by Douglas J. Elliott Brookings Institution Press 2013 getAbstract 2013 Rating (10 is best) Overall: 7 Importance: 7 Innovation: 7 Style: 6 Take-Aways Americas regulatory response to the 2008 crisis ignored an opportunity to rethink the purpose and structure of the financial sector. The finance industrys purpose should be to serve the real economy by providing liquidity, acting as an intermediary and managing risk. Before the crisis, many large banks benefitted from an implicit government guarantee. Risk occurs when these too-big-to-fail institutions teeter, but the failure of a significant number of small banks can also pose a danger to the financial system. Capping the size of banks could lead to a reduction in overall economic benefits. Preventing banks from proprietary trading may not make practical economic sense. Regulators are exploring ring fencing to isolate deposit taking from riskier activities. The Volcker rule, which bans US banks from proprietary trading, could cause them to withdraw from securities activities. Regulators must understand the economics of scale and scope in the financial industry. If banks save money when they engage in both banking and the securities industry, restricting them from doing so could increase costs to society. Relevance What You Will Learn In this summary, you will learn: 1.) How the structure of the financial industry and its reform are intricately related, 2.) Why breaking up large banks and restricting their activities may not benefit the economy or society, and 3.) Why economic experts agree on the need for more research. Recommendation Governments responded symptomatically to the 2008 financial crisis and spent little time examining the structure and rationale of the financial system and its relationship to regulatory reform. The Economic Studies program at the Brookings Institution brought together experts and analysts from the US Federal Reserve System, universities and the financial industry to discuss fundamental issues related to the structure of finance. Among those participating were Daniel Tarullo, a member of the Board of Governors of the Federal Reserve System and the leader of the Feds financial reform efforts; Martin Baily, former chairman of the Presidents Council of Economic Advisers; and Donald Kohn, former vice chairman of the Federal Reserve Board. Baily and Kohn are senior fellows at Brookings. They and other speakers expressed a variety of opinions but all agreed on the need for more extensive research about a range of fiscal issues. getAbstract recommends this informed discussion to anyone who wants an overview of the debate about the US financial industry and its reform. Summary Peculiarities and Purpose Financial industry reform in the wake of the 2008 financial crisis has centered on preventing what went wrong then from happening again. But that response ignores an opportunity to ask basic questions about the proper purpose and structure of the financial sector. It fails to delve into what benefits finance should seek to achieve and how society can best organize the financial industry to achieve those goals. The financial industry is unique in the way its fortunes affect the broader marketplace. Its purpose should be to serve the real economy by providing liquidity, acting as an intermediary between savers and borrowers, and helping to manage risk. Most experts agree that it is not necessary for the government to support the industry for its own sake but that this sectors proper working is critical for overall economic growth and activity. Though no longer practiced widely, industrial organization (IO) the study of how industry structures achieve specific business or social objectives could provide important ideas on how the financial sector can better address socioeconomic needs. Organizing finance more effectively could lead to regulatory changes that would promote growth and stability while safeguarding the interests of all members of society. For regulators to design effective laws, they must understand the financial systems economies of scale and scope: Large banks can be more efficient than smaller institutions and can provide individuals, households and businesses with a wider range of cheaper products and services. Take the question of whether it makes sense to restrict deposit-taking institutions from participating in securities markets: If banks gain significant economies from engaging in both spheres of activity, restricting them to one or the other could impose greater costs on the public. On the other hand, if those economies exist because large banks operate with the unfair advantage of implicit government support, then constraints on size and activity would be rational remedies. In addition, IO would deal with the unseen dynamics of the financial industry, such as the extent of the cooperation necessary among banks to ensure credit and market liquidity. The financial sectors actions have unintended ripple effects that spread throughout an economy. These externalities are another industry dynamic. Mark-to-market accounting forces banks to recognize losses on assets when prices are tumbling. Banks interconnectedness with one another, with other institutions and with markets in general promotes contagion: When panic occurs, fear spreads quickly among market participants, forcing selling that pushes markets even lower. Societal Objectives Some financial sector parties have lost sight of the industrys societal responsibility. The 2008 financial crisis revealed many transactions and financial products with no underlying commercial value; rather, they existed only to enrich the participants. Yet it is hard to judge where value ends and speculation begins: Virtually all speculative transactions have at least the theoretical advantage of increasing liquidity in markets by raising the volume and frequency of activity. Whether any single speculative deals ability to improve market liquidity was worth the risk it brought to its participants and to the marketplace is unknowable. What is evident, however, is that individuals who transact for their own gain eventually join with other participants to produce an overall good for society, a concept that goes back at least as far as Adam Smith. But if the industrys structure promotes speculation at the expense of economic stability, regulators and industry experts need to investigate and change whats wrong with finance. More Questions than Answers Measuring the issues that affect financial institutions and their impacts on the economy is mostly conjecture; for instance, even experts have no way to determine how big or how integrated financial firms need to be. For now, the field lacks empirical evidence that proves the need for a rigorous reworking of the financial industry. However, more research that incorporates an IO emphasis could begin to address what kind of and how much banking reform is most effective. Other issues that require further study include the question of whether it makes sense to divide firms according to their lines of business, and how reducing the size of larger financial institutions would affect smaller ones. When economists discuss financial sector structural reform, they differ on whether banks are too big, but none think theyre too small, although, in relative terms, banking in the US is significantly smaller than in Europe and Japan. Large banks contribute significant economic advantages. A study by the Clearing House Association, an industry body, suggests that big banks create national benefits of between $50 billion to $110 billion annually through economies of scale, product offerings and financial innovation. A Federal Reserve Bank of St. Louis study points out that capping the size of banks at $1 trillion, a relatively high level, could lead to a reduction of $79 billion in overall economic benefits. But other experts argue that finance plays too big a role in the modern economy. The number of global banking positions more than tripled from 2000 to 2008. Some studies point out that economic efficiency declines with rapid financial growth and high levels of financial activity. And new research also suggests that rapid growth in financial intermediation is correlated with slower productivity growth in the wider economy. Too Big to Fail Certain financial service activities for instance, deposit taking are so vital to the future of the economy that the government should protect them with guarantees or a safety net. Firms and households need a place to deposit their money safely without fearing bank insolvency. That is why the Federal Reserve expanded its safety net to include money market mutual funds during the 2008 crisis: Even though these funds are neither regulated nor protected as deposit-taking institutions, consumers use them like banks. In the period leading up to the financial crisis, large banks profited from the view that the federal government implicitly guaranteed them against failure. Without that implied faith, these too-big-to-fail institutions would not have been able to borrow or would have had to borrow at higher interest rates. But estimating the monetary value to banks of such guarantees is impossible. Debate continues on whether post-crisis financial reforms and regulations, such as the Dodd-Frank Act, could make government bailouts unnecessary. Title II of Dodd- Frank authorizes the creation of an orderly liquidation mechanism for systemically important financial institutions. But Dodd-Frank might not go far enough. Under pressure from the finance industry, legislators have not addressed many of the core issues at the heart of the crisis. Because deposit-taking institutions might misuse the advantages of a safety net, arguments abound for breaking up the largest banks, through either compulsory restrictions or a system of incentives that would encourage massive institutions to shrink. Those who contest this assertion say that supporters of disassembling big banks often exaggerate its benefits, and contend that even if larger banks had broken into 20 smaller pieces before the financial crisis, the smaller units could have made the same mistakes and incurred similar risks and failures. The public presumes that letting smaller financial institutions fail poses fewer risks for the system than allowing large ones to collapse. History shows this may not be true. Government policy makers may decide that bailing out a significant number of small institutions is necessary, even at considerable cost to taxpayers, because their group failure presents a threat to the overall security of the financial system, as demonstrated in the US savings and loan crisis. Limits To mitigate the too-big-to-fail risk and keep the system from crashing all at once, government policy makers should focus on practical ways of limiting banks interdependence on each other. Dodd-Frank regulations stipulate and some Fed initiatives propose that banks with assets of more than $500 billion (the largest banks) should set limits on the exposure they have to each other and to the rest of the financial sector. These Single Counterparty Credit Limits (SCCLs) must balance efforts to reduce the contagion risks against stifling useful market activities. Many proposals for restructuring the financial industry suggest that regulators should prevent banking companies from participating in the securities market or, at the very minimum, restrict the scope of their activities. After the Great Depression, the US Congress passed the Glass- Steagall Act that forbade deposit-taking institutions from conducting securities transactions, thereby removing the conflict of interest that many then assumed was one of the causes of the 1930s crisis. Some economic historians today dispute that claim, and experts question whether the simplistic remedy of limiting banks activities makes any economic sense. Ring Fencing Constraining banks to conduct certain activities, like deposit taking or derivatives trading, in separate legal vehicles essentially shields federally insured deposits and bank depositors from the losses or failures arising from other riskier bank business. This ring fencing still exists in the US, which never wholly repealed the Glass-Steagall Act; instead, Congress revoked Glass-Steagall provisions that prevented commercial banks from associating with securities dealers under the same holding companys control. The law still precludes deposit-taking banks from engaging in securities activity, although their subsidiaries can do so. Stringent rules govern the interactions between the deposit-taking function and the securities affiliates of bank holding companies. In Europe, two regulatory initiatives are attempting to deal with these issues of safety through ring fencing. In the UK, the Independent Commission on Banking, also called the Vickers Commission, proposed to ring fence banks core deposit taking from their other financial activities. The European Commissions High Level Expert Group suggests that all securities trading whether proprietary trading or the market-making activities necessary to handle client needs should occur outside the ring- fenced deposit taker, an admission that regulators cant easily distinguish between proprietary trading and market- making activities. Part of the Dodd-Frank Act includes the Volcker Rule, which abolishes proprietary trading by banks and their affiliates. But commercial banks are central to US financial markets, and loans and credit are synergistically related to underwriting securities. Regulatory confusion could lessen the liquidity that enables markets to provide companies with well-priced equity and debt. Many experts worry that strict adherence to the Volcker Rule could cause market inefficiencies if large commercial banks were to withdraw from market-making activities. In addition, derivatives have become central to the risk management practices of firms, financial institutions and markets, so disentangling what are client-initiated trades from bank proprietary trading is difficult, to say the least. Finally, if regulations were to compel large commercial banks to withdraw from securities activities or restrict their involvement in these activities, the government should provide a period of transition to allow smaller firms to develop the necessary culture, risk management systems and counterparties to expand their trading. About the Author Douglas J. Elliott is a fellow in economic studies at the Brookings Institution, a nonprofit public policy organization based in Washington, DC.