Banks are pushing for deregulation and roll backs of Dodd-Frank’s regular check-ups on their financial health. We should be worried.
The great financial crisis with its peak in the fall of 2008 was not inevitable; it could and should have been prevented. Had it been, the economy would not have lost trillions of dollars, millions of Americans would have been spared eviction and unemployment, and the U.S.’s vibrant financial sector would have remained intact.
But few saw a crisis of these proportions coming: Almost no one raised red flags when the first mortgage originators filed for bankruptcy, or when a roster of medium-sized banks experienced liquidity shortage. Even when margin calls began putting pressure even on larger financial firms, and credit lines that had been put in place to provide only short-term, stopgap measures were running hot, almost no one sounded alarms.
Every incident was eyed in isolation even as, slowly but surely, stress built in the system as a whole, as it always does in finance, from the weaker, less resilient periphery of mortgage originators to the very core of storied investment banks whose ultimate fall threatened to bring down the entire system.
The 16th of March of this year marked the 10-year anniversary of the marriage between Bear Stearns and JP Morgan Chase, which was arranged and co-financed by the Federal Reserve. It was by no means the beginning of the crisis; rather, it marked the beginning of the end. It was the final stage in which financial firms at the core were still able to keep their heads above water; however, fearing for their own survival, they would extend another lifeline to fellow banks only with government help.
By September, it took a massive government bailout to prevent a financial meltdown.
Of course, the government could have stepped aside and allowed the banking and finance system to selfdestruct. Members of Congress who voted against the Troubled Asset Relief Program (TARP) Act at the time certainly thought it should.
Allowing it to implode would have created a much cleaner slate for rebuilding finance on sound footing just as the collapse of the financial system in the 1930s had. On the downside, no one could say for sure whether the system would recover and what it would cost to get there. Fearing the abyss, the Fed, the Treasury and Congress stepped in and did what it took (to paraphrase then-Fed Chairman Ben Bernanke) to stabilize the financial system which has since returned to making huge profits.
No good deed goes unpunished.
Instead of a new foundation for sound finance, all we got for this massive public intervention was the same old system, merely patched up with rules and regulations to make it more resilient.
Among the most far-reaching of the reform measures was a new set of essentially preventive care measures for the financial sector: annual check-ups for banks beyond a certain size, strategies for designing tests that would make it harder for financial intermediaries to game them, and additional discretionary powers for regulators to impose additional prudential measures on banks in the name of system stability. Given the massive regulatory failure in spotting early signs of trouble and preventing the 2008 crisis, that looked like the least Congress could do to keep Americans safe from financial instability.
Yet, Republicans, along with a breakaway bloc of Democratic senators, have begun to strip away much of the preventive measures in the post-crisis regulatory legislation, known as Dodd-Frank. Following lobbying by the financial industry, the US. Senate just voted to proceed with considering a new bill, which provides that only banks with consolidated assets worth $100 billion or more (up from $50 billion) will be subject to regular stress tests conducted by the Fed; but these checkups will be “periodic” rather than annual, and they will include only two rather than three stress scenarios. Similarly, in the new design, company-run internal stress tests are required now only for firms with more than $50 billion in assets (up from $10 billion). They, too, can dispense with annual checks: periodic ones will do.
This massive act of deregulation will not be accompanied by greater discretion for the Fed to impose supervisory measures on select companies. On the contrary, the Fed’s discretionary powers have been circumscribed in the bill.
Thresholds are always arbitrary; it is simply impossible to find an optimal point that imposes just enough costs on banks and financial institutions to ensure financial stability. But with these new changes, financial stability has been placed on the back burner. Instead we are presented with back-of-the-envelope calculations about the positive effects scaling back regulation will have on credit expansion, and therefore on growth. It’s a dangerous game, least because this calculation does not include the costs of future crises that result from reckless credit expansion.
If financial stability were the goal, as it should be, we might want to do away with asset thresholds altogether and instead empower regulators to diagnose and treat threats to financial instability wherever they find them. No doubt, the financial industry would reject such a move, because it craves regulatory “certainty”, the very reason its lobbyists pushed for the thresholds in the first place. But we should not fool ourselves: Limiting financial preventive care to large banks at the core of the system deprives regulators of the tools they need to diagnose a crisis in the making, and leaves us exactly where we were in the run-up to the last one.
Waiting for the Chinese Bear Stearns
Unregulated, speculative lending markets nearly brought down the global financial system 10 years ago. Now, Western banks are exporting this failed model to the developing world.
What a difference a decade makes’, mused Mark Carney, the head of the Financial Stability Board (FSB), in a recent speech. Carney was measuring, and applauding, regulatory progress since shadow banking brought Bear Stearns down in March 2008 and Lehman Brothers six months later, and since 2013, when he warned that shadow banking in developing and emerging countries (DECS) was the threat to global financial stability. A lot has changed since.
Shadow banking is no longer used pejoratively. The IMF recently noted that DEC shadow banking ‘might yield greater efficiencies and risk sharing capacity. In scholarly and policy literature, DEC shadow banking is portrayed as an activity confined by national borders, connected closely to banks that move activities in the shadows, circumventing regulation or financial repression, complementary to traditional banks that underserve (SME) entrepreneurs, be it because of market imperfections or the priorities of the developmental state (China).
Another C is relevant for China: constructed by the Chinese state as a quasi-fiscal lever. After Lehman, China’s fiscal stimulus involved encouraging local governments to tap shadow credit, often from large state-owned banks through local Government Financing Vehicles; Yet systemic risks pale in comparison to those that gave us the Bear Sterns and Lehman moments, since (a) complex securitization and wholesale funding markets are (still) absent and (b) DECS have preserved autonomy to design regulatory regimes proportional to the risks posed by shadow banks important to economic development. At worst, DECs may have to backstop shadow credit creation, just like high-income countries did after Lehman’s collapse.
The ‘viable alternative’ story has one shortcoming. It stops short of theorizing shadow banking as a phenomenon intricately linked to financial globalization. In so doing, it misses out a recent development.
The global agenda of reforming shadow banking has morphed into a project of constructing resilient market-based finance that seeks to organize DEC financial systems around securities markets. The project re-invigorates a pre-crisis plan designed by G8 countries, led by Germany’s central bank, the Bundesbank, together with the World Bank and the IMF, to promote local currency bond markets, a plan that G20 countries endorsed in 2011. As one Bundesbank official put it then: “more developed domestic bond markets enhance national and global financial stability. Therefore, it is not surprising that this is a topic which generates an exceptional high international consensus and interest even beyond the G20.”
Deeper local securities markets, it is argued, would (a) reduce DEC dependency on short-term foreign currency debt by (b) tapping into growing demand from foreign institutional investors and their asset managers while (c) expanding the investor base to domestic institutional investors that could act as a buffer, increasing DEC’s capacity to absorb large capital inflows without capital controls; and (d) reduce global imbalances, since large DECs (for example, China and other Asian countries) would no longer need to recycle savings in US. financial markets. Everyone wins if DECs develop missing (securities) markets.
Despite paying lip service to the potential fragility of capital flows into DEC securities markets, this is a project of policy-engineered financial globalization.
The key to understanding this is in the plumbing. Plumbing, for building and securities markets, holds little to excite the imagination. Until it goes wrong.
The plumbing of securities markets refers to the money markets where securities can be financed. According to the International Monetary Fund (IMF) and the World Bank: “the money market is the starting point to developing… fixed income (i.e. securities) markets.” The institutions refer to a special segment, known as the repo market. Repo is the “plumbing” that circulates securities between asset managers, institutional investors, market-making banks and leveraged investors, “greasing” securities’ liquidity (ease of trading). It allows financial institutions to borrow against securities collateral and to lend securities to those betting on a change in price.
This is why international institutions, from the FSB to the IMF and World Bank, have insisted that DECS seeking to build resilient market-based finance need to (re)model their repo plumbing according to a ‘Western’ blueprint.
The official policy advice coincides with the View of securities markets’ lobbies, as expressed, for instance, by the Asia Securities Industry and Financial Markets Association, in the 2013 India Bond Market Roadmap and the 2017 China’s Capital Markets: Navigating the Road Ahead.
The advice ignores economist Hyman Minsky’s insights on fragile plumbing (and the lesson of the Bear Sterns and Lehman moments). Minsky was deeply interested in the plumbing of financial markets, where he looked for signs of evolutionary changes that would make monetary policy less effective while sowing the seeds of fragile finance.
Fragility, he warned, arises where: ‘the viability of loans mainly made because of collateral, however, depends upon the expected market value of the assets that are pledged. An emphasis by bankers on the collateral value and the expected values of assets is conducive to the emergence of a fragile financial structure’
Western or classic repo plumbing does precisely that. It orients (shadow) bankers towards the daily market value of collateral. For both borrower and lender, the daily market value of the security collateral is critical: the borrower does not want to leave more collateral with the lender than the cash it has borrowed, and vice-versa. This is why repo plumbing enables aggressive leverage during good times, when securities prices go up, the borrower gets cash/securities back, and can borrow more against them to buy more securities, drive their price up etc. Conversely, when securities prices fall, borrowers have to find, on a daily basis, more cash or more collateral.
Shadow bankers live with daily anxieties. One day, they may find that the repo supporting their securities portfolios is no longer there, as Bear Stearns did. Then they have to firesale collateral, driving securities’ prices down, creating more funding problems for other shadow bankers until they fold, as Lehman Brothers did.
It was such destabilizing processes that prompted the FSB to identify repos as systemic shadow markets that need tight regulation in 2011. Since then, regulatory ambitions to make the plumbing more resilient have been watered down significantly, as the global policy community turned to the project of constructing market-based finance.
Paradoxically, when the Bundesbank advises DECS to make (shadow) bankers more sensitive to the daily dynamic of securities markets, it ignores its own history. Two decades ago, finance lobbies pressured the Bundesbank to relax its strong grip on German repo markets. The Bundesbank resisted because it believed only tight control would safeguard financial stability and monetary policy effectiveness. Eventually, the Bundesbank abandoned this Minsky-like stance because it worried other Euro-area securities would be more attractive for global investors.
Since the 1980s, the policy engineering of liquid securities markets has been a project of promoting shadow plumbing, first in Europe and the US, now in DECs. Take China. Since 2009, Chinese securities markets have grown rapidly to become the third largest in the world, behind the US and Japan. Such rapid growth reflects policies to re-organize Chinese shadow banking into market-based finance, driven by a broader renminbi (RMB, China’s currency) internationalization strategy that views deep local securities markets as a critical pillar. The repo plumbing of Chinese securities markets expanded equally fast, to around US$ 8 trillion by June 2017. Chinese plumbing is now roughly similar in volumes to European and US repo markets, when in 2010 it was only a fifth of those markets. Since then, Chinese (shadow) banks increased repo funding from 10% to 30% of total funding.
Yet China’s repo is fundamentally different. Legal and market practice there does not force the Chinese (shadow) banker to care about, or to make profit from, daily changes in securities prices. Without daily collateral valuation practices, the “archaic” regime makes for patient (shadow) bankers and more resilient plumbing. This is the case in most DEC countries.
The pressure is on China to open repo markets to foreign investors and to abandon “archaic” rules if it wants RMB internationalization. While China may be able to resist such pressures, it is difficult to see how other DECs will. The global push for market-based finance prepares the terrain for organizing international development interventions via securities markets, as suggested by the growing popularity of green bonds, bond markets for infrastructure, impact investment and digital financial inclusion approaches to poverty reduction. After all, the new mantra is “development’s future is finance, not foreign aid.”
In sum, the shadow-banking-into-resilient-market based-finance agenda seeks to define the terms on which DEC countries join the global supply of securities. It silently threatens the monetary power of DEC countries to manage capital flows and the effects of global financial cycles, a hard-fought victory to weaken the political clout of what Jagdish Bhagwati termed the “Wall Street-Treasury complex” that successfully pressured DECs to open their capital accounts.
This policy-engineered financial globalization seeks a clean break from “the engineered industrialization” that involved capital controls, bank credit guided by the priorities of industrial strategies and competitive exchange rate management.
Instead, it seeks to accelerate the global diffusion of the architecture of US. securities markets and their plumbing, despite well-documented fragilities and contested social efficiency.
Questions of sustainability, credit creation and growth should not be left to securities markets. Carefully designed developmental states, historical experience suggests, work better.