Several weeks ago I gave a talk based on my Brookings paper with Natasha Sarin at the Atlanta Fed’s annual research conference. Here are the video and slides. I continue to be puzzled by gap between what is widely believed and my reading of market evidence.
I began by highlighting three facts that seem to me to be in substantial tension with the widespread view that banks are far safer now than they used to be because they are far better capitalized. Mark Carney’s statement that “The capital requirements of our largest banks are now ten times higher than before the crisis. . . . This substantial capital and huge liquidity give banks the flexibility they need to continue to lend…even during challenging times” is typical.
First, there is distressingly little evidence in favor of the proposition that banks that are measured as better capitalized by their regulators are less likely to fail than other banks. Andrew Haldane suggests the absence of a relationship looking across banks before the 2008 crisis. Òscar Jordà and coauthors suggest the absence of such a relationship historically, using data for many countries. Jeremy Bulow and Paul Klemperer note that for banks whose crisis failure resulted in FDIC losses, the FDIC typically had to inject an amount in excess of 15 percent of their assets, suggesting that they in fact had substantial negative capital positions.
Second, financial logic embodied in the celebrated Modigliani Miller theorem and suggested by common sense holds that substantial reductions in leverage, if achieved, should be associated with reduced volatility, reduced sensitivity to shocks and lower risk premiums. Our paper examines a comprehensive suite of volatility measures including actual volatility, volatility implied by option pricing, beta, credit default spreads, preferred stock yields and earnings price ratios. While each indicator has associated ambiguities, it is striking that none suggest a major reduction in leverage for the largest US financial institutions, large global institutions or midsize domestic institutions.
Third, the ratio of the market value of bank’s common equity to its risk weighted assets provides a market based measure of its leverage. Of course, the market value of equity overstates true capital because of limited liability: if assets rise in value there is no limit to how much shareholders can ultimately receive; but there is a zero lower bound on what shareholders receive. Still, as Haldane and others have documented, this market measure has historically proven useful in predicting bank distress. The data suggest that on a market value of equity basis, major financial institutions are no less levered than they were over the period before the crisis—even excluding the couple of years before the crisis when there was plausibly a bubble element in market pricing.
I am more confident that these observations need to be reckoned with in thinking about financial stability than I am in any particular set of explanations much less policy conclusions. Here though are some observations suggested by our findings.
First, it is essential to take a dynamic view of capital. The health of a financial institution depends critically on the profits it can expect to generate in the future. I suspect that the decline in the ratio of the market value of bank equity to assets reflects declines in expected future profits, and that this declining franchise value, other things equal, causes banks to be more levered.
The stress tests introduced by the regulatory community represent a welcome recognition of the need to take a dynamic view of capital. However I am inclined to agree with Jeremy Bulow who noted in commenting on the our paper that recent stress tests estimate that if GDP drops 6.25 percent, unemployment doubles, the stock market halves, and real estate falls by 25 to 30 percent, then capital losses would be insufficient to trigger “prompt corrective action.” Bulow wonders—and we do as well—if this is not more of a comment on the inadequacies of the stress test procedures, than on the soundness of the banks.
Second, a crucial challenge for financial regulation going forward is assuring prompt responses to deteriorating conditions that do not set off vicious cycles. Markets were sending clear signals of major problems in the financial sector well in advance of the events of the fall of 2008 but the regulatory community did not even limit bank dividend payouts, even after the experience at Bear Stearns, which had been deemed very well capitalized even as it was failing. Current experiences in Europe where some institutions have a price-to-book ratio of barely 0.35 and have not yet been forced to raise capital are not encouraging about lessons learned.
Third, regulators need to be attentive to franchise value. It goes without saying that banks should not be permitted to take excessive risks or treat customers unfairly in order to raise their franchise value. Nor would it be wise public policy to undermine competition in banking in order to raise franchise values. On the other hand, it is not just an issue of cost, but financial stability as well when regulators impose needless burdens on banks. This point was brought home to me not long ago when I heard about the legal contortions one big bank felt it had to go through when I recommended a student for a job. Would hiring the student be doing me an impermissible favor? Would not hiring the student be unfair? The debates surrounding my well-intentioned suggestion consumed hours of time on behalf of the bank’s compliance team. And I am sure such abundance of caution is commonplace at most large financial institutions. On a random Tuesday, there are hundreds of federal government employees going to work at each of our major banks, some of which have more than 10,000 people engaged in compliance activity.
Regulatory costs are an especially large issue for smaller banks since there are almost certainly economies of scale in compliance functions. There is also the crucial point that incomplete regulation which discriminates against banks in favor shadow banks may by undermine financial stability in two ways. First, shadow banks may become loci of instability. Second, weakening the franchise value of regulated institutions may make their insolvency more likely.
Fourth, bankers may be more right in their concerns about increased costs of capital and its effect on lending than economists usually suggest. Economists like Anat Admati normally rely on Modigliani-Miller considerations to argue that enhanced regulation does not raise capital costs, because it makes equity safer. If as our results suggest equity is not safer, there is every reason to suppose that bank capital costs have increased as a consequence of regulation, and that this may to some extent have reduced credit flows.
Fifth, it is high time we move beyond a sterile debate between more and less regulation. No one who is reasonable can doubt that inadequate regulation contributed to what happened in 2008 or suppose that market discipline is sufficient to contain excessive risk-taking in the financial industry. At the same time, not all regulatory expansions are desirable and in some contexts tougher regulation can be counterproductive for financial stability if it reduces profitability without offsetting benefit, if interferes with bank diversification, or if it causes regulators to become overly identified within regulated institutions. Neither the approach that holds that all increases in measured capital and other regulation are attractive, nor the one that holds that capital and other regulations should be completely scaled back is likely to prevent or contain the next financial crisis.
The global pandemic response has typically followed cycles of panic followed by neglect. We are now, once again, in a phase of neglect, leaving the world highly vulnerable to massive loss of life and economic shocks from natural or human-made epidemics and pandemics. Quantifying the size of the losses caused by large-scale outbreaks is challenging because the epidemiological and economic research in this field is still at an early stage. Research on the 1918 influenza H1N1 pandemic and recent epidemics and pandemics has shown a range of estimated losses (See full report here).
A limitation in assessing the economic costs of outbreaks is that they only capture the impact on income. Fan and colleagues recently addressed this limitation by estimating the “inclusive” cost of pandemics: the sum of the cost in lost income and a dollar valuation of the cost of early death. They found that for Ebola and severe acute respiratory syndrome (SARS), the true (“inclusive”) costs are two to three times the income loss. For extremely serious pandemics such as that of influenza in 1918, the inclusive costs are over five times income loss. The inclusive costs of the next severe influenza pandemic could be US$570 billion each year or 0·7% of global income (range 0·4–1·0%)—an economic threat similar to that of global warming, which is expected to cost 0·2–2·0% of global income annually. Given the magnitude of the threat, we call for scaled-up financing of international collective action for epidemic and pandemic preparedness.
Two planks of preparedness must be strengthened. The first is public health capacity—including human and animal disease surveillance—as a first line of defence. Animal surveillance is important since most emerging infectious diseases with outbreak potential originate in animals. Rigorous external assessment of national capabilities is critical; WHO developed the Joint External Evaluation (JEE) tool specifically for this purpose. Financing for this first plank will largely be through domestic resources, but supplementary donor financing to low-income, high-risk countries is also needed.
The second plank is financing global efforts to accelerate research and development (R&D) of vaccines, drugs, and diagnostics for outbreak control, and to strengthen the global and regional outbreak preparedness and response system. These two international collective action activities are underfunded.
Medical countermeasures against many emerging infectious diseases are currently missing. We need greater investment in development of vaccines, therapeutics, and diagnostics to prevent potential outbreaks from becoming humanitarian crises. The new Coalition for Epidemic Preparedness Innovations (CEPI), which aims to mobilise $1 billion over 5 years, is developing vaccines against known emerging infectious diseases as well as platforms for rapid development of vaccines against outbreaks of unknown origin. The WHO R&D Blueprint for Action to Prevent Epidemics is a new mechanism for coordinating and prioritising the development of drugs and diagnostics for emerging infectious diseases. Consolidating and enhancing donor support for these new initiatives would be an efficient way to channel resources aimed at improving global outbreak preparedness and response.
Crucial components of the global and regional system for outbreak control include surge capacity (eg, the ability to urgently deploy human resources); providing technical guidance to countries in the event of an outbreak; and establishing a coordinated, interlinked global, regional, and national surveillance system. These activities are the remit of several essential WHO financing envelopes that all face major funding shortfalls. The Contingency Fund for Emergencies finances surge outbreak response for up to 3 months. The fund has a capitalisation target of $100 million of flexible voluntary contributions, which needs to be replenished with about $25–50 million annually, depending on the extent of the outbreak in any given year. However, as of April 30, 2017, only $37·65 million had been contributed, with an additional $4 million in pledges. The WHO Health Emergencies and Health Systems Preparedness Programmes face an annual shortfall of $225 million in funding their epidemic and pandemic prevention and control activities.
Previous health emergencies have shown that it can take time to organise global collective action and provide financing to the national and local level. In such situations, a global mechanism should offer a rapid injection of liquidity to affected countries. The World Bank’s Pandemic Emergency Financing Facility (PEF) is a proposed global insurance mechanism for pandemic emergencies. It aims to provide surge funding for response efforts to help respond to rare, high-burden disease outbreaks, preventing them from becoming more deadly and costly pandemics. The PEF currently proposes a coverage of $500 million for the insurance window; increasing the current coverage will require additional donor commitments. In addition, the PEF has a $50–100 million replenishable cash window.
As the world’s health ministers meet this month for the World Health Assembly, we propose five key ways to help prevent mortality and economic shocks from disease outbreaks. First, to accelerate development of new technologies to control outbreaks, donors should expand their financing for CEPI and support the WHO R&D Blueprint for Action to Prevent Epidemics. Second, funding gaps in the WHO Contingency Fund for Emergencies and the WHO Health Emergencies Programme should be urgently filled and the PEF should be fully financed. Third, all nations should support their own and other countries’ national preparedness efforts, including committing to the JEE process. Fourth, we believe it would be valuable to create and maintain a regional and country-level pandemic risk and preparedness index. This index could potentially be used as a way to review preparedness in International Monetary Fund article IV consultations (regular country reports by staff to its Board). Finally, we call for a new global effort to develop long-term national, regional, and global investment plans to create a world secure from the threat of devastation from outbreaks.
Gavin Yamey, Marco Schäferhoff, Ole Kristian Aars, Barry Bloom, Dennis Carroll, Mukesh Chawla, Victor Dzau, Ricardo Echalar, Indermit Singh Gill, Tore Godal, Sanjeev Gupta, Dean Jamison, Patrick Kelley, Frederik Kristensen, Ceci Mundaca-Shah, Ben Oppenheim, Julie Pavlin, Rodrigo Salvado, Peter Sands, Rocio Schmunis, Agnes Soucat, Lawrence H Summers, Anas El Turabi, Ron Waldman, Ed Whiting