During the Vietnam conflict a common complaint of soldiers was that you could never tell who the enemy really was.
In this current economic recession I too am beginning to wonder who the enemy of
our recovery really is.
The President, Congress, the Federal Reserve, and the regulators are all telling us why so many others are to blame. The big banks have done it to us, shouts one group! Wall Street did it, claims another. Homebuyers who bought homes they could not afford are the real culprit claims another!
Perhaps those that have been charged with the responsibility for managing the
fiscal and monetary policy of our nation should look inward for their
responsibility in this continuing crisis.
For example, the major banking crisis in 2008 as seen with the Lehman Brothers
disaster, the Bear Stearns crisis, the Wachovia Bank crisis, the National City
bankruptcy, the Countrywide fiasco, the virtual meltdown of Fannie Mae and Freddie Mac caused Congress to become concerned about capital adequacy of banks and financial institutions.
Stress testing banks came into vogue. The intent was to protect the economy from
the “too big the fail” firms so that our economy would no longer be
vulnerable to the bankruptcy of one institution. Stress testing may have been a
laudable objective in concept but perhaps not so laudable in practice.
To implement a too big to fail strategy in the middle of a recession likely made
the recession more severe and prolonged. Investors became concerned about what the government would do next with banks which, in turn, made it harder for banks to acquire the very capital that would be needed to eliminate the too big to fail concern in the first place.
By the same token, our government is considering BASEL 3 capital adequacy
standards. Such capital standards make sense on the surface however, in the middle of a recession, with stock prices already depressed for banks, the likelihood is that banks will increase their capital ratios by getting smaller rather than by raising equity. Reducing capacity to lend in a recession is problematic for our economy.
In reality, the most recently released stress tests have allowed many well
capitalized banks to buy shares of their own stock back because the shares are so “cheap”. In other words, the financial sector is contracting in the middle of a recession!
In a similar vein, in a misguided effort to spur on the economy, the Federal
Reserve has enacted Quantitative Easing 1, Quantitative Easing 2, and Operation
Twist. The intent of all of these measures is to reduce long-term interest rates to spur on consumer spending and investment by business.
In reality, what has occurred is that we have set the stage for unrealistically low interest rates which, when the interest rates reset, will make the investment or spending decision painful in retrospect.
Quantitative Easing is an identical concept to the teaser interest rates that
Fannie Mae, Freddie Mac, and the federal government encouraged with banks and
investment banks to entice homeowners into buying homes they could not afford. Have we not learned anything from the housing crisis!
The extremely low interest rates have encouraged investors to withhold funds from the investment markets because they understand that these rates are unrealistically low in light of inflation concerns.
Finally, at the height of the financial crisis in 2009, the FDIC required banks to post three years of prepayments of the FDIC insurance premiums. The prepayments amounted to $45 billion. The intent was to restore some solvency to the FDIC insurance fund which had seen rapid withdrawals in 2008 and 2009.
Unfortunately the impact of the $45 billion premium was to pull almost $450 billion of lending capacity from the banks at a time when the nation was already in crisis.
The problem expands to $450 Billion because of the capital requirements of banks
with the Total Risk Based Capital calculation.
The intent of the FDIC was very sound. Unfortunately bank stocks were selling at
such depressed levels in 2008 and 2009 that most banks decided to get smaller
rather than raise equity at depressed prices to meet the regulatory capital
In defense of the FDIC, they did try to increase the size of the fund during
booming economic times but large banks were able to successfully lobby that the
fund was big enough already. In reality the fund should have been allowed to
continue to grow so that in stressful economic times the fund would be large enough to weather the storm without special assessments during a crisis. This is a situation where the large banks, Congress, and the FDIC were all complicit.
For there to be a reasonable solution to the current economic malaise, government must recognize the timing, as well as the intent, of its decisions.
Increasing capital standards in good times would likely be absorbed by the economy and the banking industry with little adverse effect on consumers.
Allowing the FDIC to maintain the insurance fund as an insurance fund without
intervention on the limits of the size of the fund would permit insurance to do
what it's intended to do: insure. By reducing FDIC premiums in good times, banks
actually reported above normal earnings. In severe economic times, banks earnings have been negatively affected by increasing premiums. Not the message that should be sent in the middle of a recession.
The Dodd-Frank Bill was intended to reduce our economy's risk to institutions that were too big to fail. Since the passage of this bill the exact opposite is
happened. The larger banks have become bigger and our risk greater.
It is essential that until the economy is more robust, that the federal government, Congress, the President, and the regulators stop all efforts at increasing regulatory compliance burdens. Capital standards should be maintained at prudent levels until after the recession is over. At that time, it would be appropriate to consider recapitalizing banks with higher regulatory standards.
Once again the very people tasked with assisting in controlling the economy are
meddling, in a political way, in activities for which they have no understanding.
When will Congress understand that you cannot legislate economic principles!
Congress and the President must be aware that the laws of supply and demand were
never passed by any government nor can those laws be repealed.
Interfere excessively with a free market and be prepared for the unintended
Col. Frank Ryan, CPA, is a retired Marine Reserve Colonel, taught economics as an Adjunct Faculty member at the college level, and specializes in corporate
restructuring and lectures on ethics for the state CPA societies. He has served on numerous boards of publicly traded and non-profit organizations. He can be reached at FRYAN1951@aol.com and via twitter fryan1951
Sound Economic Policies
Emphasize personal responsibility
Eliminate deficit spending
FOR BY FRIENDS OF FRANK RYAN, DANIEL BOREMAN TREASURER © 2009