A commenter directed me to an excellent article by Richard Werner comparing three different approaches to banking. The first two are commonly found in the economics literature, and the third is the credit creation theory of banking. Werner’s article provides a very good analysis of the three approaches, and weighs in heavily in favor of the credit creation theory.
Werner points out that when regulators use the wrong model, they inadvertently allow banks to do things that they should not be allowed to do. More precisely, Werner finds that when regulators try to impose capital constraints on banks without understanding how banks function, they leave open the possibility that the banks find a way to create capital “out of thin air,” which clearly is not the regulator’s intent.
In this post I want to point out that Werner does not give the best example of how banks can sometimes create their own capital. I offer two more examples of how banks created their own capital in the years leading up to the crisis.
1. The SIVs that blew up in 2007
You may remember Hank Paulson running around Europe in the early fall of 2007 trying to drum up support for something called the Master Liquidity Enhancement Conduit (MLEC) or more simply the Super-SIV. He was trying to address the problem that structured vehicles called SIVs were blowing up left, right, and center at the time.
These vehicles were essentially ways for banks to create capital. Here’s how:
According to a Bear Stearns report at the time, 43% of the assets in the SIVs were bank debt, and commentators a the time make it clear that the kind of bank debt in the SIVs was a special kind of debt that was acceptable as capital for the purposes of bank capital requirements because of the strong rights given to the issuer to forgo making interest payments on the debt.
The liability side of a SIV was comprised of 4-6% equity and the rest senior liabilities, Medium Term Notes (MTNs) of a few years maturity and Commercial Paper (CP) that had to be refinanced every few months. Obviously SIVs had roll-over (or liquidity) risk, since their assets were much longer than their liabilities. The rating agencies addressed this roll-over risk by requiring the SIVs to have access to a liquidity facility provided by a bank. More precisely the reason a SIV shadow bank was allowed to exist was because there was a highly rated traditional bank that had a contractual commitment to provide funds to the SIV on a same-day basis in the event that the liquidity risk was realized. Furthermore, triggers in the structured vehicle’s paperwork required it to go into wind down mode if, for example, the value of its assets fell below a certain threshold. All the SIVs breached their triggers in Fall 2007.
Those with an understanding of the credit creation theory of banking would recognize immediately that the “liquidity facility” provided by the traditional bank was a classic way for a bank to transform the SIV’s liabilities into monetary assets. That’s why money market funds and others seeking very liquid assets were willing to hold SIV CP and MTNs. In short, a basic understanding of an SIV asset and liability structure and of the banks’ relationship to it would have been a red flag to a regulator conversant with the credit creation theory that banks were literally creating their own capital.
2. The pre-2007 US Federal Home Loan Bank (FHLB) System
In the early naughties all of the FHLBs revised their capital plans. For someone with an understanding of the credit creation theory, these capital plans were clearly consistent with virtually unlimited finance of mortgages.
The FHLBs form a system with a single regulator and together offer a joint guarantee of all FHLB liabilities. The FHLB system is one of the “agencies” that can easily raise money at low cost on public debt markets. Each FHLB covers a specific region of the country and is cooperatively owned by its member banks. In 2007 every major bank in the US was a member of the FHLB system. As a result, FHLB debt was effectively guaranteed by the whole of the US banking system. Once again using the credit creation theory, we find that the bank guarantee converted FHLB liabilities into monetary assets.
The basic structure of the FHLBs support of the mortgage market was this (note that I will frequently use the past tense, because I haven’t looked up what the current capital structure is and believe that it has changed):
The FHLBs faced a 4% capital requirement on their loans. Using the Atlanta FHLB’s capital plan as an example, we find that whenever a member bank borrowed from the Atlanta FHL bank, it was required to increase its capital contribution by 4.5% of the loan. This guaranteed that the Atlanta FHL bank could never fall foul of its 4% capital requirement — and that there was a virtually unlimited supply of funds available to finance mortgages in the US.
The only constraint exercised by FHLBs on this system was that they would not lend for the full value of any mortgage. Agency MBS faced a 5% haircut, private label MBS faced a minimum 10% haircut, and individual mortgages faced higher haircuts.
In short, the FHLB system was designed to make it possible for the FHLBs to be lenders of last resort to mortgage lenders. As long as a member bank’s assets were mortgages that qualified for FHL bank loans, credit was available for a bank that was in trouble.
The system was designed in the 1930s — by people who understood the credit creation theory of banking — to deliberately exclude commercial banks which financed commercial activity and whose last-resort lender was the Federal Reserve. Only when the FIRRE Act in 1989 was passed subsequent to the Savings and Loan crisis were commercial banks permitted to become FHLB members.
From a credit creation theory perspective this major shift in US bank regulation ensured that the full credit creation capacity of the commercial banking system was united with the US mortgage lending system making it possible for the FHLBs to create their own capital and use it to provide virtually unlimited funds to finance mortgage lending in the US.