speeches · March 10, 1998
Regional President Speech
E. Gerald Corrigan · President
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An appropriate subtitle for these remarks is “Say What You Mean, Banking in the Ninth
and Mean What You Say.” As you will see, this phrase is
essentially an admonition applicable in establishing and managing Connect
the safety net underpinning a nation's banking system. For the MinneapolisFed on Twitter
safety net should promote financial and economic stability and Minneapolis Fed on Facebook
RSS Feeds
yet, if poorly designed, it may do just the opposite, thereby
contributing to excessive risk taking and instability. Indeed, the
experience of many countries, industrialized and developing alike,
suggests that such perverse effects have in fact occurred from
time to time.
We believe that there is ample evidence in support of a safety net
to provide banking system stability, but we also believe that its
scope and operation must be defined carefully. Ultimately, the
issue transcends banking or financial system stability, for there is
now considerable evidence that the extent and quality of a
country's financial infrastructure is a significant determinant of
economic growth.
The discussion today is organized as follows. I first review the late
1980s—early 1990s banking problems in the U.S. and emphasize
the role of incentives—essentially, the moral hazard problem—in
our experience. After noting that this problem is not unique to the
U.S., I proceed in the next section to discuss the value of the
government safety net underpinning banking, arguing that in its
absence excessive instability could result. The subsequent
section takes up the issue of reconciling the objectives of
promotion of stability and limitation of moral hazard costs, and
presents a proposal, with coinsurance at its core, to do just that. I
conclude, before turning to comments and questions, with a brief
summary.
The savings and loan fiasco and increased failures of commercial
banks in the U.S. during the 1980s and early 1990s consumed
considerable resources. Explicit resolution expenses were quite
high, of course, as the S&L cleanup is estimated at 2 1/2 percent
or more of GDP. Indeed, this estimate is probably low, since it
ignores both deadweight losses resulting from resource
misallocation and damage to public confidence in the financial
and political system.
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Despite its size and significance, the American experience of this
period was not unique. The World Bank reports that at least 70
banking crises occurred in the 1980s throughout the developed
and developing worlds. The quantitative impact of some of these
crises equaled or exceeded the U.S. experience. Interestingly
enough, Asia saw its share of banking crises in the 1980s in
countries such as Indonesia, Malaysia, Japan, Thailand, and the
Philippines.
To be sure, each banking crisis seems as unique to the country
affected as the American debacle seemed to us. While detailed
understanding of the financial and legal system of each country is
required to speak about a given situation with authority,
economists have identified a number of factors common to many.
In particular, banking crises are frequently associated with:
1. Macroeconomic shocks that increase the variability of
inflation, exchange rates, interest rates, or capital flows;
2. Deficiencies in supervisory policies in areas such as capital
standards or restrictions on insider activities;
3. An unwillingness to shut down insolvent institutions (i.e.
forbearance); and
4. Poor credit decisions and inept management of credit risk,
which are often related to government influence on credit
allocation.
The preceding list is far from comprehensive. Staff and
consultants at the Bank for International Settlements, the IMF, the
Inter-American Development Bank, and the World Bank have all
produced reviews in the last several years indicating, not
surprisingly, that many factors are responsible for any given
banking crisis.
A factor deliberately omitted from the discussion to this point is
the breakdown in, or absence of, market discipline, caused by a
belief that the government will absorb the losses that bank
creditors would otherwise bear. This is the well-known problem of
moral hazard. In the U.S., moral hazard resulted in part from the
deposit insurance system that provides explicit coverage to
$100,000 per account. Protected depositors did not have
adequate incentive to price their funding according to the riskiness
of the bank, thereby allowing some institutions to attract funds at
below market rates. So-called brokered deposits exacerbated this
problem significantly, since the $100,000 umbrella could be
exploited despite geographic and other “natural” barriers.
But perhaps more devastating than explicit insurance coverage
was the influence of the government's implied support. Often
times the coverage of uninsured depositors is referred to as a
policy of too-big-to-fail, implying that, for systemic reasons, an
institution is too important to expose its creditors to loss. Actually,
however, widespread protection of all uninsured depositors is a
more accurate description, for the FDIC protected 99.7 percent of
all deposits at failed commercial banks from 1979 to 1989. This
implicit coverage created widely held expectations of government
protection of depositors, especially at large institutions, and
further undermined market discipline significantly.
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Moral hazard is not unique to the U.S. Indeed, it is “credited” to
some degree with contributing to the banking problems
experienced in a long list of countries, including Japan, the
Philippines, Taiwan, Indonesia, South Korea, and Thailand.
Equally important, there should be little doubt at this stage that
inadequate or incapacitated financial institutions and markets
inhibit economic development and industrialization. A recent
article in the Journal of Economic Literature persuasively makes
this case, and I refer you to that publication.
If a robust financial system is critical to economic development,
and if moral hazard serves to damage the financial infrastructure,
why not eliminate government protection of depositors? In other
words, why not clean up the incentives and achieve enhanced
market discipline? Where explicit insurance coverage does not
exist currently, it could be made clear that, as a matter of public
policy, losses from banking failures will be borne by depositors
and other creditors. Admittedly, this reform would be more difficult
to accomplish where there are explicit guarantees or well
established precedents in place, but extended lead times could be
a vehicle for smoothing the necessary adjustments in such
circumstances.
Nevertheless, this is not a policy I would advocate, because
commercial banks remain, in a very real sense, special. Banks,
after all, offer liabilities payable on demand at par but hold a wide
range of assets with diverse maturities, degrees of liquidity, and
credit quality. Cognizant of these features and recognizing their
informational disadvantage relative to bank management,
depositors have an incentive to run the bank when other
depositors do or if the bank is perceived, rightly or not, to be in
financial difficulty.
The answer to the question posed earlier—namely, why not
eliminate government protection of depositors?—is, then, that
excessive instability would result. We need to recognize that in
the U.S., deposit insurance backed by the government has in fact
produced an extended period without a banking panic, albeit at
significant cost in terms of moral hazard. In contrast, privatization
options, say a private deposit insurance company or a
self-insurance scheme lacking the credit quality of the U.S.
government, may not be successful in preventing panics because
they could be subject to the same disadvantages, and risk of loss,
as depositors.
Finally, a policy of simply ruling out protection of depositors and
other creditors, in all circumstances, may not reduce moral hazard
effectively because such a stance would likely lack credibility.
There may in fact be occasions when the size of the failing
institution is such that its downfall could lead to severe spillovers
throughout the financial system and, ultimately, the real economy.
Government intervention in such a case could well pass a
cost/benefit test. Further, market participants in countries which
have a long history of government intervention in many facets of
the economy are not likely to believe statements of
nonintervention, and thus are not likely to increase market
discipline of financial institutions, no matter what the authorities
say.
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The challenge to policymakers in this arena is to balance two
competing objectives, namely banking system stability and
minimizing the cost of moral hazard. There is clearly a trade-off
here: stability can be achieved at the expense of high moral
hazard costs, or moral hazard can be eliminated at the cost of
instability. But how can the two be reconciled?
As it turns out, this is a question to which several of us at the
Federal Reserve Bank of Minneapolis (and the University of
Minnesota, I might add) have given considerable thought over the
years. There are three key features of our plan to limit the
probability of banking panics and the size of the moral hazard
problem:
1. The reforms of FDICIA—the Federal Deposit Insurance
Corporation Improvement Act (of 1991)—designed to reduce
excessive risk taking by insured institutions should be
retained. These reforms include risk based deposit insurance
premia, risk based capital standards, and prompt corrective
action with regard to institutions whose capital becomes
impaired. While FDICIA is not perfect, it does effectively
establish a framework for having higher risk institutions pay
higher premia and hold more capital, and for closing banks as
they approach, but before they reach, insolvency.
2. The current level of explicit deposit insurance coverage would
be maintained, although we might eventually want to consider
limiting it to one account per social security number. The
implication of this provision is that small depositors would be
protected.
3. Market discipline would be enhanced by convincing formally
uninsured depositors that they will necessarily bear some loss
in a failed bank situation. Essentially, we have in mind a
coinsurance provision which would be added to the initial
FDICIA reforms.
More specifically, FDICIA requires a series of steps before
too-big-to-fail rescues of institutions can occur. These are that: (1)
the Secretary of Treasury must find that least cost resolution
would “have serious adverse effects on economic conditions and
financial stability” and that the provision of extra legal insurance
coverage would “avoid or mitigate such adverse effects.” (2) The
Treasury Secretary must consult with the President in making this
determination. (3) Two-thirds of the governors of the Federal
Reserve System and two-thirds of the directors of the FDIC must
approve the coverage. Under our proposal, the FDICIA legislation
would be amended so that uninsured depositors would take a
limited but meaningful loss (say, perhaps, 20 percent of the
uninsured portion of their deposit) when a too-big-to-fail rescue
occurs, pending, of course, the ultimate disposition of the assets
of the failed institution. It is obviously crucial that market discipline
be introduced carefully, because losses that proved excessively
disruptive would doom such a policy.
We see several advantages to this proposal, taken in its entirety.
As noted above, small depositors remain protected (and can,
therefore, sleep comfortably). Secondly, the approach builds on
FDICIA, legislation in place and with an established degree of
credibility. What is added is codification of the loss of the
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uninsured depositors. In this sense, the government says what it
means and means what it says. Third, the loss is imposed on
uninsured depositors in a way which limits spillovers and,
therefore, should not add materially to the probability of banking
panics, yet is sufficiently meaningful so that depositors have
significant incentive to gather and assess information about banks
and, perhaps, to diversify more than otherwise. Under this
proposal, we would expect the market for information about the
financial condition of banks to broaden and deepen over time. We
would also note that the size of the loss imposed on uninsured
depositors could be adjusted over time, so disruption could be
contained by starting at a low level.
In summary, I would note that banking systems historically are
subject to crises, and policies to reduce the probability of crises
are frequently quite costly in their own right because of excessive
risk taking resulting from moral hazard.
We are not aware of a solution to this dilemma. Nevertheless,
there are, we believe, two principles appropriate for managing the
trade-off between instability and moral hazard. First, incentives in
favor of market discipline are essential to contain the moral
hazard problem. As we see it, market discipline is a complement
to regulation and supervision of banks and not a substitute for
them. But we have ample experience to suggest that supervision
alone is incapable of adequate restraint of moral hazard. Second,
the government's policy of support for the creditors of a failed
bank should be explicit and in legislation. As we have suggested,
such a step, if carefully crafted, can enhance market discipline
and limit potentially disruptive spillover effects while, at the same
time, adding to the government's credibility.
Thank you.
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Cite this document
APA
E. Gerald Corrigan (1998, March 10). Regional President Speech. Speeches, Federal Reserve. https://whenthefedspeaks.com/doc/regional_speeche_19980311_e_gerald_corrigan
BibTeX
@misc{wtfs_regional_speeche_19980311_e_gerald_corrigan,
author = {E. Gerald Corrigan},
title = {Regional President Speech},
year = {1998},
month = {Mar},
howpublished = {Speeches, Federal Reserve},
url = {https://whenthefedspeaks.com/doc/regional_speeche_19980311_e_gerald_corrigan},
note = {Retrieved via When the Fed Speaks corpus}
}