Why Regulate Shadow Banking? Ian Sheldon

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Why Regulate Shadow Banking? Ian Sheldon Andersons Professor of International Trade sheldon.1@osu.edu Department of Agricultural, Environmental & Development Economics Ohio State University Extension

Bank Capital Requirements 2010 Dodd-Frank Act did not mandate specific levels for banks capital requirements left it to Basel Committee on Banking Supervision September 2010 Basel III: - minimum equity capital set at 7% of assets - counter-cyclical buffer of up to 2.5% of assets imposed by regulators during good times Basel III is much tougher than Basel II implies the bankers incentive to game the system is even greater than before (Financial Times, 9/21/2010) 2

Financial Crisis and Banking Financial crisis triggered by systemic event increase in subprime mortgage defaults Caused bank run in shadow-banking sector forced rescues (Bear Stearns) and bankruptcies (Lehman Brothers) Pre-1930s, bank runs occurred when depositors sought to withdraw cash en masse Collapse of liquidity in recent crisis due to run on repurchase market - rise in price of haircuts and cessation of repo lending on certain collateral 3

Shadow Banking Issuance of short-term money market instruments (repo) based on asset backed securities (ABS) Players: broker-dealers, structured investment vehicles, and money market mutual funds (MMMFs) 2010 liabilities of $16 trillion Evolved over past 40 years due to: - competition MMMFs and junk bonds - regulatory change repeal of Glass-Steagall Act - innovation derivatives and securitization 4

Loans Shadow Banking Investors (MMMFs) $ Shares Retail Investors $ $ Securitization through SPVs Key: ABS = asset-backed securities MMMFs = money market mutual funds SPVs = Special Purpose Vehicles Repo Agreements $ Source: Gorton and Metrick (2010) Banks Loans $ Borrowers 5

Repo Agreements With cap on deposit insurance, large institutions have no access to safe short-term investments In repo market, Bear Stearns sells assets (collateral) to Fidelity for $Xm, and buys assets back at $Ym, where (Y-X)/X is repo rate investor keeps collateral if bank defaults on promise to repurchase Amount investor deposits with bank typically less than value of asset, i.e., there is a haircut Example: Bank sells asset worth $2m for $1.6m, and repurchases at $1.76m, repo rate = 10%, and haircut = 20% 6

Securitization Loan originators can sell claims to cash flows Multiple loans pooled, and assembled off-balance sheet in a trust - Special Purpose Vehicle Pool of loans tranched designation of classes of claimants on cash-flows, i.e., AAA through to BBB Example: 100 loans in pool, BBB tranche loses money if 1 loan not repaid, AAA tranche only loses if all 100 loans not repaid ABS sold to capital market to finance purchase of cash flows from originator or used as collateral in repo agreements 7

Why Securitization? Benign Story: Securitization spreads risks across wider range of investors lowers lending costs Also, if securitization done properly, senior tranches of ABS relatively easy for non-specialized investors to evaluate expands buyer-base Regulatory Arbitrage Story: Rules on bank capital requirements, i.e., 1988 Basel I provisions, avoided via off-balance-sheet vehicles 8

The Run on Repo 2007, investors became concerned about quality of ABS and began to pull back on short-term lending causing run on repo, with sharp increase in haircuts If borrower has $1 billion of ABS, and haircuts rise from 2% to 50%, equivalent to deposits falling from $980 to $500 million Borrowers forced to liquidate ABS, depressing prices via fire-sale effect, reducing value as collateral, and causing further pullback in short-term lending Liquidity crisis eventually backstopped by Federal Reserve after Lehman s collapse 9

The Run on Repo Source: Gorton (2009) 10

Shadow Banking Regulation AND THE* MAYBE Shadow banking ought to be regulated as it is new form of banking with same vulnerabilities as traditional banking What might regulation consist of? - the Good : independent of market conditions, minimum haircuts should be charged - the Bad : expansion of federal safety nets - the Maybe : limiting creation of pseudo-riskless securities * Stein (2010) 11

Relevant Citations (i) Gary Gorton (May 2009), Slapped in the Face by the Invisible Hand and the Panic of 2009 http://www.frbatlanta.org/news/conferen/09fmc/gorton.pdf (ii) Gary Gorton and Andrew Metrick (September 2010), Regulating the Shadow Banking System http://www.brookings.edu/~/media/files/programs/es/bpea/2010_fall_bpea_pape rs/2010fall_gorton.pdf (iii) Jerome Stein (May 2010), Securitization, Shadow banking, and Financial Fragility http://www.economics.harvard.edu/faculty/stein/files/securitizationshadowbankin gandfragilityrevised.pdf 12

Ian Sheldon Andersons Professor of International Trade Dept. Agricultural, Environmental & Development Economics The Ohio State University http://aede.osu.edu/people/ (speaker.5) (614) 292-2194 sheldon.1@osu.edu 10/25/2010 Policy & Outlook Program 13