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April 13, 2016
Putting the MetLife Decision into an Economic Context
In a recently released decision, a U.S. district court has ruled that the Financial Stability Oversight Council's (FSOC's) decision to designate MetLife as a potential threat to financial stability was "arbitrary and capricious" and rescinded that designation. This decision raises many questions, among them:
- Why did MetLife sue to end its status as a too-big-to-fail (TBTF) firm?
- How will this decision affect the Federal Reserve's regulation of nonbank financial firms?
- What else can be done to reduce the risk of crisis arising from nonbank financial firms?
Why does MetLife want to end its TBTF status?
An often-expressed concern is that market participants will consider FSOC-designated firms too big to fail, and investors will accord these firms lower risk premiums (see, for example, Peter J. Wallison). The result is that FSOC-designated firms will gain a competitive advantage. If so, why did MetLife sue to have the designation rescinded? And why did the announcement of the court's determination result in an immediate 5 percent increase in the MetLife's stock price?
One possible explanation is that the FSOC's designation guarantees the firm will be subject to higher regulatory costs, but it only marginally changes the likelihood it would receive a government bailout. The Dodd-Frank Act (DFA) requires that FSOC-designated firms be subject to consolidated prudential supervision by the Federal Reserve using standards that are more stringent than the requirements for other nonbank financial firms.
Moreover, the argument that such designation automatically conveys a competitive advantage has at least two weaknesses. First, although Title II of the DFA authorizes the Federal Deposit Insurance Corporation (FDIC) to resolve a failing nonbank firm in certain circumstances, DFA does not provide FDIC insurance for any of the nonbank firm's liabilities, nor does it provide the FDIC with funds to undertake a bailout. The FDIC is supposed to recover its costs from the failed firm's assets. Admittedly, DFA does allow for the possibility that the FDIC would need to assess other designated firms for part of the cost of a resolution. However, MetLife could as easily have been assessed to pay for another firm as it could have been the beneficiary of assessments on other systemically important firms.
A second potential weakness in the competitive advantage argument is that the U.S. Treasury Secretary decides to invoke FDIC resolution only after receiving a recommendation from the Federal Reserve Board and one other federal financial regulatory agency (depending upon the type of failing firm). Invocation of resolution is not automatic. Moreover, a part of any decision authorizing FDIC resolution are findings that at the time of authorization:
- the firm is in default or in danger of default,
- resolution under other applicable law (bankruptcy statutes) would have "serious adverse consequences" on financial stability, and
- those adverse effects could be avoided or mitigated by FDIC resolution.
Although it would seem logical that FSOC-designated firms are more likely to satisfy these criteria than other financial firms, the Title II criteria for FDIC resolution are the same for both types of firms.
How does this affect the Fed's regulation of nonbank firms?
Secretary of the Treasury Jack Lew has indicated his strong disagreement with the district court's decision, and the U.S. Treasury has said it will appeal. Suppose, however, that FSOC designation ultimately does become far more difficult. How significantly would that affect the Federal Reserve's regulatory power over nonbank financial firms?
Although the obvious answer would be that it would greatly reduce the Fed's regulatory power, recent experience casts some doubt on this view. Nonbank financial firms appear to regard FSOC designation as imposing costly burdens that substantially exceed any benefits they receive. Indeed, GE Capital viewed the costs as so significant that it had been selling large parts of its operations and recently petitioned the FSOC to rescind its designation. Unless systemically important activities are a core part of the firm's business model, nonbank financial firms may decide to avoid undertaking activities that would risk FSOC designation.
Thus, a plausible set of future scenarios is that the Federal Reserve would be supervising few, if any, nonbank financial firms regardless of the result of the MetLife case. Rather, ultimate resolution of the case may have more of an impact on whether large nonbank financial firms conduct systemically important activities (if designation becomes much harder) or the activities are conducted by some combination of smaller nonbank financial firms and by banks that are already subject to Fed regulation (if the ruling does not prevent future designations).
Regardless of how the courts and the FSOC respond to this recent judicial decision, the financial crisis should have taught us valuable lessons about the importance of the nonbank financial sector to financial stability. However, those lessons should go beyond merely the need to impose prudential supervision on any firms that are systemically important.
The cause of the financial crisis was not the failure of one or two large nonbank financial firms. Rather, the cause was that almost the entire financial system stood on the brink of collapse because almost all the major participants were heavily exposed to the weak credit standards that were pervasive in the residential real estate business. Yet if the real problem was the risk of multiple failures as a result of correlated exposures to a single large market, perhaps we ought to invest more effort in evaluating the riskiness of markets that could have systemic consequences.
In an article in Notes from the Vault and other forums, I have called for systematic end-to-end reviews of major financial markets starting with the origination of the risks and ending with the ultimate holder(s) of the risks. This analysis would involve both quantitative analysis of risk measures and qualitative analysis of the safeguards designed to reduce risk.
The primary goal would be to identify and try to correct weaknesses in the markets. A secondary goal would be to give the authorities a better sense of where problems are likely to arise if a market does encounter problems.
April 11, 2016
The Rise of Shadow Banking in China
China's banking system has suffered significant losses over the past two years, which has raised concerns about the health of China's financial industry. Such losses are perhaps not all that surprising. Commercial banks have been increasing their risk-taking activities in the form of shadow lending. See, for example, here, here, and here for some discussion of the evolution of China's shadow banking system.
The increase in risk taking by banks has occurred despite a rapid decline in money growth since 2009 and the People's Bank of China's efforts to limit credit expansions to real estate and other industries that appear to be over capacity.
One area of expanded activity has been investment in asset-backed "securities" by China's large non-state banks. This investment has created potentially significant risks to the balance sheets of these institutions (see the charts below). Using the micro-transaction-based data on shadow entrusted loans, Chen, Ren, and Zha (2016) have provided theoretical and empirical insights into this important issue (see also this Vox article that summarizes the paper).
Recent regulatory reforms in China have taken a positive step to try to limit such risk-taking behavior, although the success of these efforts remains to be seen. An even more challenging task lies ahead for designing a comprehensive and sustainable macroprudential framework to support the healthy functioning of China's traditional and shadow banking industries.
March 15, 2016
Collateral Requirements and Nonbank Online Lenders: Evidence from the 2015 Small Business Credit Survey
Businesses can secure a bank loan by offering collateral—typically a business asset such as equipment or real estate. However, the recently released 2015 Small Business Credit Survey (SBCS) Report on Employer Firms,conducted by seven regional Reserve Banks, found that 63 percent of business owners who had borrowed also used their personal assets or guarantee to secure financing. Surprisingly, the use of personal collateral was common not only among startups. Older and relatively larger small firms (see the following chart) also relied heavily on personal assets.
Source: 2015 Small Business Credit Survey
Note: "Unsure", "None", and "Other" were also options but are not shown on the chart.
Alternative lending options also exercised
Not every small business owner has sufficient hard assets, such as real estate or equipment, that can be used as collateral to secure a traditional bank loan or line of credit. For these circumstances, there are options such as credit cards and products offered by nonbank lenders (mostly operating online) that have less stringent underwriting requirements than banks. Many online nonbank lenders advertise unsecured loans or require only a general lien on business assets, without valuing those business assets.
In the 2015 SBCS, 20 percent of small firms seeking loans or lines of credit applied at nonbank online lenders. These lenders have a good reputation for quick application turnaround, and the collateral requirements can be looser than those applied by traditional lenders. But when borrowers were asked about their overall experience, only a net 15 percent of businesses approved at nonbank online lenders were satisfied (40.6 percent were satisfied and 25.3 percent were dissatisfied). In contrast, small banks received a relatively high net satisfaction score of 75 percent (see the chart).
Source: 2015 Small Business Credit Survey Report on Employer Firms
1 Satisfaction score is the share satisfied with lender minus the share dissatisfied.
2 "Online lenders" are defined as alternative and marketplace lenders, including Lending Club, OnDeck, CAN Capital, and PayPal Working Capital.
3 "Other" includes government loan funds and community development financial institutions.
The survey also showed that high interest rates were the primary reason for dissatisfaction at nonbank online lenders (see the chart).
Source: 2015 Small Business Credit Survey Report on Employer Firms
Note: Respondents could select multiple options. Select responses shown due to low observation count.
Merchant cash advances make advances
Most applicants to nonbank online lenders were seeking loans and lines of credit, but some were seeking a product that tends to be particularly expensive relative to other finance options: merchant cash advances (MCA). MCAs have been around for decades, but their popularity has risen in the wake of the financial crisis. Typically a lump-sum payment in exchange for a portion of future credit card sales, the terms of MCAs can be enticing because repayment seems easier than paying off a structured business loan that requires a fixed monthly payment. Instead, the lender is paid back as the business generates revenue, in theory making cash flow easier to manage.
One potential challenge for users of MCA products is interpreting the repayment terms. Instead of displaying an annual percentage rate (APR), MCAs are usually advertised with a "buy rate" (typically 1.2 to 1.4). For example, a buy rate of 1.3 on $100,000 would require the borrower to pay back $130,000. However, a percentage of the principal is not the same as an APR. The table below compares total interest payments made on a 1.3 MCA versus a 30 percent APR business loan repaid over 12 months and over six months. With a 12-month business loan, a 30 percent APR would equal total interest payments of roughly $17,000. With a six-month business loan, repayment would include about $9,000 in interest.
Because an MCA is structured as a commercial transaction instead of a loan, it is regulated by the Uniform Commercial Code in each state instead of by banking laws such as the Truth in Lending Act. Consequently, the provider does not have to follow all of the regulations and documentation requirements (such as displaying an APR) associated with making loans.
Converting a buy rate into an APR is not straightforward for many potential users, as was made clear in a recent online lending focus group study with small business owners conducted by the Cleveland Fed. When asked what the APR was on a $40,000 MCA that required a repayment of $52,000 (the same as a 1.3 buy rate), their answers were the following: (Product A is the MCA type of product; see the study for exactly how it was presented to respondents.)
Source: Federal Reserve Bank of Cleveland
The correct answer is that "it depends on how long it takes to pay back." For example, if the debt is repaid over six months, the APR would be 110 percent (as this calculator shows).
Nonbank online lenders can fill gaps in the borrowing needs of small business. But there may also be a role for greater clarity to ensure borrowers understand the terms they are signing up for. In a September 2015 speech, Federal Reserve Governor Lael Brainard highlights one self-policing movement already well under way:
Some have raised concerns about the high APRs associated with some online alternative lending products. Others have raised concerns about the risk that some small business borrowers may have difficulty fully understanding the terms of the various loan products or the risk of becoming trapped in layered debt that poses risks to the survival of their businesses. Some industry participants have recently proposed that online lenders follow a voluntary set of guidelines designed to standardize best practices and mitigate these risks. It is too soon to determine whether such efforts of industry participants to self-police will be sufficient. Even with these efforts, some have suggested a need for regulators to take a more active role in defining and enforcing standards that apply more broadly in this sector.
Many, but not all, nonbank online lenders have already signed the Small Business Borrower Bill of Rights. Results from the 2015 Small Business Credit Survey Report on Employer Firms can be found on our website.
May 13, 2014
Today’s news brings another indication that low inflation rates in the euro area have the attention of the European Central Bank. From the Wall Street Journal (Update: via MarketWatch):
Germany's central bank is willing to back an array of stimulus measures from the European Central Bank next month, including a negative rate on bank deposits and purchases of packaged bank loans if needed to keep inflation from staying too low, a person familiar with the matter said...
This marks the clearest signal yet that the Bundesbank, which has for years been defined by its conservative opposition to the ECB's emergency measures to combat the euro zone's debt crisis, is fully engaged in the fight against super-low inflation in the euro zone using monetary policy tools...
Notably, these tools apparently do not include Fed-style quantitative easing:
But the Bundesbank's backing has limits. It remains resistant to large-scale purchases of public and private debt, known as quantitative easing, the person said. The Bundesbank has discussed this option internally but has concluded that with government and corporate bond yields already quite low in Europe, the purchases wouldn't do much good and could instead create financial stability risks.
Should we conclude that there is now a global conclusion about the value and wisdom of large-scale asset purchases, a.k.a. QE? We certainly have quite a bit of experience with large-scale purchases now. But I think it is also fair to say that that experience has yet to yield firm consensus.
You probably don’t need much convincing that QE consensus remains elusive. But just in case, I invite you to consider the panel discussion we titled “Greasing the Skids: Was Quantitative Easing Needed to Unstick Markets? Or Has it Merely Sped Us toward the Next Crisis?” The discussion was organized for last month’s 2014 edition of the annual Atlanta Fed Financial Markets Conference.
Opinions among the panelists were, shall we say, diverse. You can view the entire session via this link. But if you don’t have an hour and 40 minutes to spare, here is the (less than) ten-minute highlight reel, wherein Carnegie Mellon Professor Allan Meltzer opines that Fed QE has become “a foolish program,” Jeffries LLC Chief Market Strategist David Zervos declares himself an unabashed “lover of QE,” and Federal Reserve Governor Jeremy Stein weighs in on some of the financial stability questions associated with very accommodative policy:
You probably detected some differences of opinion there. If that, however, didn’t satisfy your craving for unfiltered debate, click on through to this link to hear Professor Meltzer and Mr. Zervos consider some of Governor Stein’s comments on monitoring debt markets, regulatory approaches to pursuing financial stability objectives, and the efficacy of capital requirements for banks.
By Dave Altig, executive vice president and research director of the Atlanta Fed.
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January 31, 2014
A Brief Interview with Sergio Rebelo on the Euro-Area Economy
Last month, we at the Atlanta Fed had the great pleasure of hosting Sergio Rebelo for a couple of days. While he was here, we asked Sergio to share his thoughts on a wide range of current economic topics. Here is a snippet of a Q&A we had with him about the state of the euro-area economy:
Sergio, what would you say was the genesis of the problems the euro area has faced in recent years?
The contours of the euro area’s problems are fairly well known. The advent of the euro gave peripheral countries—Ireland, Spain, Portugal, and Greece—the ability to borrow at rates that were similar to Germany's. This convergence of borrowing costs was encouraged through regulation that allowed banks to treat all euro-area sovereign bonds as risk free.
The capital inflows into the peripheral countries were not, for the most part, directed to the tradable sector. Instead, they financed increases in private consumption, large housing booms in Ireland and Spain, and increases in government spending in Greece and Portugal. The credit-driven economic boom led to a rise in labor costs and a loss of competitiveness in the tradable sector.
Was there a connection between the financial crisis in the United States and the sovereign debt crisis in the euro area?
Simply put, after Lehman Brothers went bankrupt, we had a sudden stop of capital flows into the periphery, similar to that experienced in the past by many Latin American countries. The periphery boom quickly turned into a bust.
What do you see as the role for euro area monetary policy in that context?
It seems clear that more expansionary monetary policy would have been helpful. First, it would have reduced real labor costs in the peripheral countries. In those countries, the presence of high unemployment rates moderates nominal wage increases, so higher inflation would have reduced real wages. Second, inflation would have reduced the real value of the debts of governments, banks, households, and firms. There might have been some loss of credibility on the part of the ECB [European Central Bank], resulting in a small inflation premium on euro bonds for some time. But this potential cost would have been worth paying in return for the benefits.
And did this happen?
In my view, the ECB did not follow a sufficiently expansionary monetary policy. In fact, the euro-area inflation rate has been consistently below 2 percent and the euro is relatively strong when compared to a purchasing-power-parity benchmark. The euro area turned to contractionary fiscal policy as a panacea. There are good theoretical reasons to believe that—when the interest rate remains constant that so the central bank does not cushion the fall in government spending—the multiplier effect of government spending cuts can be very large. See, for example, Gauti Eggertsson and Michael Woodford, “The Zero Interest-rate Bound and Optimal Monetary Policy,” and Lawrence Christiano, Martin Eichenbaum, and Sergio Rebelo, "When Is the Government Spending Multiplier Large?”
Theory aside, the results of the austerity policies implemented in the euro area are clear. All of the countries that underwent this treatment are now much less solvent than in the beginning of the adjustment programs managed by the European Commission, the International Monetary Fund, and the ECB.
Bank stress testing has become a cornerstone of macroprudential financial oversight. Do you think they helped stabilize the situation in the euro area during the height of the crisis in 2010 and 2011?
No. Quite the opposite. I think the euro-area problems were compounded by the weak stress tests conducted by the European Banking Association in 2011. Almost no banks failed, and almost no capital was raised. Banks largely increased their capital-to-asset ratios by reducing assets, which resulted in a credit crunch that added to the woes of the peripheral countries.
But we’re past the worst now, right? Is the outlook for the euro-area economy improving?
After hitting the bottom, a very modest recovery is under way in Europe. But the risk that a Japanese-style malaise will afflict Europe is very real. One useful step on the horizon is the creation of a banking union. This measure could potentially alleviate the severe credit crunch afflicting the periphery countries.
Thanks, Sergio, for this pretty sobering assessment.
By John Robertson, a vice president and senior economist in the Atlanta Fed’s research department
Editor’s note: Sergio Rebelo is the Tokai Bank Distinguished Professor of International Finance at Northwestern University’s Kellogg School of Management. He is a fellow of the Econometric Society, the National Bureau of Economic Research, and the Center for Economic Policy Research.
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December 04, 2013
Is (Risk) Sharing Always a Virtue?
The financial system cannot be made completely safe because it exists to allocate funds to inherently risky projects in the real economy. Thus, an important question for policymakers is how best to structure the financial system to absorb these losses while minimizing the risk that financial sector failures will impair the real economy.
Standard theories would predict that one good way of reducing financial sector risk is diversification. For example, the financial system could be structured to facilitate the development of large banks, a point often made by advocates for big banks such as Steve Bartlett. Another, not mutually exclusive, way of enhancing diversification is to create a system that shares risks across banks. An example is the Dodd-Frank Act mandate requiring formerly over-the-counter derivatives transactions to be centrally cleared.
However, do these conclusions based on individual bank stability necessarily imply that risk sharing will make the financial system safer? Is it even relevant to the principal risks facing the financial system? Some of the papers presented at the recent Atlanta Fed conference, "Indices of Riskiness: Management and Regulatory Implications," broadly addressed these questions and others. Other papers discuss the impact of bank distress on local economies, methods of predicting bank failure, and various aspects of incentive compensation paid to bankers (which I discuss in a recent Notes from the Vault).
The stability implications of greater risk sharing across banks are explored in "Systemic Risk and Stability in Financial Networks" by Daron Acemoglu, Asuman Ozdaglar, and Alireza Tahbaz-Salehi. They develop a theoretical model of risk sharing in networks of banks. The most relevant comparison they draw is between what they call a "complete financial network" (maximum possible diversification) and a "weakly connected" network in which there is substantial risk sharing between pairs of banks but very little risk sharing outside the individual pairs. Consistent with the standard view of diversification, the complete networks experience few, if any, failures when individual banks are subject to small shocks, but some pairs of banks do fail in the weakly connected networks. However, at some point the losses become so large that the complete network undergoes a phase transition, spreading the losses in a way that causes the failure of more banks than would have occurred with less risk sharing.
Extrapolating from this paper, one could imagine that risk sharing could induce a false sense of security that would ultimately make a financial system substantially less stable. At first a more interconnected system shrugs off smaller shocks with seemingly no adverse impact. This leads bankers and policymakers to believe that the system can handle even more risk because it has become more stable. However, at some point the increased risk taking leads to losses sufficiently large to trigger a phase transition, and the system proves to be even less stable than it was with weaker interconnections.
While interconnections between financial firms are a theoretically important determinant of contagion, how important are these connections in practice? "Financial Firm Bankruptcy and Contagion," by Jean Helwege and Gaiyan Zhang, analyzes the spillovers from distressed and failing financial firms from 1980 to 2010. Looking at the financial firms that failed, they find that counterparty risk exposure (the interconnections) tend to be small, with no single exposure above $2 billion and the average a mere $53.4 million. They note that these small exposures are consistent with regulations that limit banks' exposure to any single counterparty. They then look at information contagion, in which the disclosure of distress at one financial firm may signal adverse information about the quality of a rival's assets. They find that the effect of these signals is comparable to that found for direct credit exposure.
Helwege and Zhang's results suggest that we should be at least as concerned about separate banks' exposure to an adverse shock that hits all of their assets as we should be about losses that are shared through bank networks. One possible common shock is the likely increase in the level and slope of the term structure as the Federal Reserve begins tapering its asset purchases and starts a process ultimately leading to the normalization of short-term interest rate setting. Although historical data cannot directly address banks' current exposure to such shocks, such data can provide evidence on banks' past exposure. William B. English, Skander J. Van den Heuvel, and Egon Zakrajšek presented evidence on this exposure in the paper "Interest Rate Risk and Bank Equity Valuations." They find a significant decrease in bank stock prices in response to an unexpected increase in the level or slope of the term structure. The response to slope increases (likely the primary effect of tapering) is somewhat attenuated at banks with large maturity gaps. One explanation for this finding is that these banks may partially recover their current losses with gains they will accrue when booking new assets (funded by shorter-term liabilities).
Overall, the papers presented in this part of the conference suggest that more risk sharing among financial institutions is not necessarily always better. Even though it may provide the appearance of increased stability in response to small shocks, the system is becoming less robust to larger shocks. However, it also suggests that shared exposures to a common risk are likely to present at least as an important a threat to financial stability as interconnections among financial firms, especially as the term structure and the overall economy respond to the eventual return to normal monetary policy. Along these lines, I recently offered some thoughts on how to reduce the risk of large widespread losses due to exposures to a common (credit) risk factor.
By Larry Wall, director of the Atlanta Fed's Center for Financial Innovation and Stability
Note: The conference "Indices of Riskiness: Management and Regulatory Implications" was organized by Glenn Harrison (Georgia State University's Center for the Economic Analysis of Risk), Jean-Charles Rochet, (University of Zurich), Markus Sticker, Dirk Tasche (Bank of England, Prudential Regulatory Authority), and Larry Wall (the Atlanta Fed's Center for Financial Innovation and Stability).
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March 08, 2013
Will the Next Exit from Monetary Stimulus Really Be Different from the Last?
Suppose you run a manufacturing business—let's say, for example, widgets. Your customers are loyal and steady, but you are never completely certain when they are going to show up asking you to satisfy their widget desires.
Given this uncertainty, you consider two different strategies to meet the needs of your customers. One option is to produce a large quantity of widgets at once, store the product in your warehouse, and when a customer calls, pull the widgets out of inventory as required.
A second option is to simply wait until buyers arrive at your door and produce widgets on demand, which you can do instantaneously and in as large a quantity as you like.
Thinking only about whether you can meet customer demand when it presents itself, these two options are basically identical. In the first case you have a large inventory to support your sales. In the second case you have a large—in fact, infinitely large—"shadow" inventory that you can bring into existence in lockstep with demand.
I invite you to think about this example as you contemplate this familiar graph of the Federal Reserve's balance sheet:
I gather that a good measure of concern about the size of the Fed's (still growing) balance sheet comes from the notion that there is more inherent inflation risk with bank reserves that exceed $1.5 trillion than there would be with reserves somewhere in the neighborhood of $10 billion (which would be the ballpark value for the pre-crisis level of reserves).
I understand this concern, but I don't believe that it is entirely warranted. My argument is as follows: The policy strategy for tightening policy (or exiting stimulus) when the banking system is flush with reserves is equivalent to the strategy when the banking system has low (or even zero) reserves in the same way that the two strategies for meeting customer demand that I offered at the outset of this post are equivalent.
Here's why. Suppose, just for example, that bank reserves are literally zero and the Federal Open Market Committee (FOMC) has set a federal funds rate target of, say, 3 percent. Despite the fact that bank reserves are zero there is a real sense in which the potential size of the balance sheet—the shadow balance sheet, if you will—is very large.
The reason is that when the FOMC sets a target for the federal funds rate, it is sending very specific instructions to the folks from the Open Market Desk at the New York Fed, who run monetary policy operations on behalf of the FOMC. Those instructions are really pretty simple: If you have to inject more bank reserves (and hence expand the size of the Fed's balance sheet) to maintain the FOMC's funds rate target, do it.
To make sense of that statement, it is helpful to remember that the federal funds rate is an overnight interest rate that is determined by the supply and demand for bank reserves. Simplifying just a bit, the demand for reserves comes from the banking system, and the supply comes from the Fed. As in any supply and demand story, if demand goes up, so does the "price"—in this case, the federal funds rate.
In our hypothetical example, the Open Market Desk has been instructed not to let the federal funds rate deviate from 3 percent—at least not for very long. With such instructions, there is really only one thing to do in the case that demand from the banking system increases—create more reserves.
To put it in the terms of the business example I started out with, in setting a funds rate target the FOMC is giving the Open Market Desk the following marching orders: If customers show up, step up the production and meet the demand. The Fed's balance sheet in this case will automatically expand to meet bank reserve demand, just as the businessperson's inventory would expand to support the demand for widgets. As with the businessperson in my example, there is little difference between holding a large tangible inventory and standing ready to supply on demand from a shadow inventory.
Though the analogy is not completely perfect—in the case of the Fed's balance sheet, for example it is the banks and not the business (i.e., the Fed) that hold the inventory—I think the story provides an intuitive way to process the following comments (courtesy of Bloomberg) from Fed Chairman Ben Bernanke, from last week's congressional testimony:
"Raising interest rate on reserves" when the balance sheet is large is the functional equivalent to raising the federal funds rate when the actual balance sheet is not so large, but the potential or shadow balance sheet is. In both cases, the strategy is to induce banks to resist deploying available reserves to expand deposit liabilities and credit. The only difference is that, in the former case, the available reserves are explicit, and in the latter case they are implicit.
The Monetary Policy Report that accompanied the Chairman's testimony contained a fairly thorough summary of costs that might be associated with continued monetary stimulus. Some of these in fact pertain to the size of the Fed's balance sheet. But, as the Chairman notes in the video clip above, when it comes to the mechanics of exiting from policy stimulus, the real challenge is the familiar one of knowing when it is time to alter course.
By Dave Altig, executive vice president and research director of the Atlanta Fed
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October 04, 2012
Trends in Small Business Lending
The Atlanta Fed's latest semiannual Small Business Survey is active through October 22, 2012. If you own a small business and would like to participate, send an e-mail to SmallBusinessResearch@atl.frb.org.
In our previous survey conducted in April 2012, we found that firms applying for credit at large national banks had notably less success than firms that applied to small banks.
We also found that the firms applying to large banks tended to be much younger than the firms that applied to small banks. We speculated that this "age factor" could be contributing to the lower overall success rates at large banks.
A difference between small businesses' success at large and small banks has also been documented by the online credit facilitator Biz2Credit. Biz2Credit works a bit like an online dating service—after answering a series of questions (and providing the typical financial documents required by lenders), small businesses are presented with five potential "matches." To determine the best five matches, Biz2Credit identifies what lenders are looking for—usually a certain credit score, a minimum number of years in business, an established banking relationship, and targeted industries.
The resulting credit applications are the basis for the Biz2Credit Small Business Lending Index. Biz2Credit also reports approval rates from the matching process for large banks, small banks, credit unions, and alternative lenders. These approval rates are plotted on the chart below.
Much like we saw in the Small Business Survey, Biz2Credit reports that small firms have had consistently less success in obtaining credit at large banks.
Confirming our results encourages us that our April observation was a good one. But confirmation isn't explanation—what accounts for the different experiences small businesses have in securing credit from small banks versus big banks? And so, we dig deeper.
Note: According to Biz2Credit, its index is based on 1,000 of the 10,000-plus applications submitted each month. To be included, the business has to have at least a 680 credit score, be at least two years old, and have an established relationship with the bank to which it is applying. Selection methods are also applied to provide for national representation.
By Ellyn Terry, senior economic research analyst at the Atlanta Fed
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June 28, 2012
Young versus mature small firms seeking credit
The ongoing tug of war between credit supply and demand issues facing small businesses is captured in this piece in the American Prospect by Merrill Goozner. Goozner asks whether small businesses are facing a tougher borrowing environment than is warranted by current economic conditions. One of the potential factors identified in the article is the relative decline in the number of community banks—down some 1,124 (or 13 percent of all banks from 2007). Community banks have traditionally been viewed as an important source of local financing for businesses and are often thought to be better able to serve the needs of small businesses than large national banks because of their more intimate knowledge of the business and the local community.
The Atlanta Fed's poll of small business can shed some light on this issue. In April we reached out to small businesses across the Sixth Federal Reserve District to ask about financing applications, how satisfied firms were that their financing needs were being met, and general business conditions. About one third of the 419 survey participants applied for credit in the first quarter of 2012, submitting between two and three applications for credit on average. As we've seen in past surveys (the last survey was in October 2011), the most common place to apply for credit was at a bank.
For the April 2012 survey, the table below shows the average success of firms applying to various financing sources (on a scale of 1 to 4, with 1 meaning none of the amount requested in the application was obtained, and 4 meaning that the firm received the full amount applied for). The table also shows the median age of businesses applying for each type of financing.
The results in the table show that for credit applications, Small Business Administration loan requests and applications for loans/lines of credit from large national banks tended to be the least successful, whereas applications for vendor trade credit and commercial loans/line-of-credit from community banks had the highest average success rating.
Notably, firms applying for credit at large national banks were typically much younger than firms applying at regional or community banks. If younger firms generally have more difficulty in getting credit regardless of where they apply, it could explain why we saw less success, on average, among firms applying at larger banks.
To investigate this issue, we compared the average application success among young firms (less than six years old) that applied at both regional or community banks and at large national banks, pooling the responses from the last few years of our survey. The credit quality of borrowers is controlled for by looking only at firms that applied at both types of institutions. What we found was no significant difference in the average borrowing success of young firms applying for credit across bank type—it just does seem to be tougher to get your credit needs met at a bank if you're running a young business. Interestingly, we also found that more mature firms were significantly more successful when applying at regional or community banks than at large national banks—it seems to be relatively easier for an established small business to obtain requested credit from a small bank.
While this analysis did not control for other factors that could also affect the likelihood of borrowing success, the results do suggest that Goozner's question about the impact of declining community bank numbers on small business lending is relevant. If small businesses are generally more successful when seeking credit from a small bank, will an ongoing reduction in the number of community banks substantially affect the ability of (mature) small businesses to get credit? More detailed insights from the April 2012 Small Business Credit Survey will be available soon on our Small Business Focus website, and we will provide an update when they are posted.
Ellyn Terry, senior economic research analyst, both of the Atlanta Fed's research department
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May 31, 2012
What is shadow banking?
"Shadow banking is a market-funded, credit intermediation system involving maturity and/or liquidity transformation through securitization and secured-funding mechanisms. It exists at least partly outside of the traditional banking system and does not have government guarantees in the form of insurance or access to the central bank."
As the Deloitte study makes clear, this definition is fairly narrow—it doesn't, for example, include hedge funds. Though Deloitte puts the size of the shadow banking sector at $10 trillion in 2010, other well-known measures range from $15 trillion to $24 trillion. (One of those alternative estimates comes from an important study by Zoltan Pozsar, Tobias Adrian, Adam Ashcraft, and Hayley Boesky from the New York Fed.)
What definition of shadow banking you prefer probably depends on the questions you are trying to answer. Since the interest in shadow banking today is clearly motivated by the financial crisis and its regulatory aftermath, a definition that focuses on systemically risky institutions has a lot of appeal. And not all entities that might be reasonably put in the shadow banking bucket fall into the systemically risky category. Former PIMCO Senior Partner Paul McCulley offered this perspective at the Atlanta Fed's recent annual Financial Markets Conference (video link here):
"...clearly, the money market mutual fund, that 2a-7 fund as it's known here in the United States, is the bedrock of the shadow banking system...
"The money market mutual fund industry is a huge industry and poses massive systemic risk to the system because it's subject to runs, because it's not just as good as an FDIC bank deposit. We found out that in spades in 2008...
"In fact, I can come up with an example of shadow banking that really didn't have a deleterious effect in 2008, and that was hedge funds with very long lockups on their liability. So hedge funds are shadow banks that are levered up intermediaries, but by having long lockups on their liabilities, then they weren't part and parcel of a run because they were locked up."
The more narrow Deloitte definition is thus very much in the spirit of the systemic risk definition. But even though this measure does not cover all the shadow banking activities with which policymakers might be concerned, other measures of the trend in the size of the sector look pretty much like the one below, which is from the Deloitte report:
The Deloitte report makes this sensible observation regarding the decline in the size of the shadow banking sector:
"Does this mean that the significance of the shadow banking system is overrated? No. The growth of shadow banking was fueled historically by financial innovation. A new activity not previously created could be categorized as shadow banking and could creep back into the system quickly. That new innovation might be but a distant notion at best in someone's mind today, but could pose a systemic risk concern in the future."
Ed Kane, another participant in our recent conference, went one step further with a familiar theme of his: new shadows are guaranteed to emerge, as part of the "regulatory dialectic"—an endless cycle of regulation and market innovation.
In getting to the essence of what the future of shadow banking will (or should) be, I think it is instructive to consider a set of questions that were posed at the conference by Washington University professor Phil Dybvig. I'm highlighting three of his five questions here:
"1. Is creation of liquidity by banks surplus liquidity in the economy or does it serve a useful economic purpose?
"2. How about creation of liquidity by the shadow banking sector? Was it surplus? Did it represent liquidity banks could have provided?...
"5. If there was too much liquidity in the economy, why? Some people have argued that it was because of too much stimulus and the government kept interest rates too low (and perhaps the Chinese government had a role as well as the US government). I don't want to take a side on these claims, but it is an important empirical question whether the explosion of the huge shadow banking sector was a distortion that was an unintended side effect of policy or whether it is an essential feature of a healthy economy."
Virtually all regulatory reforms will entail costs (some of them unintended), as well as benefits. Sensible people may come to quite different conclusions about how the scales tip in this regard. A good example is provided by the debate from another session at our conference on reform of money market mutual funds between Eric Rosengren, president of the Boston Fed, and Karen Dunn Kelley of Invesco. And we could see proposals by the Securities and Exchange Commission in the future to enact further reforms to the money market mutual fund industry. But whether any of these efforts are durable solutions to the systemic risk profile of the shadow banking sector must surely depend on the answers to Phil Dybvig's important questions.
By Dave Altig, executive vice president and research director at the Atlanta Fed
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