Too big to fail and Bank Separation
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1 Too big to fail and Bank Separation Markus Henn Policy Officer Financial Markets, World Economy, Ecology & Development WEED Member of Working Group Financial Markets & Taxes, Attac Germany Contact: 21 August 2014 Paris
2 Banking structure Universal bank Commercial bank Investment/trading bank Deposit Loan Securities, Derivatives, Loans e.a. Savers Companies, Individuals Funds Exchanges Banks Trading either on clients' account or on own ( proprietary trading ) U.S. Glass-Steagall Act: no universal banks, abolished in
3 Bank size: example United Kingdom Bank assests GDP and largest bank (2012) % of GDP Billion US dollars Cash & similar Real Estate UK GDP HSBC Assets Repos Investment Other Loans 3 Quelle: Adair Turner (2010), What do banks do?
4 Financial crisis: commitment to end too big to fail Structure, size and interconnectednes of banks turned out to be reasons for the financial crisis. Ben Bernanke (2010): "to have a competitive, vital, and innovative financial system ( ) we have to end the too-big-to-fail problem once and for all." Angela Merkel (2010): Wie kann ich sicherstellen, dass die Banken, die Finanzinstitutionen nicht so groß werden, dass sie letztendlich immer ein Erpressungspotential für Staaten darstellen? Finance Watch (2013): A well-designed and effective structural reform is one of the most important measures to safeguard financial stability. 4
5 Overview on bank sepration reports and laws USA EU Paul Volcker John Vickers Erki Liikanen Dodd-Frank Act with Volcker Rule Final Provisions Vickers Report (UK) Liikanen Report (EU) German, French & UK laws EU Commission Draft Law EU & secondary UK law 5 Source Photos: Teemu Rajala, Wikimedia / IWF, flickr; all Creative Commons Licence
6 What kind of separation / prohibition? Volcker Vickers/UK Liikanen Commission Germany (1) Full separation (2) Holding (2) Holding (1/2) Mixed (2) Holding (1) Full separation (i.e. prohibition of activities for commercial banks) (2) Holding with separate entities ( ring fencing ) Commercial bank Investment/trading bank Deposit Loan Securities, Derivatives, Loans e.a. Companies, Savers Funds Exchanges Banks Individuals 6
7 Which banks exempted (thresholds)? Volcker Vickers/UK Liikanen no threshold (only for compliance programs) 25 billion retail deposits (probably) trading assets 100 billion or 15-25% of total assets Commission Prohibition: 30 billion total assets and trading actitivies of 70 billion or 10% of total assets and EU Globally Systematic Important Institutions Holding: list of criteria, little discretion of supervisors 29 banks in EU plus some non-eu Germany trading assets 100 billion or trading assets 20% of total and 90 billion total assets single case decision by supervisor High thresholds; trading assets appropriate (better e.g. derivatives? 7
8 Which activities seperated / prohibited? Volcker Proprietary trading Yes (but short term) Hedge Funds & Private Equity Funds (EU: AIF) Owning, sponsoring & other relations Vickers/UK Yes (Probably: relations to non ring-fenced entities) Liikanen Yes Shares & linked instruments Commission Yes (narrowly, probited, indirect too) Germany Yes (but short term) Shares & linked instruments (prohibited, indirect too) Sponsoring & guaranteeing Other Market making, securitization ea Market making Holding: market making, risky products Optional: market making, risky products 8
9 Which activity exempted (most important ones)? Volcker Vickers/UK Liikanen Commission EU sovereign bonds; client-related services; money market activities; funds: closed-ended, non-leveraged, long-term, venture capital Germany 9 U.S. sovereign bonds; risk-mitigating hedging; market making; funds: wholly owned, joint ventures, e.a.; several client services (e.g. as broker / agent), e.a. Not fully clear yet (secondary law), probably simple derivative trading; debt-equity swaps; securitization e.a. Heding services; simple securitization; money market funds; asset management; interbank lending Risk-mitigating hedging (client deals, interest, currency, liquidity); long-term shares; non-speculative trading
10 Summary Separation and down-sizing is particularly in the EU the missing piece to ensure an effective banking regulation Rules on separation / prohibition go into right direction but much too weak, particularly on the kind of separation (often holding only) and due to many exceptions (market making, hedging, fund shares/sponsoring) No effective down-sizing of banks the contrary has happened after the financial crisis Civil society needs to push for stronger reforms, particularly in the ongoing EU law making process 10
11 Thank you for your attention! Weltwirtschaft, Ökologie & Entwicklung World Economy, Ecology & Development
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