does not make the ideas any the less worth considering as a way of making the real economy more resilient. The banking system had its crisis during the GFC and the real economy is being tested this time around. There are arguments about whether the changes to banking went far enough but it is clearly a lot better placed to play its part in this crisis than it was in the last. The question Isabella poses is what kinds of structural change will be required to make the real economy more resilient in the face of the next crisis.

Another example of FT Alphaville being a reliable source of ideas and information to help you think more deeply about the world.

Tony (From the Outside)