FIN 683 Financial Institutions Management Liquidity Management and Deposit Insurance Professor Robert B.H. Hauswald Kogod School of Business, AU Bank Runs • Can arise due to concern about: – Bank solvency – Failure of a related FI – Sudden changes in investor preferences • Demand deposits are first come, first served – Depositor’s place in line matters • Where do bank runs occur these days? – why? • Bank panic: Systemic or contagious bank run 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 2 Liquidity Risk • Faced by all FIs: trading short-term claims – deposits, CDs, interbank: reason? • High exposure – Depository institutions – Loss of confidence in bank-to-bank lending affects liquidity in other markets • Regulation: how can you control a risk which is – impossible to define – hard to measure? 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 3 Liquid Asset Management • Examples: T-bills, T-notes, T-bonds • Requirements differ across FIs and across countries – Benefits of holding large quantities of liquid assets – Costs of holding liquid assets • Regulatory requirements for minimum levels of liquid assets 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 4 Liquid Asset Regulation • Monetary policy: multiplier effect of changes in reserve requirements • Taxation: noninterest bearing reserves represent transfer of a resource to the central bank. – Higher inflation rate increases this “tax” burden – Note DI responses such as sweep programs • Liquid assets ratio – Cash and government securities in countries such as U.K. – Similar case for U.S. life insurance companies (regulated at state level) – U.S. banks: Cash-based, but banks view government securities as secondary, or buffer, reserves 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 5 Return-Risk Trade-off • Cash immediacy versus reduced return • Constrained optimization – Privately optimal reserve holdings – Regulator imposed reserve holdings • Regulation: incremental reserve requirements for transaction accounts: – First $10.3 million 0.0% – $10.3 million to $44.4 million 3.0% – Over $44.4 million 10.0% 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 6 Computation Period • Computation period runs from a Tuesday to a Monday, 14 days later. – Average daily reserves are computed as a fraction of the average daily deposits over the period. – This means that Friday deposit figures count 3 times in the average for each week. • In the past, “Weekend Game” • Sweep accounts 3/2/2016 18-7 Liquidity and Liability Management © Robert B.H. Hauswald Maintenance Period • The reserve maintenance period, begins 17 days after the end of the computation period – or 30 days after the start of the computation period • Lagged reserve accounting as of July 1998 – Previously, contemporaneous (2-day lag) – Benefits of lagged reserve accounting 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 8 Undershooting/Overshooting • Allowance for up to a 4% error in average daily reserves without penalty – Surplus reserves required for next 2-week period • Undershooting by more than 4% penalized by a 2% markup on rate charged against shortfall • Frequent undershooting likely to attract scrutiny by regulators 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 9 Undershooting • Two options at end of the maintenance period – Liquidate assets – Borrow reserves: Fed funds, repurchase agreements • Discount Window: reserve shortfalls in the past – Discount window borrowing at a rate lower than fed funds target – January 2003, rate increased on discount window lending and terms eased – Primary credit 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 10 Overshooting • First 4 percent can be carried forward to next period: rarely happens • Excess reserves typically low due to opportunity costs: what is it? – Impact of Fed’s liquidity enhancement measures (late 2008) offset by – introduction of interest payments on reserve holdings: no longer any opportunity cost to excess reserves 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 11 Liquidity Management • Important role of securities portfolio in liquidity management • Securitization and loan sales – Risk during crisis: Fire-sale prices • Liquidity management as a knife-edge problem – the mirage of external liquidity provision: lender of last resort and its costs • Changes in technology alter the problem – Check Clearing For the 21st Century Act 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 12 Funding Risk versus Cost Funding Cost Funding Risk 18-13 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald Liability Management • Note the tradeoff between funding risk and funding cost – Demand deposits are a source of cheap funds – but there is high risk of withdrawal – NOW accounts: adjust rate, implicit rate, and minimum balance requirements • What about other liquidity sources? – what are the tradeoffs? 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 14 Fed Funds and Repos • Interbank market for excess reserves – 90% have maturities of 1 day • Fed funds rate very variable: demand and supply – Very volatile prior to 1998 under contemporaneous reserve accounting • Rollover risk: extreme during 2008-2009 crisis • Repurchase Agreements: collateralized fed funds transactions backed by government securities − more difficult to arrange than simple fed funds loans 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 15 Historical Trends • Since 1960, ratio of liquid to illiquid assets has fallen from 44% to about 18.8% in 2009 – but, loans themselves have also become more liquid – Securitization and sales of DI loans • Since 1960s, a shift away from sources of funds that have a high risk of withdrawal – but the core problem remains: – so, same old story: 3/2/2016 Liquidity and Liability Management © Robert B.H. Hauswald 16 Intermediaries are Special • Banks are special: intermediaries – reduce informational frictions through – screening, monitoring, and contracting • But: acquire information monopoly – reducing one friction, creating another one – competition is imperfect – moral hazard in banking: regulation • Moral hazard and holdup: systemic risk 3/2/2016 Bank Runs and Systemic Risk © Robert B.H. Hauswald 17 Liquidity Risk • Definition: asset owner unable to recover full value of asset when sale desired, or – for borrower, that credit is not rolled over • Alternative definition – risk of being unable to satisfy claims without impairment of financial or reputational capital • Defining liquidity mathematically: L1=Pi/P*; L2=∑ i=0…n Pi/P*, L3=E(P)/P* where P* is full value price and Pi is realised price • Bank liquidity – ability of institution to meet obligations under normal business conditions 3/2/2016 Bank Runs and Systemic Risk © Robert B.H. Hauswald 18 Liquidity Risk Leads to 3/2/2016 Bank Runs and Systemic Risk © Robert B.H. Hauswald 19 Spillovers and Externalities • Bank runs can serve a useful purpose – how? – contagion has more serious consequences • FDIC created in 1933 • Securities Investors Protection Corporation (SIPC) created in 1970 • Pension Benefit Guaranty Corporation (PBGC) created in 1974 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 20 Creditors May be Fooled by Accounting Façade that Weak Banks Erect to Keep Capital Looking Good Long After it is First Exhausted 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 21 A Run on A Bank 3/2/2016 Bank Runs and Systemic Risk © Robert B.H. Hauswald 22 FDIC: The Past • FDIC created in wake of banking panics 1930-1933 – 10,000 failed commercial banks – Original coverage was $2,500, now $250,000 – Between 1945-1980, FDIC worked well • Failures accelerated in 1980 – why? – open question: is (some) failure good? 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 23 FDIC: The Present • In 1991: Borrowed $30 billion from Treasury and still generated a $7 billion deficit – FDIC Improvement Act 1991 • FDIC reserves in March 2008: 52.8 billion • Sep 2009, reserves were at a deficit of $8.2bn – Rate increases – Prepayments – $500 billion in additional funding via the Treasury Department 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 24 Causes of Depository Fund Insolvency • Financial and economic environment – Rise in interest rates – Collapse in oil, real estate, and commodity prices – Increased competition: domestic and foreign • Late 2000s: – housing market collapse – demise of high profile FIs – mortgaged, consumer loan defaults 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 25 Insurance Problem: Moral hazard • Todd buys theft insurance for his laptop. – Because he buys the insurance, he is more likely to leave the laptop in his car. • Ideally, he would like to commit to not leaving the computer in his car. – Sometimes but not always we can contract on it – what do insurance companies do? • Do we have a moral hazard problem with deposit insurance? 3/2/2016 Banking Regulation © Robert B.H. Hauswald 26 Of Course! • Marc is the manager of a Springfield S&L. – Marc pays higher interest than a bigger and safer bank claiming his small size helps him cut costs. – Springfield has deposit insurance (100%). • Todd puts his money on deposit with Springfield. – Springfield lends money to a dodgy financial economist teaching at Springfield State University at a higher rate. – When there is no default, everyone wins. – When there is a default, Todd still gets paid. • Without insurance, Todd would not invest if he saw Springfield’s risky lending behavior. 3/2/2016 Banking Regulation © Robert B.H. Hauswald 27 Moral Hazard • Deposit insurance encouraged underpricing of risk and reduced depositor discipline – one-way bet: excessive risk taking – what disciplining force is missing? • Premiums not linked to risk: political economy – Role of implicit premiums • Inadequate monitoring: bank examination • Prompt Corrective Action (1992) 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 28 Crunch Time • Trade-off: Moral Hazard vs. Bank Run Risk – one as bad as the other: where have we come down? – EU example: industry-run insurance schemes • Insurance was not actuarially fairly priced – Reduced incentive for runs: reduced incentives for depositors to monitor DIs – Increased moral hazard. • FDICIA 1993 intended to increase stockholder, depositor, and regulator discipline 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 29 Controlling DI Risk Taking • Stockholder discipline – Links insurance premiums to risk – option analysis similar to default probability • Practical problems in applying option pricing to insurance premiums – DI’s asset values and risk are not easily observable – FDIC adopted risk-based premiums 1993 • Split in industry: who is against? who is for? 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 30 Risk-Based Deposit Insurance • Categories and concentrations of assets • Categories and concentrations of liabilities – Insured, uninsured, contingent, noncontingent • Other factors that affect probability of loss • Deposit insurer’s revenue needs • Since Jan 2007, FDIC calculating risk premia in more a aggressive risk-based manner – Basel II with its own problems 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 31 Risk Categories & Initial Assessment Rates * Assessment rates are in cents per $100 of deposits 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 32 Consequences • Increased capital requirements, stricter DI closure rules – Controls forbearance – Requires lower leverage • Five capital zones – Prompt corrective action • Criticisms of – inadequate depositor discipline – who said inadequate supervision? 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 33 Depositor Discipline • Insurance cap can be bypassed by – altering structure of deposit funds and – spreading deposits across banks • Higher interest rates provided incentive to deposit in riskier banks, up to coverage limit • Limits on brokered deposits • TARP: Deposit coverage cap raised to $250,000 • Implicit 100% coverage from “too big to fail” 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 34 Failure Resolution Post-FDICIA • In January 1995, FDICIA required leastcost resolution – Systemic risk exception – Criticisms related to “too big to fail” remain – Insured depositor transfer (IDT) or “haircut” method encourages depositor vigilance 3/2/2016 19-35 Deposit Insurance © Robert B.H. Hauswald Regulatory Discipline • Two major weaknesses in regulatory practices: – Frequency and thoroughness of examinations – Forbearance for weakly capitalized banks pre-1991 • Examinations: independent audits – Improved accounting standards including market valuation of assets and liabilities – Annual on-site examination of every bank • Capital forbearance: Prompt Corrective Action – Transition to rules rather than discretion 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 36 Lender of Last Resort • Traditionally: central bank acts as lender of last resort through discount window to problem banks – Short-term, non-permanent: “need to borrow basis” – Requires high-quality liquid assets as collateral • Implemented in January 2003: – Primary credit available on short-term basis even to sound banks – Secondary credit (seasonal program) – Easing of availability but with increased rate 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 37 Discount Window • Unprecedented steps taken after 9/11 to ease liquidity – unfortunate because? • Not permanent support for unsound banks – where does that come from? • Loans to troubled banks limited to no more than 60 days in any 120 day period – unless authorized by FDIC and institution’s primary regulator 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 38 Why Can’t Government Officials Rely on the Market to Tell Them When an FSF is Truly Dead? Government Guarantees Negate the Pin-Prick Test 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 39 Bank Runs only Occur in Developing Countries 3/2/2016 Bank Runs and Systemic Risk © Robert B.H. Hauswald 40 Other Guaranty Programs • National Credit Union Administration provides up to $250,000 coverage – Lower risk due to asset diversification – Substantial portion of assets in form of government securities rather than mortgages • Changes in Deposit Insurance Reform Act of 2005 apply to NCUIF-insured credit unions as well 3/2/2016 Deposit Insurance © Robert B.H. Hauswald 41
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