In short
Podcast Notes: Odd Lots - Episode: The Quiet Revolution in How We Rescue Banks
Episode Overview
- Hosts: Joe Weisenthal and Tracy Alloway
- Guest: Steven Kelly, Associate Director of Research at the Yale University Program on Financial Stability
- Key Topics:
- The evolution of emergency lending facilities for banks.
- Recent banking crises and the role of the Federal Reserve.
- Regulatory changes in the aftermath of the banking drama in 2023.
Background Context
- In early 2023, the US banking system experienced its first significant crisis since 2008, resulting in the collapse of three banks, including Silicon Valley Bank (SVB).
- This prompted discussions on how to improve the mechanisms for rescuing troubled banks, particularly regarding the discount window and other emergency facilities.
Key Concepts Discussed
- Emergency Lending Facilities
- Discount Window: A Federal Reserve facility allowing banks to borrow money, typically at a higher interest rate.
- Stigma: Accessing the discount window can signal weakness, leading to rumors and a loss of depositor confidence.
- Federal Home Loan Banks (FHLBs): Initially designed for mortgage lending, they evolved into alternative emergency lending facilities.
- Access Issues: Banks, like SVB, preferred using FHLBs due to ease of access compared to the discount window.
- Proposals for Change
- Pre-positioning Collateral: Proposed by Michael Hsu, requiring banks to maintain collateral at the discount window to ensure operational readiness in times of crisis.
- Reducing Stigma: The idea is to normalize the use of the discount window by requiring routine access, potentially reducing the stigma associated with its use.
- Impact of the Banking Crisis
- The collapse of banks like SVB highlighted the critical need for a robust liquidity framework.
- Regulatory changes are underway to require banks to hold more collateral and possibly adjust how facilities like FHLBs operate.
- Liquidity vs. Solvency
- The discussion addressed the crucial difference between liquidity (the ability to meet short-term obligations) and solvency (the ability to meet long-term debts).
- The pressures of market perception can quickly change the financial landscape for banks, leading to crises driven by liquidity issues.
- Regulatory Landscape
- Post-crisis regulatory reforms may involve stricter requirements for mid-sized banks that previously enjoyed some regulatory leniency, especially concerning capital requirements.
- There is a broader discussion about the desired structure of the banking system in the U.S., balancing the benefits of large, efficient banks with the community-focused approach of smaller banks.
Key Takeaways
- Banking Perceptions: The importance of public perception and the stigma associated with accessing emergency lending facilities can significantly impact a bank's health.
- Need for Evolution: There is a clear need for the evolution of the systems in place to manage bank crises, particularly in fostering a culture where using the discount window is normalized.
- Regulatory Challenges: The discussions around regulation highlight ongoing challenges in balancing effective oversight with the operational needs of banks, particularly mid-sized institutions that fell into risk during the recent crises.
- Future Outlook: The podcast hints at continued debates and potential reforms in the banking sector, particularly as economic conditions evolve.
Closing Thoughts The conversation highlighted the intricate dynamics of banking regulation, emergency lending, and the importance of maintaining depositor confidence. As the landscape shifts, the need for a resilient financial system remains paramount, with the recent banking events serving as a critical learning opportunity for policymakers and regulators.
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Additional Notes
- Related Episodes: Reference to previous discussions on the discount window and banking conditions from 2022 and early 2023.
- Listener Engagement: Encouragement for listeners to engage with the Odd Lots community via Discord and leave reviews on podcast platforms.
Written by AI. May contain mistakes. Listen to the episode to check what was said.
Transcript
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1:35Hello and welcome to another episode of the Odd Lots podcast. I'm Tracey Alloway. And I'm Joe Weisenthal. Joe, do you remember what we were doing this time last year? Nope, not really. I should say around this time last year. But yes, I can't really even remember last week at this point. But in the middle of January, we recorded an episode on the discount window. Yeah. Oh, on the discount window. Yes, I do. Why were we talking about the discount window? Just for the fun of it? No, because borrowing was going up. Right. Yes. Right. Yes. Okay. Yes. So in like February or something or maybe early March of last year.
2:15No, no. February, early March of last year, like we did that episode about like deposit rates and then that turned out to be very relevant. But even before that, you started writing about the rise in discount window borrowing. Yes, that's right. I think I wrote something in December. I think the headline was like, billions in discount window borrowing suggests all is not well with banks, which turned out to be fairly true come March because we did see a mini banking crisis, banking drama, whatever you want to call it, the collapse of three banks, including Silicon Valley Bank. But since then, there has been this massive discussion about how to tweak all these emergency financing programs for banks, what they should actually look like, how do we want the lender of last resort system to operate, and what does it mean for banks?
3:08If they have to hold back additional collateral in order to access these programs, then what does it mean for them from a capital or a revenue standpoint? So many things going on in this space right now. It's a little bit under the radar, but I think we should talk about it. Totally. It always is like there's this inherent challenge, right? And even with Silicon Valley Bank, even setting aside emergency borrowing, the thing I guess that people get anxious about is as soon as any financial institution makes moves to shore up liquidity, shore up finances, et cetera, that becomes a signal to investors or depositors, whoever.
3:48It's like, oh, wait, why do they feel the need to shore up their finances? And then you become a target and you start worrying about the share price and equity, et cetera. And it feels like this is like an inherent challenge for regulators, which is, of course, you want banks to be proactive. You want banks to have plenty of liquidity. You want them to have equity cushions. But if the act of doing so invites suspicions, then how do you get out of that puzzle? Well, exactly. And I think this is most apparent with the discount window where people talk about the stigma of accessing the discount window.
4:18And, you know, when you access it, it's supposed to be anonymous. The Fed doesn't publish who's actually tapping it until I think two years later. But you start to see rumors swirl. In the case of last year, when we saw the discount window borrowing start to go up in December, I think that was the proximate time when people started to ask questions about like, well, wait a second, what's going on with Signature? What's going on with Silicon Valley Bank? That might have contributed to some of the deposit withdrawals that we eventually saw. So the super interesting thing now is that people are talking about reforming the discount window as well as some other facilities.
4:55We saw the acting comptroller of the currency, Michael Su, also a former All Lots guest, talk about the idea of like, well, maybe we're going to require banks to tap the discount window every once in a while, just so the stigma maybe reduces. But also they have the operational readiness to do it when they really need to. Can I say something? It's almost inappropriate for... No, it's borderline... How are you going to make the discount window inappropriate? I'm curious now. So you know what I think whenever I hear this idea of like, well, if you just get everyone to do it, there's no stigma. Oh, I know exactly what you're going to say.
5:32I tweeted this once. I always think about the scene in the movie Billy Madison where the kid is really embarrassed because everyone can see that he peed his pants. And so wait, who's that actor who's in that? The comedian? Adam Sandler. Adam Sandler. He like splashes a bunch of water on his own pants. And so he's like, oh, everyone and everyone around has water on their own pants. There's nothing embarrassing about it. And in my mind, that's, I'm sorry, maybe I have a juvenile humor. That is always where my mind goes. If you have everyone do it, no one can be embarrassed about doing it. Okay. Well, on today's episode, why requiring banks to tap the discount window is the equivalent of splashing your pants with water.
6:14That's going to be the title of this episode. Excellent. Well, we really do have the perfect guest. It's someone we've wanted to get on the podcast for a long time. And I don't think he's been on before, though. We're going to be speaking with Stephen Kelly, Associate Director of Research at the Yale Program on Financial Stability. So, Stephen, thank you so much for coming on All Thoughts. Happy to be here and talk about Billy Madison. So how much did the banking drama of last year change attitudes towards emergency lending facilities? I guess another way of asking the question is, do we think that all these lender of last resort type things actually stood up to the test last year?
6:56Yeah. So it's a tricky question because obviously what comes after these crises is you go, why didn't it work? Right. It's there. The Fed can mint money. Why doesn't it work? You know, why didn't SVB just post everything at the window? And we can get into the various reasons about that. But basically, it's hopeless to say, oh, the discount window is going to work once you have a name that's in the headlines. And that's sort of the pressure we put on it sometimes. What the discount window is great for is sort of a macro story. It's great for Contagion. It's great for maybe a community bank that isn't facing the same kind of headline risks.
7:32It's never going to save that bank that's in the headlines. And we can go into all the reasons about why, but so much of the franchise value just gets destroyed so fast. And when you're talking about replacing all your depositors, well, what is a bank but a collection of its depositors? So you can put all the money you want in the window, but it's never going to save that bank. And that's just too much pressure on the window. Can good banks fail by taking on these counter signals to the market? So whether it's going to the Fed and trying to get additional liquidity, whether it's doing an equity sale at some point just to create that greater equity cushion.
8:11If the bank is fundamentally sound, can simply expressing concern be enough to bring it down? Because it does seem like, you know, people don't want to send that signals. Or ultimately, if the bank is good, then these are good moves to take and they'll survive it. Yeah. The biggest thing is if you can't get capital. I mean, capital is what protects the deposit layer of the balance sheet. So if you can't get capital as a bank, you're out of business. So SVB comes out March 8th last year with an 8K that says, oh, you know, we were kind of looking at raising$2.25 billion. We have$500 million of commitment.
8:44Like, that was enough to say, OK, they gave an inside look at the balance sheet and nobody wanted it. So it wasn't that they were raising capital. It was that they announced that there was this gap. Yeah. If they had come out on March 8th and said Warren Buffett is investing$2.5 billion, we would still have SVB today. Got it. Maybe this is a good place to sort of back up and dive into what exactly happened with SVB. So there seems to have been a reluctance or an inability to tap the discount window soon enough. But we also know in retrospect, with the benefit of hindsight, that they were tapping another emergency.
9:21Well, I should be careful here. It's not really supposed to be an emergency lending facility. I'm talking about the FHLBs, the Federal Home Loan Banks. We used to call these, by the way, we used to joke in like 2009 that FHLBs stood for free hubris loans for banks or find huge lumps of bucks. I love find huge lumps of bucks. But anyway, I mean, this is a facility. It was supposed to facilitate home ownership and help banks do mortgages for people, but it sort of transformed to become an alternate emergency lending facility. And we should definitely talk about why. But SVB was basically tapping that instead of the discount window.
10:03So walk us through what we saw from that particular bank in terms of the choices they made to access different types of liquidity. Yeah. So we call the FHLBs the flubs, which they don't love, but we'll deal with it anyways. So I think it's not unique to SVB that they sort of relied on the FHLBs. You know, there was an SNL sketch after 2008 during the original stress test where they sort of did a bit like the stress test was an actual exam that banks had to take. And, you know, Citigroup kept answering government bailout to all the questions. And that's... I never saw that. Yeah, I don't remember this either.
10:39That's sort of what happened with the FHLBs, particularly prior to March and prior to, you know, the supervisory pressure we've seen since where if you ask the bank, hey, what do you do if you really get pinched? They go, well, we'll go to the flub. You know, we have a great relationship with the FHLBs. I mean, that's another piece is that these FHLBs are a lot more commercial in nature than the Fed. But so that was sort of the contingency funding plan writ large across the system. And, you know, it sort of works if you need a billion or five billion. If you're SVB, it doesn't work if you need 40 billion because the FHLBs, they take government collateral, they take mortgage collateral.
11:13If you need to start posting, you know, commercial and industrial loans, something like that, corporate bonds, you got to go to the Fed. And if you're not set up at the Fed because it's annoying to do that, it's too expensive, you don't want to leave collateral there, whatever the reason, you run out of time. So some banks just aren't set up with the Fed, like it's too annoying? Exactly. That's the operational readiness argument for making them splash water on their pants slash go to the discount window. Right. So SVB literally couldn't get collateral to the Fed in time before the run is out. Again, the SVB story was over, so it didn't matter.
11:49But it's useful to be ready to go at the Fed because they can take effectively your whole balance sheet. Basically, any asset a bank will have, you can put to the window. I mean, that's why it exists. And the FHLBs, you know, because of this sort of housing origin and whatever other reasons, they just don't have that range. The same thing happened at Signature, by the way. And I think there was a really good speech by a Fed official. I can't remember who it was, but they were talking about how it had basically been five years since Signature tapped the discount window. And when it came time to tap again, you know, things are blowing up.
12:25You need to access emergency liquidity. The Signature staff didn't really understand the rules around collateral eligibility and what they had to do in order to actually go to the window and borrow money. So I can see the argument for why you would want people to, like, practice it. Hey, what happened to Signature? Who took over their assets again?
12:49I'm making a bit of a joke there. I'm aware of that. I'll have to check my Bloomberg. I think there's some sleepy bank no one's ever heard of. Yeah, NYCB. Okay. So no, this really, I mean, that sort of blew my mind at the time that like, here are these institutions. And I guess that weekend, obviously, I guess the Fed or the Treasury determined that there was some sort of emergency aspect of it. And we all know that there was this sort of rescue and they opened up this new program, the BTFP, which we'll talk about. But it sort of blew my mind that you could have this crisis. And part of it is like, well, what time is it?
13:23What time is the window actually open? Can we reopen the window? That sort of blew my mind. So what happened immediately, or maybe not immediately, but in the wake of all of this? We've sort of talked about the run-up and how they were, like, what changes did we see regulatory-wise in the wake of the SVB and signature disaster? So the biggest change, which is long overdue, is you got to post more collateral at the window. It's this term pre-positioning that we're starting to hear more and more of. And, you know, you got to practice. And we're hearing more from regulators that they would like a little more practice in this, you know.
13:58And this is probably the direction that supervision needs to go of like, hey, if you're not practicing, we're going to we're going to dock you. If you can't show that you can show up at the window and get liquidity when you need it, we're going to dock you from a supervisory perspective. But really, it's been a lot of pressure to send more collateral to the Fed. There is something like three trillion dollars of collateral at the Fed. We don't get like daily updates on this, but it's in that vicinity and we know it's been growing. And we're also hearing from regulators that there's maybe some reforms to be had and some new liquidity measures to take.
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16:02Discover how at MasterCard.com slash commercial acceptance. acceptance. Is pre-positioning a synonym basically for encumbrance? So the idea that I have a certain number of assets on my balance sheet, I'm going to have to use more of those or set more of those aside at the central bank in order to satisfy these new requirements. And therefore, they're going to be less available to me to do stuff, do creative and hopefully revenue generating things with them, like repo them out or something like that. So yes, that's part of the story. And the other thing I think about is like banks have a lot of loans.
16:38So those are just sitting there. If you move those to the Fed, you get over the hurdles of moving them. Like it's like you're repoing out your loans necessarily as a community bank. Just house them at the Fed. Don't leave them at the FHLBs. Send them to the Fed. And so that's going to be a piece of it. The other thing that may come here is some sort of carrot with that stick. So the hardest thing about the discount window is that it really can't be any cheaper. And that's the stigma is that it's really expensive. So if you have a deposit, which is yielding zero and you've got to go to the window, the Fed can say, oh, look, it's just the top of the Fed funds rate.
17:15But that's still, you know, right now it's 500 bips more than more than deposit. Oh, I see. So even if it's just like, you're just borrowing, even if it's just at the Fed funds rates. Yeah. Like really banks are borrowing from their depositors. That's way more or, you know, whatever it is now, it's not zero anymore, but whatever the typical deposit is. Right. So it's incredibly expensive. It would be great if you were Coca-Cola and you could go to the discount window, but you can't. So the way to destigmatize is to offer some sort of carrot. And if you can say, hey, if you pre-position collateral, we'll give you some credit towards your LCR or we'll give you some credit towards these other things.
17:48so you can self-insure less and do more profitable things with your balance sheet, that's maybe a viable route. And that's why prepositioning is sort of coming in vogue. Can you talk a little bit more about the rates available at, I guess, specifically the discount window versus the FHLBs? Because this is something I never quite understood. So if you go to the FHLB, the flub, I think they actually do something where they do look at unrealized gains and losses on your securities in order to see whether or not you're a viable entity to be lending money to. So if you are like super stressed, they might not actually lend you money.
18:30But on the other hand, it seems like everyone kept going to them. And I'm assuming it's because like the rate of borrowing is more attractive than the discount rate. Yeah. So that's a big piece of it. And it's the confidentiality. So the valuation thing you're thinking of is only unavailable for sale. So that's part of the story is you can still hide the losses and held to maturity to some degree. But the pricing is definitely advantageous. And nobody can write that story that you wrote last February, Tracy, where you're saying, OK, it looks like there's... December, please. Give me my extra two months.
19:02I think you told these banks to borrow so you can write the story. Nobody can write that story because the data is not... It's not public data. We don't get a weekly balance sheet like we did from the Fed. Why isn't it public? Because you don't want to run on the bank. Because the FHLBs are a private entity. They're cooperative, basically, put together by the banks. And so that's a piece of the stigma. And the funding is really good because this is, you know, it's a GSE. It's a government-sponsored enterprise. So when you have a crisis and there's a flight into government money market funds, what can they buy?
19:33They can buy treasuries and they can buy FHLB debt. And so you really have cheap issuance. And the FHLB pays out their earnings to members. They don't pay it out based on, you know, the biggest bank gets the biggest or, you know, everybody gets an equal share. Whoever borrows is who gets the earnings back. So it's literally, you know, a rebate to anybody who borrows. And so what we see is the FHLBs are always competitive with the Fed, often cheaper. And, you know, that drives part of the story, too, is that they just have this built in discount. So one other thing that's happened recently is the Fed has basically said they're going to end the BTFP program.
20:11I think in March, which was when it was supposed to end. And I was kind of amazed at some of the arbitrage story that came out a little while ago, the idea that banks could basically get free money from the Fed because of the way the rates were set on the BTFP versus other financing sources. How big of an issue was that? How much did that play into the decision to end it? And then, And I guess lastly, given what we're seeing now with one particular New York-based bank and the troubles there, is there a possibility that the BTFP gets extended? So I would say it's unlikely absent a wider crisis.
20:51The arbitrage story isn't really, it's not likely that that's why it was ended. It was ended because things, you know, NYCB notwithstanding, things have been calmer. There's not really the unusual and exigent circumstances the Fed looks for. I think it's probably why we found out in January that it was going to end in March and why they announced the rate change. Yeah, so the way the rate thing worked is the BTFP is for one year. The Fed charged one year OIS plus 10 basis points. So that was sort of the penalty built in. But what they're lending is reserves. And if you're a bank, you can leave those reserves at the Fed, not do anything with them, and earn interest on reserves.
21:25So this is sort of a new post-2008 thing that actually weighs into the expenses of the Fed. So when OIS plus 10 bips drops below IOR, you could just run that trade infinitely as long as you have the collateral and just sort of harvest the carry basically. Just for listeners and for myself, remind me again. So what exactly the BTFP stipulated? It was rolled out as part of the SVB emergency. I guess there were all these concerns about these losses on the hold to market book. But remind me what the actual design of that program was. So the biggest thing about the BTFP is that it took collateral at par value.
22:04Right, par. And so there was a lot of these treasuries, in particular in SVB cases, were like way off par because rates had shot up. Right. And so the critique at the time was, oh, my gosh, this is not how central banking works. You can't just lend at whatever value, blah, blah, blah. And that was pretty overblown because the BTFP still charges a market rate. So just like we were talking about before, they're not charging the deposit rate. They're charging 500 bips at the time. So all it did was term out a bank's losses because a mark-to-market loss on a held-to-maturity security from interest rates is representative of your funding cost over time to hold that security.
22:39Banks typically don't pay that actual rate if they're paying cheaper deposits. And that's why we ignore the accounting. But once you take that security to the Fed, if you take a 30-year treasury to the Fed for 30 years, just keep rolling that discount window alone, you're going to pay the market rate. And so those losses, you're going to realize them over time. So it solved the liquidity problem, but it didn't ignore these losses. Banks still had to deal with them. You just alluded to something that I wanted to ask you. This is sort of a provocative question. I know it's going to get you going, but liquidity versus solvency.
23:11That's not even a question. That's just a statement. What's the difference? Does it matter? So this is a common versus framing for basically synonyms in banking. Every time a bank fails, it's either one political party, it's definitely the executive who ran the bank. We just had a liquidity problem. We just needed more liquidity from the Fed. People freaked out. The question they can't answer is, why your bank? We don't have a panic that takes down JP Morgan. The idea that something can be a liquidity issue alone, it doesn't exist. These banks aren't chosen at random. Every bank at the very end looks like a liquidity issue because the The last thing they do is either fail to make a payment or look like they're about to fail to make a payment and the regulators show up.
23:58Well, can you have like a pure self-fulfilling prophecy? Like, couldn't someone start a false rumor or misunderstand social media? And I remember in the wake of SVB is like, oh, social media caused the bank run or all of these people on a ski trip in Aspen, I think, was like one of the stories. Like they were all like WhatsAppping with each other. And that's what caused the bank run. Like, could that is that a real thing? where a bank could go down? You say, well, yeah, but why are they targeting you? But maybe everyone just on the WhatsApp group says this is the bank that's in trouble. They could, but we just don't see that as really happening.
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24:34SVB was running on negative accounting equity for months and investors had discounted it. It's not just the SVB case. There has yet to be a case study where Twitter can come out or Bill Ackman can just take down Goldman Sachs because it goes back to what saying about Warren Buffett or the capital raise it if the franchise is strong and you have if you have contingent capital you don't have to worry if you don't have contingent capital the capital structure breaks down this is the thing Tracy that I still like to this day I don't quite understand which is that you know there was no question that they were running like negative equity and it was right there in like probably the 10q or like some sec filing but you know like all of these startups like supposedly love the bank.
25:18They target it. They understood they had like these special products so that founders could get mortgages by posting their RSUs as collateral, which other banks didn't. Like, I don't understand why they couldn't have monetized that franchise value, which now seems to be gone. So they did for so long. I mean, that's how they could afford running at negative accounting equity. It's like Amazon, right? How long did they take to turn a profit? But you had long-term viability. And the thing with SVB is like, okay, you can have the most loyalist depositors in the world, like every bank thinks they have.
25:51And SVB probably did. But what happened, what Tracy was observing with her article and what was happening before the run is they had to spend their money. The deposit balance at SVB was dependent on new IPOs that just weren't happening. So these venture capitalists are as loyal as can be, but they're just spending down their cash balances. And so the balance sheet unwinds. How much of the banking fragility that we've seen over the past year is basically an interest rate story? So, you know, setting aside IPOs, which dried up when interest rates increased, you also just have the losses on the bond portfolio.
26:29And to me, this is kind of it's kind of a non-issue, but it's also kind of a fundamental tension in the banking system, which is that you've built all the rules around the idea that like the best type of collateral is either cash or government bonds, which is fine when government bonds are really boring and not very volatile and there's not a lot happening. But when inflation starts to go up and the primary tool the central bank has to manage that is to affect the price of bonds, then we seem to have this like tension enter the system. For sure. That's how you end up with the BTFP, which, you know, sort of fits in this long trend, particularly at the Fed of like, what is a treasury and how much do we want to monetize it?
27:16Like, how often do we want to be intervening? How, you know, what different lending facilities do we have to set up? Who do we let? So it does sort of sit within that post 2008 tension of like, you know, we're really building the system on top of these safe assets and we kind of have to keep them money like. But yeah, that is the key vulnerability. But also there's so many banks who have that same vulnerability as SVU that didn't fail. So that's sort of the built in macro vulnerability. but the interest rate risk, you know, was also in tech and in innovation and in crypto. And so that's why we've seen like banks like Schwab, banks like Bank of America, like huge unrealized losses, but less concern about the franchise.
27:55Yeah. It seems like when I say non-issue, like it seems like there's a tension, but also I find it hard to believe that like the banking system is going to come down because banks have bought too many U.S. treasuries. Like that doesn't seem realistic. This was always the nuclear option that the Fed had is like the second you're worried about JP Morgan going down because of too many treasuries, the Fed's going to cut rates and just recapitalize the whole system. So it was also sitting in this tension of the Fed was tightening and didn't want to ease up on tightening. So that made it a harder dance, too.
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29:57And the best part? Odoo replaces multiple expensive platforms for a fraction of the cost. It's built to grow with your business, whether you are just starting out or already scaling up. Plus, it's easy to use, customizable, and designed to streamline every process, so you can focus on what really matters, running your business. Thousands of businesses have made the switch, so why not you? Try Odoo for free at odoo.com. That's O-D-O-O dot com. You wrote about this a little bit at the time, and I think even before SVB, what happens if we get into the situation in which the Fed is trying to put out a financial fire at the same time that it's trying to fight inflation, which was certainly the case in March 2023, because at that point, the hiking cycle had not yet reached its peak.
30:47And so, you know, they re-expanded the balance sheet. You know, some Twitter people thought that was QE or it wasn't. But like, what is like, talk to us about that tension of if the Fed, you know, it's like, You mentioned it's like, OK, let's say JP Morgan, we're getting into trouble. But, you know, that could happen at a time of high inflation. And as Tracy mentioned, you it could happen that some bank through the Treasury channel literally did. How do central bankers think about this tension or how do you resolve that? Well, central bankers might not. I mean, at the absolute limit, this is why crisis interventions are capital injections and guarantees and fiscal, you know, it's sort of all these things at once and why the discount, again, going back to the discount, why it's not always enough and why it doesn't solve every crisis.
31:27But that's exactly why you have to see, quote unquote, innovative things like valuing collateral at par. And the BTFP and the arbitrage and sort of the terming out losses is a little unique because all the losses really built up just in treasuries at the time. You know, if you're thinking about something like commercial real estate to pick a random asset class, the credit risk is endogenous to the Fed. Right. So it's not it's not a case where the losses necessarily materialize over time. The Fed can come along and write, you know, basically a put option on credit risk in a way that even valuing collateral at par, it sort of couldn't with the BTFP.
32:04So I mentioned at the beginning that we are seeing various attempts to tweak and in some cases like change significantly the way these various facilities are used. If you were Michael Su at the OCC or if you were Michael Barr, the vice chair of supervision at the Fed, if you were like the ultimate Michael, basically, how would you be arranging this constellation of facilities? Yeah, there's a few things. I mean, one, we can talk about the standing repo facility, but I might pop a blood vessel if we do that. I want to see that. OK, talk. No, no, we'll get to that. The biggest thing is you have to have some carrot at the window because the Fed.
32:45So it used to be, even in recent history, that there was a premium to go to the discount window, right? You want banks to be evaluated by the market when they're getting funding, and you don't want haircuts at the discount window being your effective collateral requirements. So there is a reason to not run everything out of the Fed, right? They're not asset managers. But at the same time, you have this tension where you want them to come when the time is right. So you have to have some incentive for the banks to go because the Fed can't go any lower on price. It used to be 100 basis point premium.
33:15We've seen the Fed lower this in crisis. They lowered it to zero over Fed funds in COVID, and it's been there since. So it's clear that they are keeping the discount window right at top of Fed funds. So they really can't go any lower because then we're in the BTFP problem where They're taking in less than you can pay on interest on reserves. So you have to have some regulatory carrot and stick, basically, for the discount window. So that's a big piece. Second thing is get the FHLBs out of the lender of last resort game. We sort of got a unique political moment in that the FHFA put out a report a few months back kind of saying this thing, right?
33:52Like, you know, my sense is Sandra Thompson, the head of the FHFA, cares about affordable housing, right? She doesn't want to be in this world of bankers just lending to each other, and it goes to a trillion dollars in a crisis. It's just sort of so far from where those institutions started. It's so far from the goal of housing. Get them out of the lender last resort game. Don't let them pay dividends based on who borrows. Pay dividends based on who does affordable housing or something along those lines. And basically write up a bunch of term sheets for all these different potential 13-3 facilities that you're going to have to roll out.
34:24because the other piece of this is like going back to your rates question, Joe. All we talk about now is central bank intervention. Like anytime a market blows up, it's where's the ECB? Where's the BOJ? Like buy equities now, bail out this bank, like especially since 2008. And where was all this before? It's like, well, they just cut rates. When we didn't have to worry about the zero lower bound, they just cut rates. And, you know, that was sort of the Greenspan playbook, right? Just like let some financial froth come out and then clean up the mess with rates. So that's sort of the other reason that we're talking about this more and more and more is we're worried about the zero lower bound.
34:58Talk to us about the standing repo facility. It seems like a good idea, you know, just always be there. Whoa, his head just exploded. Oh, shoot. Oh, shoot. It was nice knowing you, Stephen. It's okay. What's the downside? It always seemed like a good idea. So the standing repo facility is, so first of all, it's basically the discount window for treasuries and agencies. The nice thing about it is that it adds primary dealers. You hear the Fed talk about it and they want to add all these banks to it, but it's just the discount window. You can bring treasuries to the discount window. So that whole piece of it of like, let's get banks involved, it would really only be valuable if you as a bank, like the depository subsidiary, had collateral in the tri-party repo market.
35:40Because the Fed runs this program out of the tri-party repo market. It's not like the discount window in that sense. So that part's sort of goofy. It's nice to have it for the primary dealers. but there's two problems we have with it one and zoltan has talked about this on this podcast at length which is you're relying on the primary dealer's balance sheet to sort of on lend it to everybody you know repurpose the liquidity for every hedge fund that needs it in a time of crisis and that just doesn't work because balance sheets get pinched and then the alternative is like okay you let every hedge fund come directly to the fed and there are political and legal issues with that the other thing is again it's not like it takes a matched book right the same repo facility is not going to take your treasury and your future.
36:19So if you look at something like the basis trade and the risks we have around the basis trade, I take very little comfort in the standing repo facility, even though some folks do, because when the basis blows out, you basically have the cash price falls and the futures tighten, right? And that's what we saw in March 2020. And all the standing repo facility can do is replace your repo funding at that new market value. So it goes back to this issue of like, where do you value the collateral? It's not going to to recognize, oh, you have a future and you have a treasury. So I'm going to lend at the collective value of that portfolio.
36:53It's going to lend at the cash value of your dash to cash treasury that everybody's trying to get rid of. And so you're just going to get caught in that spiral. What does a bank do? No, seriously, what is the main product that a bank offers? Deposits. Can you explain it? And like when I think it's like, oh, I want to go to the bank, I want a loan. If a bank offers mostly deposits, why are they all so bad at actually matching the benchmark interest rate. Because deposits are a service. That's exactly why. I disagree. I got nothing from my bank. This is my argument. We should be paying the bank for deposits.
37:26I love easy online banking services and free ATM withdrawals. Why aren't I paying them? Well, not only that, it's the ledger, Tracy. It's the ledger of the whole economy. You cannot make a payment that isn't a deposit transfer happening somewhere at the back end. And that is a service that banks offer. And that is exactly why the franchise value can erode so quickly. Because if you say, oh, we have all the liquidity we need at the discount window because we're highly capitalized, which failed banks always have great capital ratios, right? So they can take their collateral to the window, haircut it, whatever.
37:58But you have no deposit franchise left. And the deposit franchise is what was allowing you to borrow at zero and lend at three. So that's your whole franchise value. I realize we've made it through this entire conversation without even touching the Basel endgame proposals. Should we do it? Yeah, let's go for it. All right, Basil. I mean, it's almost not worth it because it's not going to look anything like it does now. I mean, I don't even know. What does that mean? Well, there's a lot of places in it that look like easy fixes. You know, there's like weird charges that show up for like climate financing or like random distortions that happen in housing.
38:33So the Fed's going to look very responsive. It's going to look like it changed a lot of things. The other thing is they've sort of signaled that they want more consensus than they had putting out the proposal. and they had two dissents putting out the proposal. They had Mickey Bowman, who they're never going to get. She hates everything the Fed has done on the regulatory front in the last year. And it's Chris Waller, who has really talked about the operational piece, which is a little bit distorted. So the proposal sort of looks at charging for operational risk based on the size of a business.
39:04So the size of an asset management business would cause you to need to hold more capital. But those businesses tend to be very stabilizing. Like, look at what we've seen happen to Morgan Stanley. Like, it's a diversifying business. It's sort of an all-seasons business. So I think we'll probably see a lot of changes on the operational risk charges as well. Prior to SVB, I believe there were a lot of fights around the regulatory limits and whether stress tests about, like, banks that weren't the mega, too-big-to-fail banks, but weren't necessarily, like, the little tiny community banks out in the middle of nowhere.
39:37And I think like SVB and some of these others sort of like fell in that middle and in a way like probably harmed themselves because in retrospect, they probably just would have been better off taking a little bit of hit to profitability for a sort of like tighter regulatory requirement. What is happening with regulation for some of these more mid-sized banks? Well, I mean, the goal is to bring them all into sort of recognize them as big banks, which you know it seems why not do that there are like maybe legal reasons and blah blah blah and but i'm really not convinced but i'm also like fundamentally like if we take a step back from the capital regulation debate like we're talking about changing ratios from like 12 percent to 13 and a half like i get why a bank is annoyed i get why there's all these interest groups involved but like from a systemic perspective that's just not that interesting that's not gonna be the difference between 2008 and not and it's also not gonna be the difference between a profitable banking system that beats Europe and China and not.
40:32I mean, it is true that SVB had a carve out as a smaller bank. And there is discussion about whether or not those carve outs should exist. But just backing up for a second, big picture. I feel like in the U.S. we have yet to decide what we want the banking system to actually look like. So there's this sort of it's a wonderful life vision where you have all these local banks, community banks, even in New York, and they know you and they build up that relationship and, you know, you get those benefits. But on the other hand, there also, you know, our experience of last year is that maybe there is a benefit to being extremely large and efficient and having a funding advantage and things like that.
41:15And it feels to me like the regulators, politicians, basically everyone involved in this equation has yet to figure out exactly what they want. Yeah. And it's a hard thing to talk about because, you know, you can't go out as like Jay Powell and be like, I think we should have less banks because you'll have less banks by Friday, right? So it's a hard thing to talk about. And they've pushed back on this idea of like a barbell banking system, which is sort of the midsize ones get hollowed out, they either downsize or upsize, and you're left with community banks and bigger banks. And that is sort of the verdict of 2023 is you would say, okay, big banks did well, small banks did well, let's just get rid of the mid-sized banks.
41:56But, you know, there's small banks that are very dependent on the local economy. I will say, big picture, you cannot be a niche bank that is also under the pressure of financial markets. Like, you can't be focused on Silicon Valley and also, you know, need to raise equity and have attentive, you know, headlines. If you're a community bank, you can probably run on negative equity longer than, you know, a mid-sized bank that has to go to market and things like that. All right, Stephen Kelly, thank you so much for coming on All Thoughts and letting us trigger you for basically 40 minutes. I really appreciate it.
42:29That was great. Yeah, thanks, Stephen. Thanks, guys.
42:44So, Joe, I really enjoyed that conversation. I have a feeling it's going to be a very relevant one in 2024 as we start to see more movement on these various issues, including, you know, maybe reforming the discount window, whatever the Basel endgame actually ends up looking like. There are a few interesting things that I would pick out there. So one of them was Stephen's emphasis of how important the actual banking franchise, the deposit franchise is to funding. And, you know, if the franchise starts to go like that's when you do get the deposit issues and then you can't actually raise capital.
43:20And I think some of that did get lost in the conversation around SVB and Signature and First Republic, where it was more like, oh, these banks kind of got unlucky, like they bought too many bonds or whatever. No, that really connects some dots and crystallized a lot of things. And I had forgotten with SVB that prior to the run that did happen on the bank, there was the deposit shrinkage that was simply as a result of Silicon Valley financial conditions at the time, which is that there was no IPO window for a while there. And there was no new fundraising. So you didn't have these startups and stuff did not have fresh cash coming in.
44:01And they were in survival mode. And they're like spending down their money all the time. So there was this sort of like natural, it was not a run. It wasn't even about the treasuries. It was not about the report on the substack in January of that year. That's like, uh, Bern Hobart, the author of the diff, uh, newsletter. Uh, he's like, by the way, uh, Silicon Valley bank is insolvent. You guys should check this out. And like, people like ignored it for about four weeks. Um, it was not about that. It was just about the fact that, uh, the deposits were going down. Yeah. However, Joe, I really, I remain reluctant to pay my bank a fee.
44:33I don't want to. No, I, I mean, I don't, I, I like having free banking and I like having free access to ATMs and the website and a nice app and stuff like that, but it does really make sense and sort of like crystallize this point, which is that that is the only sub market rate borrowing in the world, right? Like basically for the banks. And there's a reason that they can get sub market rate because they also throw in this service for you. But you know, there was like that chart we had at our recent odd lots trivia night that Josh Younger showed, which was like the Fed funds rate. And then it's like, what is this rate below it?
45:07And there really is only one rate in the world that's going to ever be below the Fed funds rate. And that's like the special rate that banks can borrow at from their own customers. Deposits. Yeah. You did mention, I think, earlier in the intro that around this time last year, so in addition to the Bill Nelson on the discount window episode that we did in January, I think in February, probably, we spoke to Joe Abate over at Barclays about exactly this issue. So deposit rates, the beta to benchmark interest rates. So, yeah, I think we're pretty on the ball. We're pretty on the ball. And that talking, Stephen, that like put a bunch of things together, like a lot of like light bulbs went up.
45:49It's like, oh, I get why this is the case or I get why that's not really an ultimate fix, et cetera. So I really enjoyed that conversation. OK, on that self-congratulatory note. And the flubs. That's a good one. I'm going to start calling it that. That's so much easier to say than FHLB. Shall we leave it there? Let's leave it there. This has been another episode of the All Thoughts Podcast. I'm Tracy Allaway. You can follow me at Tracy Allaway. And I'm Joe Weisenthal. You can follow me at The Stalwart. Follow our guest, Stephen Kelly, at StephenKelly49. Follow our producers, Carmen Rodriguez at CarmenArmin, Dashiell Bennett at Dashbot, and Kale Brooks at Kale Brooks.
46:24Thank you to our producer, Moses Andam. For more OddLots content, go to Bloomberg.com slash OddLots, where we post transcripts. We have a blog and a weekly newsletter that Tracy and I write. And you can talk about all of these topics with fellow listeners 24-7 in the Discord, discord.gg slash oddlots. And if you enjoy Oddlots, if you like it when we do deep dives on emergency lending facilities for banks, then please leave us a positive review on your favorite podcast platform. And remember, if you are a Bloomberg subscriber, you can listen to all of our episodes absolutely ad-free. All you need to do is connect your Bloomberg account to Apple Podcasts.
47:05Thanks for listening.
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From the publisher
A little less than a year ago, the US financial system was rocked by its first major banking drama since 2008. While the crisis was eventually contained, and only three lenders ended up collapsing, the experience re-ignited an ongoing conversation about the way we rescue troubled lenders. Not only did the Federal Reserve launch a new liquidity program called the Bank Term Funding Program as part of its support to the banking system in 2023, but regulators are now talking about changing existing facilities, including the Federal Home Loan Banks (FHLBs) and the discount window. For instance, Michael Hsu of the Office of the Comptroller of the Currency's has proposed that banks be required to tap the discount window and "pre-position" collateral at the facility, just in case they one day need it. In this episode, we speak with Steven Kelly, associate director of research at the Yale University Program on Financial Stability, about the constellation of existing emergency facilities for banks, how they've evolved over time, and the changes that could be made to them now.
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