Data Management: Does changing

The Macroeconomics of Shadow Banking by Alan Moreira and Alexi Savov Discussion by Fabio M Natalucci Board of Governors of the Federal Reserve System Federal Reserve Bank of Atlanta 2015 Financial Markets Conference Central Banking in the Shadows: Monetary Policy and Financial Stability Postcrisis The views expressed here are solely the responsibility of the author and should not be interpreted as reflecting the views of the Board of Governors of the Federal Reserve System or its staff. Main Question Is shadow banking an optimal outcome? Previous literature has emphasized

Shortage of entrepreneurial or financial intermediary net worth and the role of leverage in magnifying and propagating shocks Regulatory arbitrage as a driver of shadow banking growth This paper focuses on liquidity transformation Shadow banking is the process of issuing liquid securities against risky assets Shadow money is liquid only in normal times (not crash proof, illiquid at times of crashes) 1 The Elements of the Story Shadow banking is optimal

Households demand liquidity to insure against liquidity events Liquidity provision is constrained by collateral While money-like securities require enough collateral to remain liquid at all times, shadow money is cheaper to produce as it uses collateral when it is abundant Shadow banking allows for greater liquidity creation for each dollar of available collateral When uncertainty is low, increased liquidity supply results in a crowding out of money, greater savings, higher prices, investment, and growth 2

The Elements of the Story (contd) But booms in liquidity and economic activity lead to a buildup in economic fragility When uncertainty increases, households demand crash-proof liquidity Financial intermediaries reduce supply of overall liquidity to meet demand for collateral-intensive money Collateral premiums rise, asset price fall, investment and economic activity contract Endogenous collateral runs (or margin spirals) reinforce the downturn 3 Outline of the Discussion

A few thoughts on the assumptions and the policy implications of the paper Ex-ante vs. ex-post liquidity Equity issuance is not costless in the midst of a crisis Collateral runs vs. runs on financial institutions Externalities created by the shadow banking sector What would a central planner do? Monetary policy and regulatory initiatives in this framework The regulatory effort since the financial crisis Focus on liquidity risk

4 Ex-ante vs. Ex-post Liquidity In the model, households use liquid securities to insure against liquidity events but they are aware ex-ante that shadow money ceases to be liquid in a crash: L(t) = m(t) +s(t) [1-dJ(t)] Pre-crisis, however, shadow banking referred to the creation of ex-ante seemingly safe, seemingly liquid financial instruments (Tarullo 2012) Surge in demand for safe, liquid assets for precautionary or transactional purposes Met by shadow banking-driven creation of assets thought to be safe and

liquid 5 Ex-ante vs. Ex-post Liquidity contd But tail risk associated with shadow banking instruments had not been understood and internalized by either buyers nor sellers There was a widespread belief that risk-free assets could be created by augmenting an already seemingly safe asset with a promise by a financial institution to provide liquidity or bear credit losses Contractual provisions (e.g., ABCP) Implicit support (e.g., MMFs, triparty repo market, sec lenders) When investors questioned the credibility of that promise, and thus

the apparent safety and liquidity of those instruments, the financial system became suddenly vulnerable to runs 6 Equity Issuance is not Costless in a Crisis In the model, financial intermediaries can issue equity at no cost Any discrepancy between assets and the value of existing equity, shadow- money and money is always made up by issuing new equity In reality, financial institutions are rarely able to issue equity during a crisis Strains emerge in short-term funding markets Eventually investors see through the collateral and repo run turns into fully fledged runs on financial institutions

By contrast, the model predicts that the price of A (risky) capital is always higher with shadow banking than without because prices capitalize the lower funding costs in a shadow banking-driven boom. The possibility of future booms leads to less severe downturns. This seems to the result of the assumption that financial institutions do not fail 7 Externalities Created by the Shadow Banking In the model, shadow banking is optimal However, the economic boom driven by increased shadow banking liquidity is associated with a buildup in economic fragility Many models (e.g., Stein (2013)) show that economic agents do not internalize the

externalities from collateral constraints Fraction of asset lost in a crash Kappa A (t) What would be the social planners optimal mix of traditional vs. shadow banking intermediation? Should a central bank use its balance sheet and monetary policy framework to affect the mix of public/private short-term, safe assets available to investors? See Carlson et al. (2014) 8 Monetary Policy and Regulatory Initiatives The paper focuses on competitive equilibrium where shadow banking is optimal

We dont really know whether there is any reason for policy intervention without a welfare function and welfare analysis So I will discuss the implications of monetary policy and regulatory initiatives in the paper with this caveat in mind We can think of policy intervention as an exercise in comparative statics The policies considered are designed as a change in a particular parameter of the model 9 Monetary Policy and Regulatory Initiatives (contd) LSAPs In the model, asset purchases are interpreted as replacing risky capital A with safe capital B

LSAPs push up the price of risky capital and down the price of safe capital Because of additional available collateral, liquidity provision increases, boosting asset prices and investment In reality, the Federal Reserve purchased longer-term government securities in exchange for reserves to put downward pressure on long-term rates Portfolio balance channel Investors reach out the duration and credit curve --> prices of both safe and risky assets rise (yields decline) LSAPs as implemented in the model resemble more facilities like PDCF set up during the crisis 10

Monetary Policy and Regulatory Initiatives (contd) MEP In the model, OT reduces the duration of safe assets on the intermediarys balance sheet Central bank buys long-term bonds and sells floating-rate bonds Because floating-rate bonds cannot act as a hedge (they always trade at par), price of risky capital declines As a result, contrary to LSAP in the model, OT reduces total collateral available In reality, MEP was designed to have an effect similar to LSAP Purchases of longer-term government securities were financed with sales of short-term government securities Difference is that Federal Reserve balance sheet was unchanged in size

11 Monetary Policy and Regulatory Initiatives (contd) Liquidity requirements Liquidity regulation is introduced as an upper bound on the issuance of total liquid securities (money and shadow money) in order to limit liquidity mismatches with illiquid assets But the definition of liquidity regulation seems at odds with LCR and NSFR LCR = (stock of HQLA / total net cash outflows over 30 days) > 100% NSFR = (ASF / RSF) >100% Volcker rule Interpreted as a mandatory segregation of safe and risky assets, it reduces liquidity provision by preventing asset pooling

How would the result change if the high costs of financial crisis are explicitly accounted for in welfare analysis? SLR Would a leverage ratio have any impact in this framework? Likely not if equity is costless 12 In Sum Very elegant, thought provoking paper The model has many potentially testable predictions (e.g., equity premium or safety premium that evolves with uncertainty)

It would be nice to see these empirical results 13 Shadow Banking and Uncertainty 14 Shadow Banking and Crash Risk 15 Concluding

We need to think harder about socially optimal mix of intermediation More broadly, about the balance between financial stability and growth Finally, further analysis seems appropriate to better assess the interaction between policy actions and liquidity transformation activities 16 The Regulatory Effort Since the Crisis A brief tour of the regulatory effort since the financial crisis (Powell 2015)

Financial institutions: a stronger core of the financial system Higher levels of higher quality capital (risk-based ratios and SLR) Liquidity regulation (LCR, NSFR, liquidity stress testing) Forward-looking, dynamic capital stress testing FSB work on margin rules for SFTs Ongoing work on resolution of large financial institutions Financial infrastructures: a more resilient plumbing of the system Triparty repo market reform Centrally-cleared standardized derivatives and CCPs SEC 2014 MMF rule amendments 17 The Regulatory Effort Since the Crisis (contd)

Will risks and activities move to the more opaque, less regulated periphery of the financial system? Will risks emerge in different forms and shapes? For example, new ways to provide financial leverage or perform liquidity transformation Do we understand them? Can we monitor them? Do we have the tools to address them? A concern is that liquidity transformation and risk has migrated to the periphery of the system 18

AUM and Dealer Inventories 19 Liquidity Risk According to a number of market participants, the combination of more conservative risk management practices since the crisis, various regulatory initiatives, and evolving market structure has resulted in a significant decline in liquidity across a number of markets How significant is the deterioration in liquidity? Are there any policy implications/risks? Example: 2013 taper tantrum

20 Balance Sheet Capacity and Market Liquidity during the 2013 Selloff in Fixed Income Markets by T. Adrian, M. Fleming, J. Goldberg, M. Lewis, F. Natalucci, and J. Wu (FEDS Notes October 2013) 21

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