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Mayra Rodríguez Valladares is managing principal at MRV Associates, a New York-based capital markets and financial regulatory consulting and training firm. She is also a faculty member at Financial Markets World and the New York Institute of Finance.
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Is Measuring the TBTF Subsidy a Distraction?

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Are the nation's biggest banks still receiving government subsidies six years after the crisis? Two recent studies by the Federal Reserve and the International Monetary Fund suggest that global systemically important banks benefit from implicit subsidies because the market believes they will be bailed out in the event of a crisis. A separate study by Oliver Wyman, sponsored by The Clearing House Association, concluded that subsidies received by big banks are negligible. A long-awaited study on the matter from the Government Accountability Office is due out this summer.

But some argue that quantifying the subsidies that banks receive is hardly the most important issue. Global systemically important banks, or G-SIBs, continue to have very large challenges in the areas of credit, market, operational and liquidity risks. That's what regulators, policymakers and the media should be focusing on.

I have long felt that it is very difficult to measure subsidies precisely, especially since the types and amounts of data inputs used in these measurement models  - including yields, credit spreads and ratings - will influence the results in varied ways. Patrick Sims, director at Hamilton Place Strategies, a policy and public affairs consulting firm, argues that "it is important to measure the subsidy with data since the Dodd-Frank Act was passed."

There is "no question there was a subsidy before crisis," Sims says. But with Dodd-Frank, he says, it is "against the law to bail out a bank. No politician would bail out a bank now."

Paul Saltzman, who oversees the legal, compliance and litigation functions at The Clearing House, has criticized the Fed study's methodology, arguing that it "was irrelevant since the data used were bond yields before the crisis."

Wayne Abernathy, the American Bankers Association's executive vice president of financial institutions policy and regulatory affairs, points out that "everyone will critique each other's methodology to measure any too-big-to-fail subsidy."

While it may be difficult to quantify the size of subsidies, Abernathy argues that "there is a consistent trend in all the studies. Whatever advantage existed, the more recent data show a much smaller advantage, if any at all."

Yet subsidies of any size have the potential to do real harm, as Boston University law professor Cornelius Hurley argues. "A subsidy prevents normal governance from taking place," Hurley says. "It serves as a poison pill and as disincentive to divestitures by making all too-big-to-fail assets worth less outside the TBTF womb."

Like Hurley, I believe that we should investigate the many other benefits that large banks receive, including special terms for collateral, default covenants in long-term debt and more favorable treatment on repurchase agreements. We have already had enough studies measuring the TBTF subsidy. Let's look at all the other benefits that TBTF banks continue to receive that keep them too large to manage, supervise or even to jail.

A bill crafted by Hurley for Representative Mike Capuano, HR 2266, aims to measure the too-big-to-fail subsidy once and for all. More important, however, it would require banks to hold additional capital to sustain unexpected losses. Right now, it has not even made it to committee. Anat Admati, a professor of finance and economics at Stanford University, says that while HR 2266 is "well intentioned," for her "the real elephant in the room is that big banks are very leveraged and get away with more risk at other people's expense."

Admati's concern is that trying to measure the TBTF subsidy may be a distraction from "making banks live in the real world of having more equity the way other corporations do."

Professor Mehrsa Baradaran at the University of Georgia School of Lawconcurs with Admati. "Focusing on measuring the TBTF subsidy is missing the point," she argues. "There is a very strong bank-government partnership. Does banking exist without Fed funding and Federal Deposit Insurance Corp. insurance?"

Even if we manage to measure the subsidy, the whole infrastructure that makes banks so big remains. In their study "Has Market Discipline Improved After the Dodd-Frank Act?," Professor Bhanu Balasubramnian of the University of Akron and Professor Ken B. Cyree of the University of Mississippi point out that "the market knows banks have support from FDIC guarantees on banks' deposit liabilities. Deposit holders do not actively monitor banks because of that insurance."

No matter how much time we spend trying to measure the TBTF subsidy, Admati reminds us that the "subsidy studies do not measure banks' distance to default." That's what should keep us up at night.

My own view is aligned with that of Admati: "Large banks cause a lot of collateral damage. Having more equity solves distortions; banks should be charged for the secondhand smoking damage that they cause."

Mayra Rodríguez Valladares is managing principal at MRV Associates, a New York-based capital markets and financial regulatory consulting and training firm. She is also a faculty member at Financial Markets World and the New York Institute of Finance.

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Comments (4)
Agree. Going on 6 years after the Financial Crisis caused, the fact that Too Big To Fail Banks still exists is unconscionable. Captured federal financial regulators continue to avoid taking the hard actions necessary to reduce the risk presented by the financial behemoths that drove the US economy to the brink of collapse. As a result, these casino-like entities masquerading as government-insured banks became Too Big To Behave, and now Too Big To Jail. If federal regulators are Too Timid To Do Their Jobs, they should be removed. The safety of the US economy is too important to rest in the hands of placeholders making more money than the average, hard-working banker.
Posted by jim_wells | Saturday, May 03 2014 at 6:32PM ET
Jim_Wells spot on once again. Can't add much to what he said other than a little humor..."Dodd Frank makes bailing out a bank illegal."" Bwahahaha!!!!
Posted by TxTim | Monday, May 05 2014 at 9:36AM ET
@ TxTim - yes, hard to believe that federal financial regulators who continue to prove that they are Too Timid To Regulate even in times of relative calm would be able to summon up the testicular fortitude required to hold the line on the Too Big To Jail Banks when (NOT if) they precipitate the next financial crisis.
Posted by jim_wells | Monday, May 05 2014 at 10:21AM ET
It's interesting that in the late 1980's a paper entitled "A mandate for change" published by the FDIC called for the elimination of deposit insurance. Trying to find this paper is nearly impossible, falling into a memory hole. To measure the subsidy, take a representative set of assets from a G-SIB and place it in an uninsured mutual fund, where the fund is levered as a bank and mutual ownership is consistent with similar equity ownership. The funding cost difference between these two entities will capture the bulk of the subsidy. It would prove to be large, and were banks to be removed from underpriced deposit insurance and the fractional reserve system, they would be instantly structurally unprofitable.
Posted by | Tuesday, August 19 2014 at 2:03AM ET
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