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)

Whatever it takes

There is a lot going on but this is worth noting. Under old school banking, one of the functions of the central bank is to stand ready to be the Lender of Last Resort to the banks.

Matt Levine’s Bloomberg column today covered a fairly radical extension of this 19 century banking principle with the Fed now creating the capacity to lend directly to business. There are reasons why the US market needs to consider unconventional solutions outside the banking system (big companies in the US tend to be less reliant on bank intermediated finance than is the case in Australia and Europe) but this is still something to note and watch.

Also worth reading John Cochrane’s “The Grumpy Economist” blog which goes into some of the mechanics. Matt Levine’s editor titled his column as “Companies can borrow from the Fed now”. I am not sure how much difference it takes in practice but John makes the point that technically it is the US Treasury doing the lending, not the Fed.

Interesting times

Tony

Confusing capital and liquidity

I have been planning to write something on the relationship between capital and liquidity for a while. I have postponed however because the topic is complex and not especially well understood and I did not want to contribute to the body of misconceptions surrounding the topic. An article in the APRA Insight publications (2020 Issue One) has prompted me to have a go.

Capital Explained

The article published in APRA’s Insight publication under the title “Capital explained” offers a simple introduction to the question what capital is starting with the observation that …

“Capital is an abstract concept and has different meanings in different contexts.

Capital being abstract and meaning different things in different contexts is a good start but the next sentence troubles me.

“In non-technical contexts, capital is often described as an amount of cash or assets held by a company, or an amount available to invest.”

I am not sure that the author intended to endorse this non-technical description but it was not clear and I don’t think it should be left unchallenged, especially when the casual reader might be inclined to take it at face value. The fact that non-technical descriptions frequently state this is arguably a true statement but the article does not clarify that this description is a source of much confusion and seems to be conflating capital and liquid assets.

The source of the confusion possibly lies in double entry bookkeeping based explanations in which a capital raising will be associated with an influx of cash onto a company balance sheet. What happens next though is that the company has to decide what to do with the cash, it is extremely unlikely that the cash just sits in the company bank account. This is especially true in the case of a bank which has cash flowing into, and out of, the balance sheet every day. The influx of one source of funding (in this case equity) for the bank means that it will most likely choose to not raise some alternate form of funding (debt) on that day. The amount of cash it holds will be primarily driven by the liquidity targets it has set which are related to but in no way the same thing as its capital targets.

Time for me to put up or shut up.

How should we think about the relationship between capital and liquidity including the extent to which holding more liquid assets might, as is sometimes claimed, justify holding less capital.

  • Liquidity risk is mitigated by liquidity management, including holding liquid assets, but this statement offers no insight into the extent to which some residual expected or unexpected aspect of the risk still requires capital coverage (All risks are mitigated to varying extents by management but most still require some level of capital coverage)
  • So the assessment that holding more liquid assets reduces the need to hold capital is open to challenge
  • One of the core functions of capital is to absorb any increase in expenses, liabilities, loan losses or asset write downs associated with or required to resolve an underlying risk issue; the bank may need to recapitalise itself to restore the target level of solvency required to address future issues but the immediate problems are resolved without the consumption of capital compromising solvency
  • Liquid assets, in contrast, buy time to resolve problems but they do not in themselves solve any underlying issues that may be the root cause of the liquidity stress.
  • The relationship between liquidity and solvency is not symmetrical; liquidity is ultimately contingent on a bank being solvent, but a solvent bank can be illiquid.
  • While more liquid assets are not a substitute for holding capital, a more strongly capitalised bank is less likely to be subject to the kinds of liquidity stress events that draw on liquid assets so holding more capital relative to peer banks can reduce liquidity risk
  • Being relatively strong matters in scenarios where uncertainty is high and people resort to simple rules (e.g. withdraw funding from the weakest banks; even if that is not true the risk is that other people express that view and it becomes self-fulfilling)
  • It is important to recognise that the focus of relationship between capital and liquidity risk described above is the capital position relative to peer banks and market expectations, not the absolute stand-alone position
  • The “Unquestionably Strong” benchmark used in the Australian banking system to calibrate the overall target operating range for capital in the ICAAP anchors the bank’s Liquidity Risk appetite setting.
  • Expressed another way, the capital requirements of Liquidity Risk are embedded holistically in the capital buffer the target operating range maintains over prudential minimum capital requirements.

It is entirely possible that I am missing something here – I hope not but let me know if you see an error in my logic

Australian government support for banks

The impending transition to an increased level of Loss Absorbing Capital has prompted speculation on whether this means that the assumption of government support embedded in the senior debt rating of the large Australian banks remains appropriate. This speculation is fuelled in part by precedents established in the European Union and United States where the implementation of increased loss absorption requirements has resulted in the assessment of government supportiveness being downgraded.

Standard and Poor’s addressed this question in the Australian context and the short answer is that continued high government support is the probable outcome.

“In our view, this framework does not propose–nor have the authorities more broadly taken–any concrete actions that would suggest reduced government support despite the stated intent to reduce the implicit government guarantee and the perception that some banks are too big to fail”

“Australian Government Support For Banks: Will There Be More Twists In The Tale?, 8 April 2019 – S&P Global RatingsDirect

APRA’s proposed framework for increased loss absorption

Before digging into the detail of why S&P continue to believe the Australian Government will most likely remain “highly supportive” of systemically important banks, it will be useful to quickly revisit the discussion paper APRA published in November 2018 setting out its proposed response to the Financial System Inquiry recommendation that the Government “Implement a framework for minimum loss absorbing and recapitalization capacity in line with emerging international practice, sufficient to facilitate the orderly resolution of Australian authorised deposit-taking institutions (ADIs) and minimize taxpayer support”.

APRA proposed that selected Australian banks (mostly D-SIBs) be required to hold more loss absorbing capital via an increase in the minimum Prudential Capital Requirement (PCR) applied the Total Capital Ratio (TCR) they are required to maintain under Para 23 of APS 110.

“The minimum PCRs that an ADI must maintain at all times are:
(a) a Common Equity Tier 1 Capital ratio of 4.5 per cent;
(b) a Tier 1 Capital ratio of 6.0 per cent; and
(c) a Total Capital ratio of 8.0 per cent.
APRA may determine higher PCRs for an ADI and may change an ADI’s PCRs at any time.”

APS 110 Paragraph 23

This means that banks have discretion over what form of capital they use but it is assumed they will choose Tier 2 capital as the lowest cost way to meet the requirement.

A post I did on APRA’s discussion paper, identified 5 issues posed by APRA’s proposed response including the question “To what extent would the public sector continue to stand behind the banking system once the proposed level of self insurance is in place?”. My assessment at that time was that …

“… the solution that APRA has proposed seems to me to give the official family much greater options for dealing with future banking crises without having to call on the taxpayer to underwrite the risk of recapitalising failed or otherwise non-viable banks.

It does not, however, eliminate the need for liquidity support. ... The reality is that banking systems built on mostly illiquid assets will likely face future crises of confidence where the support of the central bank will be necessary to keep the financial wheels of the economy turning. ….

… the current system requires the central bank to be the lender of last resort. That support is extremely valuable and is another design feature that sets banks apart from other companies. It is not the same however, as bailing out a bank via a recapitalisation.

“Does more loss absorption and “orderly resolution” eliminate the TBTF subsidy”, posted on From The Outside (November 2018)

I noted that the proposed increase in loss absorbing capital would give APRA and the RBA much greater options for dealing with the solvency aspect of any future crisis but my main point in that initial response to the policy proposal was that the need for a liquidity support backstop remained. In my experience, solvency and liquidity are frequently conflated in the public discussion of bail-outs and my point was that recognising that they are not the same facilitates a more sensible discussion of the role of bail-in and government support. The steps APRA is proposing to take to reduce the implied level of government support do not change the fact that the central bank standing ready to act as the Lender of Last Resort (“LOLR”) will remain a design feature of the financial system we have, not a bug.

The distinction between solvency an liquidity is important but, with the benefit of hindsight, I should have paid equal attention to the extent to which the Australian government might still be expected to go beyond liquidity support if required and the way in which the Australian approach to bail-in differs from that being developed in the U.S. and the E.U.

Standard and Poors continues to rate the Australian government as “highly supportive”

Notwithstanding some ambiguity introduced by the government’s response to the FSI recommendation, S&P continue to believe that the Australian government will remain “highly supportive” towards the systemically important private sector banks. They clarify that support in this context means “… the propensity of a government to provide extraordinary support (typically a capital injection) …”.

The factors underpinning S&P’s (admittedly subjective) assessment are:

  • The Australian economy’s dependence on continued access to offshore funding via the Australian banks
  • The potential risk of contagion across the four major banks due to their interconnectedness
  • No evidence of in-principle political or social opposition to government support should it prove necessary
  • APRA’s proposed framework for increased loss absorption does not hinder government support (in contrast to the resolution frameworks adopted in the European Union and the United States where bail-in is a pre-requisite for a government funded bail-out)
  • Notwithstanding the broad range of powers that APRA has for dealing with a stressed financial institution, S&P do not see any clearly laid out framework that would allow senior creditors to be captured by a bail-in
  • A track record of prompt and decisive action to support banks where required.

The ambiguity referenced above stems from the Government’s response to the FSI in which it stated that it “… agrees that steps should be taken to reduce any implicit government guarantee and the perception that some banks are too big to fail”.

My prior post referred to APRA’s proposed solution giving “… the official family much greater options for dealing with future banking crises without having to call on the taxpayer…”. The fact that the government will have the option to use pre-positioned capital instruments to recapitalise failing banks in the future does not necessarily mean that they have forgone the option of using public funds, if that is deemed to be a better (or least worst) option. It is also worth noting that the Government’s response itself does not contemplate eliminating the implicit guarantee and the perception that some banks are too big to fail, simply to reducing them.

What would stop the Government using bail-in to recapitalise a bank?

The interesting question here is what would preclude the government from using the bail-in option, choosing instead to use public funds to recapitalise one or more non-viable banks. So long as investors in these instruments bought them with full knowledge of the downside, there is no obvious reason why they should be protected. The bigger issue seems to be whether the banking system can cope with this particular class of investor temporarily choosing to withdraw from funding Australian banks.

Here I think it is important to distinguish between a constraint on access to senior funding and a constraint on access to the kinds of contingent debt/capital instruments used to meet the Total Loss Absorption Requirement. The history of bond defaults suggests that investors eventually forgive or forget but it is also safer to assume that any banking system subject to bail-in might be temporarily excluded from access to the kinds of contingent convertible debt instruments that were used to recapitalise it.

That I suspect is a manageable scenario provided the recapitalisation of the banking system is sufficient to address any concerns that the senior bond holders may have regarding the solvency and/or viability of the banks impacted. Some degree of over-capitalisation of the banks may be necessary to achieve this and the cost of funding can be expected to increase also. This is part of the price of failure. There is however no in principle reason why bail-in of Additional Tier 1, Tier 2 and Tier 3 capital should impact the senior debt so long as it is clear that senior debt is not subject to the same risk of bail-in.

In the absence of access to Additional Tier 1, Tier 2 or Tier 3 capital, these banks will probably be required to temporarily rely on a greater share of common equity to meet their Total Capital Requirement but that can be regenerated through profit retention. I don’t see the capital rebuilding task being materially different to what would have applied if the bank was initially required to meet its TLAC requirement entirely via CET1 capital (as the RBNZ proposes). This is also where the official family can provide liquidity support with minimal risk of the taxpayer facing a loss. Once the bank has regained the trust of the investors, the option of increasing the share of non CET1 capital in the TLAC mix can be re-established.

The importance of the assumption of government support should not be underestimated

This is a complex topic and one where reasonable people can form different interpretations of the facts so let me know if I am missing something …

Table 1 from the S&P report illustrates that an improvement in the Stand Alone Credit Profile (SACP) of one of the Australian majors is not enough on its own to offset a downgrade in S&P’s assessment of government supportiveness. The SACP of the Australian majors is currently assessed at “a-” with government support translating to a 2 notch improvement in the Issuer Credit Rating (ICR) to “AA-“. If the government support assessment is downgraded, the ICR declines 1 notch to “A+” and is not improved even if the SACP is enhanced to “a”.

Tony (From the Outside)

“The End of Alchemy” by Mervyn King

Anyone interested in the conceptual foundations of money and banking will I think find this book interesting. King argues that the significant enhancements to capital and liquidity requirements implemented since the GFC are not sufficient because of what he deems to be fundamental design flaws in the modern system of money and banking.

King is concerned with the process by which bank lending creates money in the form of bank deposits and with the process of maturity transformation in banking under which long term, illiquid assets are funded to varying degrees by short term liabilities including deposits. King applies the term “alchemy” to these processes to convey the sense that the value created is not real on a risk adjusted basis.

He concedes that there will be a price to pay in foregoing the “efficiency benefits of financial intermediation” but argues that these benefits come at the cost of a system that:

  • is inherently prone to banking crises because, even post Basel III, it is supported by too little equity and too little liquidity, and
  • can only be sustained in the long run by the willingness of the official sector to provide Lender of Last Resort liquidity support.

King’s radical solution is that all deposits must be 100% backed by liquid reserves which would be limited to safe assets such as government securities or reserves held with the central bank. King argues that this removes the risk/incentive for bank runs and for those with an interest in Economic History he acknowledges that this idea originated with “many of the most distinguished economists of the first half the twentieth century” who proposed an end to fractional reserve banking under a proposal that was known as the “Chicago Plan”. Since deposits are backed by safe assets, it follows that all other assets (i.e. loans to the private sector) must be financed by equity or long term debt

The intended result is to separate

  • safe, liquid “narrow” banks issuing deposits and carrying out payment services
  • from risky, illiquid “wide” banks performing all other activities.

At this point, King notes that the government could in theory simply stand back and allow the risk of unexpected events to impact the value of the equity and liabilities of the banks but he does not advocate this. This is partly because volatility of this nature can undermine consumer confidence but also because banks may be forced to reduce their lending in ways that have a negative impact on economic activity. So some form of central bank liquidity support remains necessary.

King’s proposed approach to central bank liquidity support is what he colloquially refers to as a “pawnbroker for all seasons” under which the  central bank agrees up front how much it will lend each bank against the collateral the bank can offer;

King argues that

“almost all existing prudential capital and liquidity regulation, other than a limit on leverage, could be replaced by this one simple rule”.

which “… would act as a form of mandatory insurance so that in the event of a crisis a central bank would be free to lend on terms already agreed and without the necessity of a penalty rate on its loans. The penalty, or price of the insurance, would be encapsulated by the haircuts required by the central bank on different forms of collateral”

leaving banks “… free to decide on the composition of their assets and liabilities… all subject to the constraint that alchemy in the private sector is eliminated”

Underpinning King’s thesis are four concepts that appear repeatedly

  • Disequilibrium; King explores ways in which economic disequilibrium repeatedly builds up followed by disruptive change as the economy rebalances
  • Radical uncertainty; this is the term he applies to Knight’s concept of uncertainty as distinct from risk. He uses this to argue that any risk based approach to capital adequacy is not built on sound foundations because it will not capture the uncertain dimension of unexpected loss that we should be really concerned with
  • The “prisoner’s dilemma” to illustrate the difficulty of achieving the best outcome when there are obstacles to cooperation
  • Trust; he sees trust as the key ingredient that makes a market economy work but also highlights how fragile that trust can be.

My thoughts on King’s observations and arguments

Given that King headed the Bank of England during the GFC, and was directly involved in the revised capital and liquidity rules (Basel III) that were created in response, his opinions should be taken seriously. It is particularly interesting that, notwithstanding his role in the creation of Basel III, he argues that a much more radical solution is required.

I think King is right in pointing out that the banking system ultimately relies on trust and that this reliance in part explains why the system is fragile. Trust can and does disappear, sometimes for valid reasons but sometimes because fear simply takes over even when there is no real foundation for doubting the solvency of the banking system. I think he is also correct in pointing out that a banking system based on maturity transformation is inherently illiquid and the only way to achieve 100% certainty of liquidity is to have one class of safe, liquid “narrow” banks issuing deposits and another class of risky, illiquid institution he labels “wide” banks providing funding on a maturity match funded basis. This second class of funding institution would arguably not be a bank if we reserve that term for institutions which have the right to issue “bank deposits”.

King’s explanation of the way bank lending under the fractional reserve banking system creates money covers a very important aspect of how the modern banking and finance system operates. This is a bit technical but I think it is worth understanding because of the way it underpins and shapes so much of the operation of the economy. In particular, it challenges the conventional thinking that banks simply mobilise deposits. King explains how banks do more than just mobilise a fixed pool of deposits, the process of lending in fact creates new deposits which add to the money supply. For those interested in understanding this in more depth, the Bank of England published a short article in its Quarterly Bulletin (Q1 2014) that you can find at the following link

He is also correct, I think, in highlighting the limits of what risk based capital can achieve in the face of “radical uncertainty” but I don’t buy his proposal that the leverage ratio is the solution. He claims that his “pawnbroker for all seasons” approach is different from the standardised approach to capital adequacy but I must confess I can’t see that the approaches are that different. So even if you accept his argument that internal models are not a sound basis for regulatory capital, I would still argue that a revised and well calibrated standardised approach will always be better than a leverage ratio.

King’s treatment of the “Prisoner’s Dilemma” in money and banking is particularly interesting because it sets out a conceptual rationale for why markets will not always produce optimal outcomes when there are obstacles to cooperation. This brings to mind Chuck Prince’s infamous statement about being forced to “keep dancing while the music is playing” and offers a rationale for the role of regulation in helping institutions avoid situations in which competition impedes the ability of institutions to avoid taking excessive risk. This challenges the view that market discipline would be sufficient to keep risk taking in check. It also offers a different perspective on the role of competition in banking which is sometimes seen by economists as a panacea for all ills.

I have also attached a link to a review of King’s book by Paul Krugman