speeches · April 14, 2021
Regional President Speech
Mary C. Daly · President
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The Last Resort in a Changing Landscape
Mary C. Daly, President and Chief Executive Officer
Federal Reserve Bank of San Francisco
Money Marketeers of New York University Webinar
New York, NY
April 15, 2021
02:00 PM EDT
Remarks as prepared for delivery.
Introduction
I grew up in Missouri surrounded by three rivers. Nearly every spring,
at least one of them would flood. Each time this happened, families,
businesses, and sometimes whole communities, would be forced to higher
ground until the water receded and returned to its banks.
Public programs were there to assist. Teams helped people evacuate,
temporary shelters were stood up overnight, and financial support was
provided for repairs and rebuilding. By many measures, these responses
were a win, repeated successes of a system meant to insure against these
types of disasters.
But flooding was not a rare event, it happened almost every year.
Against that backdrop, the prevailing public policy seems incomplete. A patch
against a problem that owed in part to known structural factors such as
geography, location, and regular weather patterns.
Which takes me to what I want to discuss today. Changes in our
economic and financial landscape have left us with a financial market
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infrastructure that is more vulnerable to disruptions. We saw this in the
Global Financial Crisis and in our recent experience with the unprecedented
shock of COVID-19. As the lender of last resort in the United States, the
Federal Reserve was there to assist. In both cases, we intervened—provided
liquidity, stabilized markets, and ensured that the financial system could
continue to fulfill its role in the economy.
But the frequency and scale of our interventions is concerning. Without
changes to our financial infrastructure, the Federal Reserve may regularly be
called to step in to stabilize markets during turbulent periods. And not just
for 100-year floods like COVID-19, but for more typical disruptions associated
with average shocks to the global and domestic economy.
The Federal Reserve’s role as lender of last resort will always be a
critical backstop in the protection against turmoil and dislocation caused by
rare or extreme events. But to fulfill the role sustainably, we need to be the
last, not the first, line of defense. Regularly relying on “save the day”
interventions by the Federal Reserve can be costly, resulting in public losses
and undesirable risk-taking on the part of the private sector.
As policymakers, we must continually evaluate our actions. We must
use all of our experiences, even those from times of crises, to identify
vulnerabilities and create a more resilient future. This means working
together, across regulatory agencies, to examine the events of last year and
ask what needs to be done to minimize the chances of future severe
disruptions.
So as we begin to emerge from our battles against COVID-19, it is time
to focus on crafting more complete policies that leave us better prepared to
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weather future storms, big and small. Only then can we foster a more stable,
sound and resilient financial system.
Before I turn to this, let me remind you that my remarks are my own
and do not necessarily reflect the views of anyone else within the Federal
Reserve System.
A Changing Landscape
The financial sector is crucial for the smooth functioning of the
economy. It enables the borrowing, lending, and saving that supports growth.
From that vantage point, it is a public resource, a critical infrastructure for our
shared prosperity.
But many shifts, exogenous to the financial system itself, are affecting its
functioning. Most notable is the decline in the neutral rate of interest, or r-
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star, which has been falling globally for the past three decades. The decline
reflects slow-moving structural trends including a step-down in productivity
growth and shifts in the demand for savings and investment associated with
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population aging. The decline in r-star and other prevailing interest rates
alone would challenge the profitability of financial firms. But lower neutral
rates of interest also mean that the Federal Reserve and other central banks,
constrained by the effective lower bound on interest rates, need to routinely
employ “low-for-long” policies to achieve mandated employment and price
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stability goals.
The effects of these low-for-long policies have well-documented
benefits of boosting economic growth, which ultimately supports the financial
1
Holston, Laubach, and Williams (2017), Jordà and Taylor (2019).
2
Carvalho, Ferrero, and Nechio (2016), Williams (2017).
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Mertens and Williams (2019), Andrade et al. (2021).
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system. But they are not without trade-offs. Over time, low interest rates can
put pressure on the business models of financial institutions, leading them to
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reach for yield, which can jeopardize the stability of the financial system.
A related but additional development affecting the financial system is
the broad-based increase in debt levels and leverage ratios. Government
policies enacted to offset the Global Financial Crisis in the late 2000s left many
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advanced nations with relatively high debt-to-GDP ratios. The response to
the COVID-19 pandemic has only intensified this trend. Debt has also surged
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in the private sector, especially among nonfinancial corporate firms. Notably,
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much of this increase in debt has been funded outside of the banking sector.
While the rise in public and private debt have contributed to economic growth
over the past decade, the increased indebtedness has created vulnerabilities
that the financial system has to intermediate.
Importantly, this increase in borrowing has had a significant impact on
the U.S. Treasury market. And this is the final aspect of the changed landscape
that I will focus on. The Treasury market is the largest and most liquid bond
market in the world and is a critical component of the domestic and global
financial infrastructure. Broker-dealers provide the lion’s share of Treasury
security intermediation and generally are well-positioned to meet the
demands of investors to buy or sell Treasury securities.
Over the past decade, Treasury securities have also become an
increasingly important p art of short-term funding markets, for instance as
4
Arias et al. (2020), Caldara et al. (2020), Bernanke, Kiley, and Roberts (2019).
5
Choi and Kronlund (2018), Di Maggio and Kacperczyk (2017), Financial Stability
Oversight Council (2020).
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Badia and Dudine (2019).
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Board of Governors (2020).
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4
Board of Governors (2020), Financial Stability Board (2020).
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collateral in repurchase agreements. And a sizable and growing share of
Treasury securities are held by financial entities such as hedge funds or
money market funds that in times of stress can find themselves needing to
liquidate quickly to meet redemption demand. This can put pressure on
broker-dealers to absorb those sales.
The pressure on the Treasury market is magnified by the fact that
Treasury securities remain a safe haven investment for foreign official and
private investors. Normally, this is a benefit to the U.S. economy, but in
periods of global stress, when liquidity is at a premium, it increases demands
on Treasury clearing that go far beyond the needs of domestic investors.
In all of these situations, broker-dealers are the primary intermediary
tasked with meeting the demand for liquidity. This normally works extremely
well. But, as we saw last year, these intermediaries face regulatory and
internal risk limits that can challenge their ability to meet surges in demand
for liquidity. Given the growing size of the Treasury market, and the potential
inability of broker-dealer balance sheets to keep up, this intermediation
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channel could face more capacity pressure in the future.
Lender of Last Resort: Crisis and Response
The onset of COVID-19 and the financial and economic disruptions that
it caused, exacerbated many of the vulnerabilities embedded in the changing
financial landscape. The crisis roiled financial markets. Even the bedrock
Treasury market experienced a severe disruption.
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This issue has been raised by various researchers including Duffie (2020) and Liang and
Parkinson (2020). But this is an open area of study and one where no consensus has
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formed.
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In the early days of March 2020, when it became clear that COVID-19
was a pandemic that would disrupt the entire global economy, investor
sentiment shifted quickly. Short-term funding markets became especially
stressed. A “dash for cash” among both domestic and foreign investors
resulted in a run from even relatively safe longer-dated Treasury securities to
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cash and Treasury bills. The rapid and large-scale repositioning caused
trading volumes to surge and price volatility to spike. Broker-dealers, facing
their own internal risk and balance sheet limits, had difficulty meeting the
demand for cash. Bid-ask spreads widened, market depth fell, and the
normally fluid Treasury market was strained. Stress was particularly
apparent in longer-dated off-the-run securities.
The Federal Reserve System and the New York Fed’s Open Market
Trading Desk reacted immediately, conducting a record number of open-
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market operations to restore and promote smooth market functioning. This
is exactly what the lender of last resort is tasked with accomplishing.
Stepping back from the crisis and the unique features of the shock, the
events of last March raise questions about the resiliency of intermediation in
the Treasury market during periods of market stress. A key lesson from the
Global Financial Crisis (GFC) was that even rare events deliver important
lessons. Following the GFC, regulatory bodies across the globe made material
changes to the financial system that paid dividends during the COVID-19
crisis. For example, in the United States, the regulatory framework that came
out of the Dodd-Frank Act ensured that systemically important institutions
entered the pandemic with sufficient capital to facilitate the forbearance and
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Acharya, Engle, and Steffen (2021).
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Logan (2020a).
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lending that has been critical to our economic recovery. The question before
us now is, what can we learn from the events of March 2020, and how can we
use those lessons to build a more resilient financial system moving forward.
Building the Resiliency of the Financial System
There are many potentially important topics for study, but I will focus
on two that are particularly salient to the idea of building more resiliency in
the financial system: short-term funding markets and greater prudential
oversight for the banking system.
Treasury and Short-Term Funding Markets
For the Treasury market, a number of possible reforms are currently
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being discussed. These include the Federal Reserve creating a domestic
standing repurchase facility to backstop markets in times of stress and making
permanent the temporary FIMA—Foreign and International Monetary
Authorities Repo Facility—to help support smooth market functioning. These
actions would provide assurance to markets that liquidity will be available in
times of stress, but they could also leave financial markets more dependent on
their existence. So, further careful study is required.
Outside of the Federal Reserve, expanding trading platform access to
more entities and using central clearing for Treasury cash markets could
reduce the burden on broker-dealers and lessen the liquidity crunch in times
of stress. Additionally, reconsidering the inclusion of reserves or even
Treasuries in the regulatory leverage-ratio requirements for broker-dealers,
12
See Baily, Klein, and Schardin (2017), Quarles (2020), Brainard (2021).
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Smith (2021).
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particularly when markets are strained, could further facilitate capacity for
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clearing. Again, these changes and expansions have potential benefits and
costs so further careful study is warranted.
Looking beyond the direct functioning of the Treasury market, the
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stability of hedge funds and money market funds is an important priority.
These entities have structural funding risk that can easily spike in times of
stress, contributing to the severity of runs. The Financial Stability Oversight
Council (FSOC) and the Securities and Exchange Commission have signaled
some movement in shoring up the resiliency of these funds, something I see as
critical to ensuring that we are prepared for the next stressful shock.
Expanding Prudential Oversight
But fixing the Treasury market and reforming other short-term funding
markets is just one piece of ensuring a healthy financial system going forward.
The proximity of the effective lower bound on interest rates and the necessity
to keep policy rates low for longer after a downturn, can, as I mentioned
earlier, result in reach-for-yield behavior among financial firms. So, we also
need to find ways to foster and maintain sustainable increases in leverage.
Regulators already have a variety of regulatory and supervisory tools
that provide an effective first-line of defense, including capital requirements,
leverage ratios, and stress tests. These tools have proven successful at
keeping the banking sector healthy and well-capitalized over the business
14
See for example Liang and Parkinson (2020), Duffie (2020), Treasury Market Practices
Group (2019), U.S. Securities and Exchange Commission (2020).
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U.S. Department of the Treasury (2021), U.S. Securities and Exchange Commission
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(2021).
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cycle, a characteristic that has served us well as we work through the
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pandemic.
But new risks emerge as the economy evolves and we need to ensure
that we are prepared for what is ahead. The banking sector is just one part of
the financial system. Shadow banking was a problem during the Global
Financial Crisis, and with the rapid growth of the fintech sector, there is much
to consider outside our traditional areas. At the Federal Reserve, we
continuously monitor the resilience and vulnerabilities of the financial system
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as a whole and publish our assessment in our Financial Stability Report. And
the FSOC is actively working to ensure that all the regulatory bodies are
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coordinating, so that the right policy levers can be activated. But more work
may need to be done to ensure that other parts of the financial infrastructure
remain sound and stable.
Policy for a Changing World
Turning back to where I started, I often think about my experience
growing up near a flood plain. The frequent disruptions of the rivers to
peoples’ lives and livelihoods. It reminds me of the importance of a last resort
backstop. Protection against losses too big for any one of us to bear. But the
experience also taught me the value of prevention. Of building resiliency and
minimizing the chances that a backstop is needed at all.
and
What the rivers of Missouri really taught me is that optimal public
policies are those that manage mitigate risks. Backstops and prevention
that result in consistently better outcomes.
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Baily, Klein, and Schardin (2017), Quarles (2020), Brainard (2021).
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Board of Governors (2020).
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Financial Stability Oversight Council (2020).
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This is the balance we will need to strike to ensure that our ever-
changing financial system continues to fulfill its role as critical public
infrastructure.
Thank you.
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References
Acharya, Viral V., Robert F. Engle III and Sascha Steffen. 2021. “Why Did Bank Stocks Crash
during COVID-19?” National Bureau of Economic Research Working Paper 28559,
(March). https://www.nber.org/papers/w28559
Andrade, Philippe, Jordi Galí, Hervé Le Bihan, and Julien Matheron. 2021. “Should the ECB
Adjust Its Strategy in the Face of a Lower r*?” Centre de Recerca en Economia
Internacional Working Paper, (February 3). https://crei.cat/wp-
content/uploads/2021/02/EAAGLBM_January2021-1.pdf
Arias, Jonas, Martin Bodenstein, Hess Chung, Thorsten Drautzburg, and Andrea Raffo. 2020.
“Alternative Strategies: How Do They Work? How Might They Help?” Federal Reserve
Board of Governors, Finance and Economics Discussion Series 2020-068.
https://doi.org/10.17016/FEDS.2020.068
Badia, Marialuz Moreno, and Paolo Dudine. 2019. “New Data on World Debt: A Dive into
Country Numbers.” IMFBlog, International Monetary Fund, December 17.
https://blogs.imf.org/2019/12/17/new-data-on-world-debt-a-dive-into-country-
numbers/
RSF: The Russell Sage Foundation
BailJyo, uMrnaartli onf Ntheeil ,S Aocairaoln S cKileenince, sa,nd Justin Schardin. 2017. “The Impact of the Dodd-Frank
Act on Financial Stability and Economic Growth.”
3, (1, January), pp. 20-47.
https://www.rsfjournal.org/content/rsfjss/3/1/20.full.pdf
Bernanke, Ben S., Michael T. Kiley, and John M. Roberts. 2019. “Monetary Policy Strategies
for a Low-Rate Environment,” Federal Reserve Board of Governors, Finance and
Economics Discussion Series 2019-009. https://doi.org/10.17016/FEDS.2019.009
Board of Governors of the Federal Reserve System. 2020. “Financial Stability Report.”
November. https://www.federalreserve.gov/publications/2020-november-financial-
stability-report-purpose.htm
Brainard, Lael. 2021. “Some Preliminary Financial Stability Lessons from the COVID-19
Shock.” Speech at the 2021 Annual Washington Conference, Institute of International
Bankers (via webcast), March 1.
https://www.federalreserve.gov/newsevents/speech/brainard20210301a.htm
Caldara, Dario, Etienne Gagnon, Enrique Martınez-Garcıa, and Christopher J. Neely. 2020.
“Monetary Policy and Economic Performance since the Financial Crisis,” Federal
Reserve Board of Governors, Finance and Economics Discussion Series 2020-065.
https://doi.org/10.17016/FEDS.2020.065
11
FINAL
European Economic Review
Carvalho, Carlos, Andrea Ferrero, and Fernanda Nechio. 2016. “Demographics and Real
Interest Rates: Inspecting the Mechanism.” 88, pp. 208–226.
The Review of Financial Studies
Choi, Jaewon, and Mathias Kronlund. 2018. “Reaching for Yield in Corporate Bond Mutual
Funds.” 31(5 May), pp. 1930–1965.
Journal of Financial Economics
Di Maggio, Marco, and Marcin Kacperczyk. 2017. “The Unintended Consequences of the
Zero Lower Bound Policy.” 123(1, January), pp. 59–80.
Duffie, Darrell. 2020. “Still the World’s Safe Haven? Redesigning the U.S. Treasury Market
a fter the COVID-10 Crisis” Hutchins Center Working Paper 62, Brookings Institution,
June 22.
https://www.brookings.edu/research/still-the-worlds-safe-haven/
Financial Stability Board. 2020. “Global Monitoring Report on Non-Bank Financial
Intermediation.” December 16. https://www.fsb.org/2020/12/global-monitoring-
report-on-non-bank-financial-intermediation-2020/
Financial Stability Oversight Council. 2020. “Annual Report.”
https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-
fiscal-service/fsoc/studies-and-reports/annual-reports
Journal of International
HolsEtcoonn, oKmatihcsryn, Thomas Laubach, and John C. Williams. 2017. “Measuring the Natural
Rate of Interest: International Trends and Determinants.”
108, supplement 1 (May), pp. S39–S75.
Jordà, Òscar, and Alan M. Taylor. 2019. “Riders on the Storm.” FRB San Francisco Working
Paper 2019–20. https://www.frbsf.org/economic-research/publications/working-
papers/2019/20/
Liang, Nellie, and Pat Parkinson. 2020. “Enhancing Liquidity of the U.S. Treasury Market
Under Stress.” Hutchins Center Working Paper 72, Brookings Institution, December.
https://www.brookings.edu/research/enhancing-liquidity-of-the-u-s-treasury-market-
under-stress/
Logan, Lorie K. 2020a. “The Federal Reserve’s Market Functioning Purchases: From
Supporting to Sustaining.” Remarks at SIFMA Webinar, July 15.
https://www.newyorkfed.org/newsevents/speeches/2020/log200715
Logan, Lorie K. 2020b. “Treasury Market Liquidity and Early Lessons from the Pandemic
Shock.” Remarks at Brookings-Chicago Booth Task Force on Financial Stability Meeting
(via videoconference), October 23.
https://www.newyorkfed.org/newsevents/speeches/2020/log201023
American Economic Association Papers and
MerPternosc,e Tedhionmgsas M., and John C. Williams. 2019. “Monetary Policy Frameworks and the
Effective Lower Bound on Interest Rates.”
109 (May), pp. 427–432.
12
FINAL
Quarles, Randal K. 2020. “What Happened? What Have We Learned from It? Lessons from
COVID-19 Stress on the Financial System.” Speech at the Institute of International
Finance, Washington, DC (via webcast), October 15.
https://www.federalreserve.gov/newsevents/speech/quarles20201015a.htm
Smith, Brian. 2021. Remarks at the Federal Reserve Bank of New York’s Annual Primary
Dealer Meeting. https://home.treasury.gov/news/press-releases/jy0116
Treasury Market Practices Group. 2019. “Best Practices for Treasury, Agency Debt, and
Agency Mortgage-Backed Securities Markets.” July.
https://www.newyorkfed.org/medialibrary/Microsites/tmpg/files/TMPG_BestPractice
s_071119.pdf
U.S. Department of the Treasury. 2021. “Readout of Financial Stability Oversight Council
Meeting on March 31, 2021.” Press release, March 31.
https://home.treasury.gov/news/press-releases/jy0093
U.S. Securities and Exchange Commission. 2020. “SEC Proposes Rules to Extend
Regulations ATS and SCI to Treasuries and Other Government Securities Markets.”
Press release, September 28. https://www.sec.gov/news/press-release/2020-227
U.S. Securities and Exchange Commission. 2021. “SEC Requests Comment on Potential
Money Market Fund Reform Options Highlighted in President’s Working Group Report.”
Press release, February 4. https://www.secF.gRoBvS/Fn Eewcosn/opmreiscs L-reetlteearse/2021-25
Williams, John C. “Three Questions on R-Star.” 2017-05 (February
21). https://www.frbsf.org/economic-research/publications/economic-
letter/2017/february/three-questions-on-r-star-natural-rate-of-interest/
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Cite this document
APA
Mary C. Daly (2021, April 14). Regional President Speech. Speeches, Federal Reserve. https://whenthefedspeaks.com/doc/regional_speeche_20210415_mary_c_daly
BibTeX
@misc{wtfs_regional_speeche_20210415_mary_c_daly,
author = {Mary C. Daly},
title = {Regional President Speech},
year = {2021},
month = {Apr},
howpublished = {Speeches, Federal Reserve},
url = {https://whenthefedspeaks.com/doc/regional_speeche_20210415_mary_c_daly},
note = {Retrieved via When the Fed Speaks corpus}
}