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Federal Reserve Bank of New YorkSpeechEN

Dudley : The Federal Reserve's Liquidity Facilities

SPEAKERNot stated

PUBLISHED04/09/2009, 00:00:00
EVENT / LOCATIONNot stated

The Federal Reserve's Liquidity Facilities - FEDERAL RESERVE BANK of NEW YORK

Speech

The Federal Reserve's Liquidity Facilities

April 18, 2009

William C. Dudley

, President and Chief Executive Officer

Remarks at the Vanderbilt University Conference on Financial Markets and Financial Policy Honoring Dewey Daane, Nashville, Tennessee

Thank you for having me here today. It is a great honor to be

on a panel with Peter Fisher and Bill Poole. I am the neophyte here in

terms of central banking experience!

Before I begin, let me emphasize that my comments represent my own views

and opinions and do not necessarily reflect the views of the Federal Open Market

Committee or of the Federal Reserve System.

I am going to talk today about the

Fed’s provision of liquidity to banks

and dealers and to market participants more generally.

I would break down our actions into three broad classes.

First, we addressed the acute seizing up of inter-bank financing markets. For

banks, we introduced the Term Auction Facility in December 2007 and for the

primary dealers, the Term Securities Lending Facility and Primary Dealer Credit

Facility in March 2008. In addition, the Federal Reserve entered into

FX swap agreements with major global central banks in order to channel dollar

liquidity to banks overseas.

Second, we expanded our provision of short term

financing beyond banks and dealers in order to alleviate constraints on highly

rated corporate borrowers. The

two most noteworthy examples of this are the Commercial Paper Funding Facility,

which was introduced in October 2008, and the Term Asset-Backed Securities

Lending Facility (announced in November 2008, but not up and running until

last month.)

Third, once

policy rates were near the zero-bound, we expanded the type of assets that

the Fed purchased. In order to put downward pressure on general

longer term borrowing rates, particularly mortgage rates, the Federal Reserve

has purchased the debt of the GSEs, namely, Fannie Mae and Freddie Mac

and the mortgage-backed-securities they issue, and, more recently, longer-term

Treasuries.

So why has the Fed done so much in terms of special programs?

As I see it,

there are four major reasons behind the dramatic expansion of the Fed’s

liquidity programs:

To provide liquidity to banks and dealers in order to slow down the deleveraging

process.

To expand the balance sheet capacity of the private sector to counteract

the shrinkage underway in the non-bank financial sector.

To restore and improve market function.

To ease financial market conditions.

This financial crisis has been marked by the rapid deleveraging of the non-bank

financial sector. This deleveraging has been driven mainly by the collapse

of securitization activity, pressure on dealers to reduce leverage and the

spillover of these efforts on to other financial players such as hedge funds.

This deleveraging process, in turn, has put intense pressure on the balance

sheet capacity of the banking sector. Not only can banks no longer securitize

assets as before, but assets that they thought were off their books have come

back on.

Although the deleveraging process is inevitable following periods when the

financial system has become overextended, it does matter how this deleveraging

process takes place. In the current crisis, the deleveraging process

at times has been very violent and dangerous, with powerful reinforcing feedback

loops intensifying the process. During these episodes, bystanders who

did not engage in excess may be trampled and fail. This may exacerbate

the tightening in financial conditions, intensifying the constraint on credit

availability and the downward pressure on economic activity.

For example, in

March 2008, in the run-up to Bear Stearns’ demise, the

deleveraging process intensified. Market volatility increased;

this caused lenders to increase the haircuts they assessed against collateral

to secure their lending. The higher haircuts, in turn, squeezed highly

leveraged investors who were forced to sell assets. This drove down asset

prices and increased price volatility further, leading to still-higher haircuts.

This intensified the deleveraging process, which led to more mark-to-market

losses.

The Federal Reserve’s facilities for banks and dealers have

been designed, in part, to slow down the deleveraging process. The TAF, the

TSLF and the PDCF have provided assurance to banks and dealers that they have

a place where they can obtain funding for their less liquid collateral. As

a result, they will not be forced to dump assets, further depressing market

prices, increasing volatility and the upward pressure on haircuts. The deleveraging

will still take place—and we have seen it—just not so quickly and

violently that it would destabilize the entire financial system.

The second

major intent of the liquidity facilities has been for the Fed to expand its

balance sheet and, by doing so, offset some of shrinkage that has been occurring

among non-bank financial intermediaries. The fact is the banking system is

capital-constrained, with insufficient capital to expand its balance sheet

fast enough to offset the shrinkage evident in the non-bank sector. Although

the Federal Reserve cannot create capital for banks, it can provide funding

directly to the private sector, attenuating the consequences caused by a balance-sheet-constrained

banking system.

The CPFF and the TALF are both important in restoring the flow

of credit to borrowers. The CPFF essentially jump-started the commercial paper

market, which had largely shut down following the failure of Lehman Brothers

in September.

The TALF’s purpose is to restart the securitization markets, and thereby

lower the cost of borrowing to households and business. The TALF does

this by providing term, non-recourse loans to investors against AAA-rated collateral.

Investor demand for these loans leads to downward pressure on AAA-rated financing

rates, lowering the cost of credit. Although TALF is off to a relatively slow

start—hurt, in part, by the reluctance of some investors to participate

because of worries about the potential implications for them of the TARP funding

that is involved in the TALF program, it has helped to restart the securitization

markets in the consumer asset-backed securities area and has brought down funding

costs for consumer ABS issuers.

The third goal of these policy interventions

has been to improve market function. By dramatically reducing rollover risk,

the Federal Reserve’s willingness

to serve as the lender or investor of last resort has helped improve market

function in a broad number of areas. Rollover risk is the risk that a

borrower may not be able to obtain new funding in order to repay an investor

when the investor needs the funds for other uses. If rollover risk is high,

the investor is going to be concerned about getting its funds back and, thus,

may be unwilling to make the investment in the first place. The impact

of the Fed’s intervention on rollover risk has been especially important

in the triparty repo market and in the commercial paper market.

The triparty

repo market is a market in which investors such as money market mutual funds

lend funds, mostly on an overnight basis, to securities dealers, with the loans

collateralized by high-quality securities. During the crisis, this market became

less stable. As the financial condition of some of the major securities dealers

worsened, the clearing banks became more reluctant to return the cash that

the triparty repo investors had invested the prior evening. The clearing banks

were worried that if a dealer were to fail, they could be stuck with a large

obligation. The nervousness of the clearing banks, in turn, spilled back to

the investors. If there is some chance that I might not get my cash back and

instead be stuck with the collateral, do I really want to make the loan in

the first place? The Primary Dealer Credit Facility essentially broke this

dynamic by putting the Federal Reserve in the position of lender of last resort

in the triparty repo system. With the Federal Reserve willing to lend against

collateral, the clearing banks no longer have significant intraday risk exposure.

The triparty repo investors have been reassured that they would be paid back.

As a consequence, they were willing to keep investing.

The TAF and the dollar

facilities offered by foreign central banks provided the same antidote to rollover

risk in the interbank funding markets. Banks that were reluctant to lend to

one another because of rollover risk became willing to reengage because they

knew that the Federal Reserve and foreign central banks would lend against

high-quality collateral.

By eliminating rollover risk, the CPFF also helped to restore market function

in the commercial paper market. Commercial paper investors who

had shunned the market returned because they were no longer worried that they

could get their money back. In extremis, the Federal Reserve could purchase

the commercial paper from the issuer, generating the funds to repay the private

investors’ commercial paper investment.

The fourth and final goal of

the Fed’s liquidity facilities has been

to ease financial conditions. This has been particularly important in

the current environment because the federal funds rate cannot be pushed below

zero (the so-called zero-bound constraint). This means that with the

federal funds rate having been effectively lowered as far as it can go, the

Federal Reserve has had to turn to other tools such as asset purchase programs

if it is to ease financial conditions further as warranted given macroeconomic

conditions.

The Federal Reserve’s purchases of agency debt, agency MBS

and longer-term Treasuries have been implemented mainly with one goal in mind—reduce

longer-term private sector interest rates, and thereby provide stimulus to

the U.S. economy.

The Federal Reserve’s Treasury purchase program is designed to hold

down the level of longer-term interest rates. To the extent that a lower

level of long-term Treasury rates pulls down the level of private long-term

rates, then these purchases should also ease financial market conditions.

So how have the Fed’s facilities worked in practice?

In general, I

think the facilities have worked quite well. In those areas where the facilities

have been active, we generally have seen an improvement in market conditions.

But the facilities have not been a panacea for three reasons. First, the facilities

cannot address the fundamental problem—the shortage of

capital in the banking system. The facilities can slow down the deleveraging

process, but until the banking system is viewed as being sufficiently well-capitalized

and is able to expand its lending activity significantly, the limits on credit

availability caused by an impaired banking system will make it more difficult

to generate a sustainable economic recovery.

Second, there are limits on what

the Fed can do legally. For example, the Fed can only lend if it is secured

to its satisfaction. There has to be sufficient collateral available. The Fed

cannot lend on an unsecured basis or provide guarantees. And the Fed cannot

purchase assets other than Treasuries, agencies and agency MBS, and short-dated

general obligations of states and municipalities.

Third, the effectiveness

of some of the Fed facilities have been undercut by stigma—the discount

window is the best example of this—or by worries

about what other strings are or might be attached to the use of the facilities—the

TALF comes to mind in this respect.

One reason why the TALF has gotten off

to a relatively slow start is the reluctance of investors to participate. Issuers’ interest,

not surprisingly, dwarfs investor demand at this stage of the program. Some

investors are apparently reluctant not because the economics of the program

are unattractive, but because of worries about what participation might lead

to. The TARP loans to banks led to intense scrutiny of bank compensation practices

given that TALF loans are ultimately secured by TARP funds, investor anxiety

about using the program has risen.

My own view is that these fears are misplaced.

The TARP funds in the TALF program only come in on the backend of the program

when loans are put back to the Fed. The lending to investors on the front end

is completely a Federal Reserve program and operation. That being said, I understand

the reasons for the anxiety given the political discourse on this subject.

I think it is worth emphasizing that actions that lead investors to shun taking

risk, especially in this environment, are ultimately detrimental to the ability

of households and businesses to secure credit at reasonable borrowing rates.

The

Federal Reserve’s liquidity facilities and asset purchase programs

have led to a substantial expansion of the Federal Reserve’s balance

sheet since September 2008. Currently, the Fed’s balance sheet totals

about $2.2 trillion, up from about $900 billion last fall prior to Lehman’s

failure.

In thinking about this balance sheet expansion, I would make three broad points.

First, in my mind, the goal is not the expansion of the balance sheet per se,

but the objectives that I laid out earlier. In this respect, the expansion

of the balance sheet differs considerably from Japan’s experience with

quantitative easing. In the current circumstance, the Federal Reserve’s

liquidity programs act on the asset side of the balance sheet as the Fed lends

funds against less liquid collateral and expands its asset holdings via purchases

of agency debt, agency MBS and Treasuries. The goals are to slow down

the pace of deleveraging to reduce the risk of catastrophic failure, improve

market function and ease financial market conditions.

In contrast, the Bank

of Japan worked on the liability side of the balance. Their goal was to expand

the amount of excess reserves held by the banking system so that the banks

would be more willing to expand their credit provisions. Although the Fed’s

activities have led to a big jump in excess reserves, this increase is incidental—a

byproduct rather than goal of the asset-oriented programs.

Second, as a consequence

of this my point, the size of the balance sheet, is not a good metric for measuring

the impact of the Fed’s facilities or

the amount of stimulus that the Fed is providing via these programs. For

example, consider the impact of the Fed facilities on rollover risk. A

Fed facility that eliminates rollover risk might not be used at all. There

might be no balance sheet impact. Nevertheless, the facility could have

an important impact on market function and financial market conditions.

It

is not possible to mechanically map the size of the balance sheet back onto

the impact on financial market conditions. That is because the balance

sheet size is being driven by a large number of different actions. Is

a dollar of TAF lending equivalent to a dollar extended through the CPFF or

to a dollar of Treasury purchases? How important is the PDCF? It

backstops lots of lending, but outstanding amounts are very low. The

differences between the various programs and activities mean that the balance

sheet size should be interpreted in light of the impact on market function

and financial market conditions, not by the impact on the size of the balance

sheet.

The size of the balance sheet is also not a good standard because the

use of the different facilities depends on the degree of impairment in market

function. If market conditions were to deteriorate, I would expect that usage

of the Fed’s

facilities would increase and the balance sheet would grow in size. This

would be appropriate. The Fed’s balance sheet would act as a shock

absorber, cushioning the impact of the shift in market conditions. In

such circumstances, the balance sheet would act as a counter-cyclical dampening

mechanism. I would view that as a desirable outcome.

In contrast, if the

Fed were committed to a particular balance sheet trajectory, then, as market

conditions improved and financial conditions eased and usage of the Fed’s

liquidity facilities diminished, the Fed would have to offset this by increasing

the scope of its liquidity facilities or by expanding its asset purchase programs.

It is unclear to me why the Federal Reserve would want to apply more stimulus

at a time when market conditions were improving. This suggests that some variability

in the trajectory of the Fed’s balance

should be expected and might even be desirable. And, in fact, this is

what we have seen in practice.

Third, I am not worried at all that the Federal Reserve’s balance sheet

expansion will generate an inflation problem. It should be emphasized

that the Federal Reserve has the ability to manage down the size of its balance

sheet over time once financial conditions and the economy improve. Many

of the liquidity facilities will shrink automatically as financial conditions

normalize. With the exception of TAF loans, all of the other Fed liquidity

facilities charge rates that are higher than what one would expect during more

normal financial circumstances. And, if we want the TAF loans to shrink,

we can either shrink the amounts on offer or raise the interest rate we charge,

or both. The other assets such as Treasury securities and agency MBS

can be sold or the impact on reserves be offset by repurchase operations that

drain reserves from the banking system.

More importantly, the Federal Reserve

now has the tools to allow the conduct of monetary policy to be separated from

the size of the balance sheet and the amount of excess reserves in the banking

system. In September 2008, the Federal Reserve gained the authority to pay

interest on excess reserves. This provides a tool that allows Fed officials

to tighten monetary policy and raise private sector interest rates by raising

the rate paid on excess reserves.

Some skeptics note that when interest on

excess reserves was first implemented, the federal funds rate traded somewhat

below the rate on excess reserves. This has created worry in some quarters

that paying interest on excess reserves might not work very well as a tool

for controlling the federal funds rate.

On this issue, two points are warranted.

First, the relatively large gap between the interest rate on excess reserves

and the federal funds rate was due, in large part, to the impaired condition

of the banking system, which inhibited the willingness of banks to arbitrage

that gap. Because balance sheet capacity was scarce, banks were reluctant to

use their balance sheets to purchase federal funds at a slight discount to

the interest on excess reserves rate. As the banking system returns to health,

this arbitrage is likely to become more attractive, causing the gap between

the interest rate on excess reserves and the federal funds rate to narrow.

Second, the Federal Reserve could alter its monetary policy framework in order

to increase its control of monetary policy in a large excess reserve environment.

It is beyond the scope of this speech to get into the details, but we have

plenty of options in devising incentives for banks to hold reserves at the

Fed that would improve our ability to control the federal funds rate. The challenge

will be deciding on the best option, not in finding a workable approach.

Thank

you for your attention.

I am happy to take any questions.

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