Structural Reforms
Featured Piece
“Universal Banking and the Financial Architecture,” by Professors Ingo Walter, Anthony Saunders, Quarterly Review of Economics and Finance, (June 2012)ABSTRACT
Discussions of systemic risk after the financial crisis of 2007–09 have focused heavily on so-called “systemically important financial institutions” (SIFIs) a cohort of financial firms that is almost exclusively (but not necessarily) comprised of large, complex and heavily interconnected financial conglomerates. This paper considers the economic and strategic drivers of SIFIs – if such institutions are a key source of systemic risk, it is important to understand how and why they get that way. The paper then sets forth a public-interest perspective on the financial architecture by setting out key benchmarks – static and dynamic efficiency, stability and robustness, and competitiveness – and the tradeoffs that exist between them, and examines how SIFIs can support or detract from these benchmarks. If SIFIs are to be subject to much sharper prudential regulation, its impact must be calibrated against systemic performance benchmarks. Finally, the paper focuses on some of the major regulatory initiatives following the 2007–09 financial crisis, and in particular the US Dodd-Frank legislation of 2010, in terms of their possible impact on business models of SIFIs. The paper concludes that improving the financial architecture in a disciplined, consistent, internationally coordinated and sustained manner with a firm eye to the public interest should ultimately be centered on market discipline. By being forced to pay a significant price for the negative externalities SIFIs generate – in the form of systemic risk – managers and boards will have to draw their own conclusions regarding optimum institutional strategy and structure in the context of the microeconomics and industrial organization of global financial intermediation. If this fails, constraints on their size, complexity and interconnectedness will be a major part of the policy reaction to the next financial crisis.
In the Media
Ring-fencing is good, but no panacea, by Professor Viral Acharya, in "The Future of Banking", Vox eBook, Oct 2011.
Papers
ABSTRACT
Discussions of systemic risk after the financial crisis of 2007-09 have focused heavily on so-called “systemically important financial institutions” (SIFIs) a cohort of financial firms that is almost exclusively (but not necessarily) comprised of large, complex and heavily interconnected financial conglomerates. This paper considers the economic and strategic drivers of SIFIs - if such institutions are a key source of systemic risk, it is important to understand how and why they get that way. The paper then sets forth a public-interest perspective on the financial architecture by setting out key benchmarks - static and dynamic efficiency, stability and robustness, and competitiveness - and the tradeoffs that exist between them, and examines how SIFIs can support or detract from these benchmarks. If SIFIs are to be subject to much sharper prudential regulation, its impact must be calibrated against systemic performance benchmarks. Finally, the paper focuses on some of the major regulatory initiatives following the 2007-09 financial crisis, and in particular the US Dodd-Frank legislation of 2010, in terms of their possible impact on business models of SIFIs. The paper concludes that improving the financial architecture in a disciplined, consistent, internationally coordinated and sustained manner with a firm eye to the public interest should ultimately be centered on market discipline. By being forced to pay a significant price for the negative externalities SIFIs generate - in the form of systemic risk - managers and boards will have to draw their own conclusions regarding optimum institutional strategy and structure in the context of the microeconomics and industrial organization of global financial intermediation. If this fails, constraints on their size, complexity and interconnectedness will be a major part of the policy reaction to the next financial crisis.
Discussions of systemic risk after the financial crisis of 2007-09 have focused heavily on so-called “systemically important financial institutions” (SIFIs) a cohort of financial firms that is almost exclusively (but not necessarily) comprised of large, complex and heavily interconnected financial conglomerates. This paper considers the economic and strategic drivers of SIFIs - if such institutions are a key source of systemic risk, it is important to understand how and why they get that way. The paper then sets forth a public-interest perspective on the financial architecture by setting out key benchmarks - static and dynamic efficiency, stability and robustness, and competitiveness - and the tradeoffs that exist between them, and examines how SIFIs can support or detract from these benchmarks. If SIFIs are to be subject to much sharper prudential regulation, its impact must be calibrated against systemic performance benchmarks. Finally, the paper focuses on some of the major regulatory initiatives following the 2007-09 financial crisis, and in particular the US Dodd-Frank legislation of 2010, in terms of their possible impact on business models of SIFIs. The paper concludes that improving the financial architecture in a disciplined, consistent, internationally coordinated and sustained manner with a firm eye to the public interest should ultimately be centered on market discipline. By being forced to pay a significant price for the negative externalities SIFIs generate - in the form of systemic risk - managers and boards will have to draw their own conclusions regarding optimum institutional strategy and structure in the context of the microeconomics and industrial organization of global financial intermediation. If this fails, constraints on their size, complexity and interconnectedness will be a major part of the policy reaction to the next financial crisis.
ABSTRACT (Click Here for Paper)
The Gramm-Leach Bliley Act (GLBA), which was hailed at the time of its enactment in 1999, has recently been flailed by critics who claim that it was a major cause of the financial crisis of 2007-2009. These critics often call for a revival of the Glass-Steagall barriers between commercial banking and investment banking, which the GLBA largely eliminated. The so-called Volcker Rule is a recent manifestation of this anti-GLBA sentiment. After reviewing the Glass-Steagall Act of 1933 and related subsequent developments, this paper discusses the enactment of GLBA and demonstrates that the GLBA and little or nothing to do with the crisis and thus that a re-enactment of the Glass Steagall barriers or enactment of the Volcker Rule would not prevent future such barriers. The paper argues that the GLBA's erection of a new barrier to a non-financial firm's ownership of a depository institution was misguided. Thus, in an important sense, the GLBA did not go far enough in breaking down barriers.
The Gramm-Leach Bliley Act (GLBA), which was hailed at the time of its enactment in 1999, has recently been flailed by critics who claim that it was a major cause of the financial crisis of 2007-2009. These critics often call for a revival of the Glass-Steagall barriers between commercial banking and investment banking, which the GLBA largely eliminated. The so-called Volcker Rule is a recent manifestation of this anti-GLBA sentiment. After reviewing the Glass-Steagall Act of 1933 and related subsequent developments, this paper discusses the enactment of GLBA and demonstrates that the GLBA and little or nothing to do with the crisis and thus that a re-enactment of the Glass Steagall barriers or enactment of the Volcker Rule would not prevent future such barriers. The paper argues that the GLBA's erection of a new barrier to a non-financial firm's ownership of a depository institution was misguided. Thus, in an important sense, the GLBA did not go far enough in breaking down barriers.
ABSTRACT (Click Here for Paper)
This paper reexamines the separation of commercial and investment banking in the context of modern wholesale financial environment, dominated by a small cohort of “systemic” institutions. The paper traces the pathology of regulation and deregulation from the watershed events of the 1930s to the systemic financial failures of the recent past. It then considers the structure, conduct and performance of the wholesale financial industry and how firms that cannot be allowed to collapse get that way. Based on the industrial organization of global wholesale finance, the paper then examines the available regulatory techniques, and makes some judgments as to their relative promise in promoting future financial stability with least possible dislocation of financial efficiency, proposing benchmarks for the calibration of proposals for regulatory reform. The paper then evaluates functional separation and carve outs of high-risk activities that cannot defensibly be conducted within systemic financial firms in the real world of power politics and regulatory capture. The paper concludes that blanket condemnation of the functional separation features of the 1930s financial reforms is unwarranted in the light of ongoing experience, and that it is time to revisit this issue in reconfiguring the global wholesale financial architecture.
This paper reexamines the separation of commercial and investment banking in the context of modern wholesale financial environment, dominated by a small cohort of “systemic” institutions. The paper traces the pathology of regulation and deregulation from the watershed events of the 1930s to the systemic financial failures of the recent past. It then considers the structure, conduct and performance of the wholesale financial industry and how firms that cannot be allowed to collapse get that way. Based on the industrial organization of global wholesale finance, the paper then examines the available regulatory techniques, and makes some judgments as to their relative promise in promoting future financial stability with least possible dislocation of financial efficiency, proposing benchmarks for the calibration of proposals for regulatory reform. The paper then evaluates functional separation and carve outs of high-risk activities that cannot defensibly be conducted within systemic financial firms in the real world of power politics and regulatory capture. The paper concludes that blanket condemnation of the functional separation features of the 1930s financial reforms is unwarranted in the light of ongoing experience, and that it is time to revisit this issue in reconfiguring the global wholesale financial architecture.
ABSTRACT
The application in July 2005 by Wal-Mart to obtain a specialized bank charter from the state of Utah and to obtain federal deposit insurance reopened a national debate concerning the separation of banking and commerce. Though Wal-Mart withdrew its application in March 2007, the issue and the debate continue. This article offers a principles-based approach to this issue that begins with the recognition that banks are special and that safety and soundness regulation of banks is therefore warranted. Building on that recognition, the article lays out the principle that the “examinability and supervisability” of an activity should determine if that activity should be undertaken by a bank. Even if an otherwise legitimate activity is not suitable for a bank, it should be allowed for a bank's owners (whether the owners are individuals or a holding company), so long as the financial transactions between the bank and its owners are closely monitored by bank regulators. The implications of this set of ideas for the Wal-Mart case and for banking and commerce generally are then discussed.
The application in July 2005 by Wal-Mart to obtain a specialized bank charter from the state of Utah and to obtain federal deposit insurance reopened a national debate concerning the separation of banking and commerce. Though Wal-Mart withdrew its application in March 2007, the issue and the debate continue. This article offers a principles-based approach to this issue that begins with the recognition that banks are special and that safety and soundness regulation of banks is therefore warranted. Building on that recognition, the article lays out the principle that the “examinability and supervisability” of an activity should determine if that activity should be undertaken by a bank. Even if an otherwise legitimate activity is not suitable for a bank, it should be allowed for a bank's owners (whether the owners are individuals or a holding company), so long as the financial transactions between the bank and its owners are closely monitored by bank regulators. The implications of this set of ideas for the Wal-Mart case and for banking and commerce generally are then discussed.
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