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The Welfare Effects of Bank Liquidity and Capital Requirements
Skander Van den Heuvel*
Federal Reserve Board
FDIC/JFSR Bank Research Conference September, 2018
* The views expressed here do not necessarily represent the views of the Federal Reserve Board or its staff.
The Welfare Effects of Bank Liquidity and Capital Requirements 2
Introduction Financial crisis spurred crucial regulatory reforms, including Basel III.
• Stronger capital requirements • New liquidity requirements
Goal: Make banks and the financial system safer, limiting negative externalities from bank failures.
Is it enough? Too much? There is an ongoing debate. E.g.
• Some favor much higher capital requirements (e.g. Admati and Hellwig) • Others have argued for versions of “narrow banking” (e.g. Cochrane, Friedman)
o Similar to a 100% liquidity requirement
The Welfare Effects of Bank Liquidity and Capital Requirements 3
Introduction
Debate in large part reflects disagreement about the existence and magnitude of social costs of capital and liquidity requirements.
Possible cost – reduced (net) liquidity creation.
Key idea: High-quality liquid assets are in limited supply and have important alternative uses.
o E.g. Krishnamurthy and Vissing-Jorgenson (2012), Greenwood, Hanson and Stein (2015).
The Welfare Effects of Bank Liquidity and Capital Requirements 4
Introduction This paper –
• Examines the welfare costs and benefits of:
o bank liquidity requirements and
o bank capital requirements
• Quantifies their welfare costs through a sufficient statistics approach. Quantitative general equilibrium analysis
• Extends previous work on capital requirements (Van den Heuvel, 2008)
The Welfare Effects of Bank Liquidity and Capital Requirements 5
1. Basic Model
HouseholdsFin. wealth = d + e + b
Banks
Bank equity
Deposits
Firms
Non-bankFinance
GovernmentTot. debt = b + B
HouseholdsFin. wealth = d + e + b
BanksLoans L Equity EGov. Bonds B Deposits DBank equity
Deposits
FirmsGovernmentTot. debt = b + B
Bonds
HouseholdsFin. wealth = d + e + b
BanksLoans L Equity EGov. Bonds B Deposits D
FirmsPhysical Equity EF
Capital K Loans L
Non-bankfinance
GovernmentTot. debt = b + B
HouseholdsFin. wealth = d + e + b
BanksLoans L Equity EGov. Bonds B Deposits D
FirmsPhysical Equity EF
Capital K Loans L
GovernmentTot. debt = b + B
Bonds
HouseholdsFin. wealth = d + e + b
BanksLoans L Equity EGov. Bonds B Deposits DBank equity
Deposits
FirmsPhysical Equity EF
Capital K Loans L
Non-bankfinance
GovernmentTot. debt = b + B
Bonds
The Welfare Effects of Bank Liquidity and Capital Requirements 6
Households
Households value liquidity:
( , , )u c d b
• Derived utility function; Feenstra (1985).
• Increasing and concave
• Flexibility will let the data speak
The Welfare Effects of Bank Liquidity and Capital Requirements 7
Households
Infinite horizon, no aggregate uncertainty Perfect foresight problem.
0{ , , , } 0max ( , , )
t t t t t
tt t t
c d e b tu c d bβ
∞=
∞
=∑
1 1 1s.t. 1 D B Et t t t t t t t t t t td b e c w R d R b R e T+ + ++ + + = + + + −
(c) ( ) 1
1 1 1( , , ) ( , , )Et c t t t c t t tR u c d b u c d bβ −
− − −=
(d) ( , , )( , , )
E D d t t tt t
c t t t
u c d bR Ru c d b
− = : convenience yield on deposits
(b) ( , , )( , , )
E B b t t tt t
c t t t
u c d bR Ru c d b
− = : convenience yield on Treasuries
The Welfare Effects of Bank Liquidity and Capital Requirements 8
Banks
Lt Loans Dt Deposits Bt Bonds Et Equity
Liquidity Requirement: t tB Dλ≥ Capital Requirement: t tE Lγ≥ (risk-based) Bank maximizes shareholder value. • Competitive banking: , , ,L B D ER R R R given
The Welfare Effects of Bank Liquidity and Capital Requirements 9
Banks: Moral Hazard and Benefits of Regulation Additional assumptions to generate benefits of regulation: Deposit Insurance / government guarantees
Moral hazard of excessive risk taking. Two risk choices:
1. Credit risk: excessively risky lending practices
2. Liquidity risk: insufficient liquid assets
The Welfare Effects of Bank Liquidity and Capital Requirements 10
Banks: Moral Hazard and Benefits of Regulation Deposit Insurance / government guarantees
Moral hazard of excessive risk taking. Two risk choices:
1. Credit risk: excessively risky lending practices
Capital requirement solves this, together with bank supervision, through “skin-in-the-game”.
/ ERεγ φ σ≥ (IC1)
o σ : ability of banks to hide excessively risky loans from supervision o Liquidity regulation does not ameliorate this problem. Bank size is not fixed so increase in B does not imply a decrease in L.
The Welfare Effects of Bank Liquidity and Capital Requirements 11
Banks: Moral Hazard and Benefits of Regulation Deposit Insurance / government guarantees
Moral hazard of excessive risk taking. Two risk choices:
2. Liquidity risk: insufficient liquid assets
o Small probability (1 – p) of liquidity stress: Fraction w of depositors withdraws early. o Liquidity stress results in bank failure if B wD< .
Bank goes into resolution with social costs that may exceed the private loss
The Welfare Effects of Bank Liquidity and Capital Requirements 12
Banks: Moral Hazard and Benefits of Regulation Bank will choose a prudent liquidity risk profile (B wD≥ ) if
1 (1 ) ( )1 1
D Bp w R Rp w
λγ γλ
− ≥ − − − − − (IC2)
A sufficient condition is: wλ ≥ . Liquidity requirement and capital requirement can each mitigate the moral hazard of liquidity risk, but the liquidity requirement is more direct and efficient. Division of Labor:
• Capital regulation for solvency risk
• Liquidity regulation for liquidity risk.
The Welfare Effects of Bank Liquidity and Capital Requirements 13
Banks: Illustration of welfare implications
The Welfare Effects of Bank Liquidity and Capital Requirements 14
Banks: Illustration of welfare implications
The Welfare Effects of Bank Liquidity and Capital Requirements 15
Summary of Bank’s Problem (no excessive risk)
Lt Loans Dt Deposits
t tB Dλ≥ Bonds t tE Lγ≥ Equity
All-in cost of funding loans with deposits:
( ) ( )1
D D D BR R R Rλλλ
≡ + −−
With (IC1) and (IC2), solution’s zero-profit condition:
(1 ) ( )L E DR R Rγ γ λ= + −
A finite solution requires: B D L ER R R R≤ ≤ ≤ .
1. Liquidity requirements binds if and only if B DR R< (will be relaxed)
2. Capital requirement binds if and only if ( )E DR R λ>
The Welfare Effects of Bank Liquidity and Capital Requirements 16
Equilibrium with capital and liquidity regulation • Investment is affected by both the liquidity requirement and the capital
requirement, if binding. ( (1 ) ( )L E DR R Rγ γ λ= + − ).
• With binding liquidity regulation, government bonds flow out of the nonbank sector, so their convenience yield E BR R− rises.
Adding a larger liquidity requirement • Can lead to disintermediation or non-bank intermediation: Shadow banking?
o More likely if the demand for safe, liquid assets is high relative to the supply.
The Welfare Effects of Bank Liquidity and Capital Requirements 17
2. Gross Welfare Cost of the Policy Tools
The Welfare Effects of Bank Liquidity and Capital Requirements 18
Welfare Cost of the Liquidity Requirement
If the economy is in steady state in the current period and IC1 and IC2 hold, then the marginal welfare cost of a permanent increase in λ is:
( ) 1(1 )D BLIQ
d R Rc
ν λ −= − −
• As a first-order approximation, the welfare loss from λ∆ is equivalent to a permanent relative loss in consumption of LIQν λ∆ .
• Takes into account gains and losses associated with move to a new steady state. • Revealed preference logic + competitive banking.
The Welfare Effects of Bank Liquidity and Capital Requirements 19
Welfare Cost of the Capital Requirement
Under the same assumptions, the marginal welfare cost of a permanent increase in γ is:
( )( )E DCAP
L R Rc
ν λ= −
Recall ( ) ( )1
D D D BR R R Rλλλ
≡ + −−
The Welfare Effects of Bank Liquidity and Capital Requirements 20
3. Costly Financial Intermediation So far we have assumed that no resource costs are involved with financial intermediation. • For 86-13, net noninterest costs are 1.3% of total assets. Before measuring costs, extend model:
Bank pays noninterest cost: ( , )g D L g is increasing, convex, constant returns to scale. Dividends = max(0,( ) )( , )L B D
t t t t t tt t tR L R B R D g D Lσ ε −+ + −
The Welfare Effects of Bank Liquidity and Capital Requirements 21
Gross Welfare Costs with Costly Intermediation
Marginal welfare costs of increasing λ and γ with costly financial intermediation:
( ) 1(( , ) 1 )D BIQ DL g dd R R
cLν λ −+= − −
( )1( ) (1 ) ( , )E DCAP D
L R Rc
g d Lλν λ −− − −=
The Welfare Effects of Bank Liquidity and Capital Requirements 22
4. Measurement of the Welfare Cost Historical Statistics on Banking - U.S. commercial banks (1986 – 2016). • From 1986-2000, Treasuries/Assets exceed 1 percent Use this period to estimate
Dg through the condition: B DDR R g= + 1.22%Dg =
• Alternative estimate based Hanson, Schleifer, Stein, Vishny (2015): 0.81%Dg =
• Use 2001-2007 to estimate average returns and ratios. o Treasuries < 1% of assets
o Provides an estimate of the cost of a liquidity requirement for a period when it would likely have been binding.
o Current environment: high level of reserves could reflect phase-in of LCR, or could mean that a modest liquidity requirement entails little immediate economic costs.
The Welfare Effects of Bank Liquidity and Capital Requirements 23
U.S. Treasuries and excess reserves held by U.S. depository institutions
The Welfare Effects of Bank Liquidity and Capital Requirements 24
Measurement of the Welfare Cost: Liquidity d = Total Deposits d/c = 0.67 c = Personal Consumption Expenditures
DR = (Interest on Total Deposits) / (Total Deposits) = 2.04% Including marginal noninterest cost: D
DR g+ = 3.26% BR = 3-month Treasury yield = 2.80%
λ = liquidity requirement = 0
( ) 1(1 )D BLIQ D
d R g Rc
ν λ −= + − −
0.67 (0.0326 0.0280) 1= × − × = 0.0031
The Welfare Effects of Bank Liquidity and Capital Requirements 25
Measurement of the Welfare Cost: Liquidity Interpretation of 0.003LIQ =ν . • The gross welfare cost of imposing a 10 percent liquidity requirement is equivalent
to a permanent loss in consumption of 0.1 100%LIQν × × = 0.031%.
• About $3.5 billion per year.
• With HSSV-based estimate ( 0.81%Dg = ): welfare cost = 0.003%.
The Welfare Effects of Bank Liquidity and Capital Requirements 26
Measurement of the Welfare Cost: Capital A risk-adjusted measure of the required return on equity is needed.
I use the required return on subordinated bank debt. • Sub-debt counts towards regulatory capital, within certain limits. • Defaults on bank sub-debt have been rare.
Limits: • Part of tier 2 capital • Until recently, limited to at most 50% of tier 1 capital. • Same tax treatment as deposits
The required return on sub-debt may be less than the risk-adjusted pre-tax required return on regular bank equity.
conservative measure.
The Welfare Effects of Bank Liquidity and Capital Requirements 27
Measurement of the Welfare Cost: Capital Sample: 1993-2010 L = Total Assets – (Treasuries + Ex. Reserves) L/c = 0.96 c = Personal Consumption Expenditures
ER = (Interest on Subordinated debt) / (Sub-debt) = 5.45% DR = (Interest on Total Deposits) / (Total Deposits) = 2.43%
Including marginal noninterest cost: DDR g+ = 3.65%
( ) 1( ) (1 )E DCAP D
L R R gc
ν λ −= − + − 10.96 0.0180 (1 0)−= × × − = 0.017
The Welfare Effects of Bank Liquidity and Capital Requirements 28
Measurement of the Welfare Cost: Capital Interpretation of 0.017CAP =ν . • The gross welfare cost of increasing capital requirements by 10 percentage points is
equivalent to a permanent loss in consumption of 0.1 100%ν × × = 0.17%.
• About $20 billion per year. • With HSSV-based estimate ( 0.81%Dg = ): welfare cost = 0.21%.
The Welfare Effects of Bank Liquidity and Capital Requirements 29
Measurement of the Welfare Cost: Summary
The Welfare Effects of Bank Liquidity and Capital Requirements 30
Conclusions
Liquidity and capital requirements reduce the ability of banks to create net liquidity in equilibrium and impact investment and economic activity.
• Cost of capital requirement scales with the convenience yield on bank deposits
• Cost of liquidity requirement scales with the difference in the convenience yields on HQLA assets and on bank deposits (adjusted for noninterest costs)
Quantitative result: Welfare cost of liquidity requirement is modest and much lower than the welfare cost of similarly-sized capital requirements.
Financial stability benefits of liquidity requirements are narrower than capital, yet liquidity regulation is part of the optimal policy mix division of labor:
• Capital regulation addresses credit risk; • Liquidity regulation addresses liquidity risk.
The Welfare Effects of Bank Liquidity and Capital Requirements 31
Extra Slides
The Welfare Effects of Bank Liquidity and Capital Requirements 32
The Demand for Treasuries Corporate Bond Spread and Government Debt
Source: Krishnamurthy and Vissing-Jorgenson, JPE
The Welfare Effects of Bank Liquidity and Capital Requirements 33
Banks: Introducing Moral Hazard Credit risk: Banks can make risky loans to firms with a stochastic technology
o Return to the bank’s loan portfolio is Lt t tR σ ε+
o tσ corresponds to fraction of lending to a risky firm
o tε has negative mean Excessive risk taking
Consistent with assumptions on technology of risky firms
o Supervision can detect excessive risk taking if tσ σ>
The Welfare Effects of Bank Liquidity and Capital Requirements 34
Bank’s Problem Bank maximizes of shareholder value:
( ){ }, , , ,(1 1 )max max 0, ( ) /
s.t.
[0, ]
B wDL B D E
B L D ER L R B R D R E
L B E DB DE L
ση σε
λγ
σ σ
<− + + − − + = +
≥≥
∈
Result: Expected dividends are convex in σ
• Decreasing when 0σ ≈ ; • Increasing when σ is sufficiently large
The Welfare Effects of Bank Liquidity and Capital Requirements 35
Choice of σ: illustration for a 2-point distribution of ε
Dividends
Excessive risk taking, σ 0
ε > 0
Expected Dividends
ε < 0 ε < 0
L B DR L R B R D+ −
The Welfare Effects of Bank Liquidity and Capital Requirements 36
Bank’s Risk-Taking Choice
0
0.05
0.1
0.15
0.2
0.25
0.3
0 0.02 0.04 0.06 0.08 0.1 0.12 0.14 0.16 0.18 0.2
λ
γ
w
γ∗
Excessive lending riskNo liquidity risk
Excessive lending riskExcessive liquidity risk
No excessivelending riskEx. liquidity risk
A
No excessive lending riskNo liquidity risk
Excessive lending riskNo liquidity risk
No excessive lending riskNo liquidity risk
Optimal Policy to deter excessive risk
The Welfare Effects of Bank Liquidity and Capital Requirements 37
Neoclassical Firms
Kt Physical Capital Lt Loans F
tE Firm Equity Safe technology: ( , )F K H , constant returns to scale
( , )HF K H w=
( , ) 1 LKF K H Rδ+ − =
Firms raise non-bank finance (firm equity) only if E LR R= . Risky firms: ( , ) RFF K H Kσ ε+ risky loans
The Welfare Effects of Bank Liquidity and Capital Requirements 38
Government - Regulator Sets
γ : Capital adequacy regulation λ : Liquidity regulation B : Fixed supply of government debt
Balanced budget, including any resolution costs:
o Excess losses covered by deposit insurance fund
o Direct resolution costs
The Welfare Effects of Bank Liquidity and Capital Requirements 39
Equilibrium Market Clearing:
1
t
t tF
t t t
Ft
t t t
t
B
d D
e E E
L
B
E
b
KH
= +
=
= +
= −
=
1( ,1) (1 )t t t t t t tF K L K c K Tξσ δ ψ+− + − = + + + Given a government policy γ, λ, B , and T, an equilibrium is defined as a path of consumption, capital, deposits, equity an bond holdings, bank loans and financial returns, for t = 0,1,2,… such that:
1. Households, banks and nonfinancial firms all solve their maximization problems, described above, with taxes set according to the balanced budget constraint; and
2. All markets clear.
The Welfare Effects of Bank Liquidity and Capital Requirements 40
2. Gross Welfare Cost of the Policy Tools Methodology: 1. Guess a constrained social planner’s problem with the liquidity and capital
requirements.
2. Verify that it replicates the decentralized equilibrium.
3. Differentiate the value of the problem (= welfare) with respect to λ or γ.
4. Use optimality conditions of the decentralized equilibrium to express the marginal welfare cost in terms of observable sufficient statistics.
The Welfare Effects of Bank Liquidity and Capital Requirements 41
Gross Welfare Cost of the Policy Tools Replicating constrained social planner’s problem
1 00 0
{ , , , } 0
1
( , , , ) max ( , , )
s.t. ( ,1) (1 )(1 )
t t t t t
tt t t
c d b K t
t t t t
t t t
t t
t t
V K B u c d b
F K K c Kd L B bB b dL K
γ λ β
δγ
λ
∞+ =
∞
=
+
=
+ − = +
≤ − + −
− ≥
≤
∑
The Welfare Effects of Bank Liquidity and Capital Requirements 42
Welfare Cost of Bank Capital Requirements From: Van den Heuvel (2008)
0.1CAPν × in %
0Dg = /Dg g D= Sub-Debt (93-04)
0.22
0.10
Total Assets (86-04)
1.09
0.94
Risk adjusted 0.85 0.71 Total Loans (86-04)
1.36
1.22
Risk adjusted 1.02 0.88
The Welfare Effects of Bank Liquidity and Capital Requirements 43
Effect of the Capital Requirement on Steady State Income Capital requirement affects capital stock even in steady state, in contrast to inflation in the Sidrauski model. Example: 0g ≡
{ } /( 1)( 1) / ( 1) /( , )u c d u c adη ηη η η η −− − = +
( )E Dt t t td a c R Rη η−⇒ = −
K* is increasing (decreasing) in γ if 0 1η< < ( 1)η > Intuition:
1(1 )( )L E E DMPK R R R Rγ
β −= = − − −
The Welfare Effects of Bank Liquidity and Capital Requirements 44
0
10
20
30
40
50
0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50
% b
ank
asse
ts
Total Risk-Based Capital Ratios, 2000.IV
The Welfare Effects of Bank Liquidity and Capital Requirements 45
The Welfare Effects of Bank Liquidity and Capital Requirements 46
The Optimal Capital Requirement Suppose the costs of excessive risk taking (ξ and ψ) are sufficiently large so that preventing excessive risk taking ( 0σ = ) is socially desirable Welfare maximization in steady state, conditional on 0σ = : 1
0,max ( ) s.t. ( )T
V S Tγ
θ γβ − ≥
Set γ, T such that
marginal welfare benefit
Assuming 0S ′′ > , larger welfare cost implies a larger T and a smaller γ .
1( )
1'( )
ci
S T
dTcd S Tγβ
νγ β−=
−= − =