by Calculated Risk on 10/21/2009 01:30:00 PM

Yesterday both former Fed Chairman Paul Volcker and BofE Governor Mervyn King argued to break up the big banks. Fed Governor Tarullo disagrees.

From Fed Governor Daniel Tarullo: Confronting Too Big to Fail

One approach suggested by a number of commentators is to reverse the 30-year trend that allowed progressively more financial activities within commercial banks and more affiliations with non-bank financial firms. The idea is presumably to insulate insured depository institutions from trading or other capital market activities that are thought riskier than traditional lending functions. There are, however, at least two reasons why this strategy seems unlikely to limit the too-big-to-fail problem to a significant degree. One is that, historically at least, some very large institutions got themselves into a good deal of trouble through risky lending alone. Moreover, as we have already seen in the experience with Bear Stearns and Lehman, firms without commercial banking operations can now also pose a too-big-to-fail threat.

Another approach would be to attack the bigness problem head-on by limiting the size or interconnectedness of financial institutions. Some observers have even suggested that existing large firms should be split up into smaller, not-too-big-to-fail entities, in a manner a bit reminiscent of the break-up of AT&T in the early 1980s. Of course, the conceptual and practical challenges in breaking up the nation’s largest financial institutions would be considerably more daunting than those faced by Judge Greene in creating four regional operating companies and a long distance carrier out of the old AT&T. Indeed, to my knowledge, no one has offered anything like standards for undertaking this task, much less a blueprint for how it would be accomplished. This is, in other words, more a provocative idea than a proposal. Like many a provocative idea, though, even in an unelaborated form it can focus attention on the relative effectiveness of alternative policy proposals.

The fact that the largest financial firms will account for a significantly larger share of total industry assets after the crisis than they did before can only add to the uneasiness of those worried about the too-big-to-fail phenomenon. It is notable that current law provides very little in the way of structural means to limit systemic risk and the too-big-to-fail problem. The statutory prohibition on interstate acquisitions that would result in a commercial bank and its affiliates holding more than 10 percent of insured deposits nationwide is the closest thing to such an instrument. Policymakers and policy commentators alike might usefully attempt to develop similarly discrete mechanisms that could be beneficial in containing the too-big-to-fail problem. As must be apparent from my remarks today, my strong suspicion is that an effective response to the problem will likely require multiple, mutually reinforcing instruments.
emphasis added

Tarullo suggests:

A regulatory response for the too-big-to-fail problem would enhance the safety and soundness of large financial institutions and thereby reduce the likelihood of severe financial distress that could raise the prospect of systemic effects. Such a response consists of three elements.

First, the shortcomings of the regulations that failed to protect the stability of the firms and the financial system need to be rectified. Regulatory capital requirements can balance the incentive to excessive risk-taking that may arise when there is believed to be government support for a firm, or at least some of its liabilities. There is little doubt that capital levels prior to the crisis were insufficient to serve their functions as an adequate constraint on leverage and a buffer against loss. The Federal Reserve has worked with other U.S. and foreign supervisors to strengthen capital, liquidity, and risk-management requirements for banking organizations. In particular, higher capital requirements for trading activities and securitization exposures have already been agreed. Work continues on improving the quality of capital and counteracting the procyclical tendencies of important areas of financial regulation, such as capital and accounting standards.

These regulatory changes are surely a necessary part of a response to the too-big-to-fail problem, but there is good reason to doubt that they are sufficient. Generally applicable capital and other regulatory requirements do not take account of the specifically systemic consequences of the failure of a large institution. It is for this reason that many have proposed a second kind of regulatory response--a special charge, possibly a special capital requirement, based on the systemic importance of a firm. Ideally, this requirement would be calibrated so as to begin to bite gradually as a firm’s systemic importance increased, so as to avoid the need for identifying which firms are considered too-big-to-fail and, thereby, perhaps increasing moral hazard.
...
A third regulatory change is in some respects the most obvious and straightforward: Any firm whose failure could have serious systemic consequences ought to be subject to regulatory requirements such as those I have just described.

by Calculated Risk on 10/21/2009 11:47:00 AM

From the BLS: Regional and State Employment and Unemployment Summary

Twenty-three states and the District of Columbia recorded over-the-month unemployment rate increases, 19 states registered rate decreases, and 8 states had no rate change, the U.S. Bureau of Labor Statistics reported today. Over the year, jobless rates increased in all 50 states and the District of Columbia.
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In September, nonfarm payroll employment decreased in 43 states and the District of Columbia and increased in 7 states.
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Michigan again recorded the highest unemployment rate among the states, 15.3 percent, in September. The states with the next highest rates were Nevada, 13.3 percent; Rhode Island, 13.0 percent; and California, 12.2 percent. The rates in Nevada and Rhode Island set new series highs. Florida, at 11.0 percent, also posted a series high.
emphasis added

Click on graph for larger image in new window.

This graph shows the high and low unemployment rates for each state (and D.C.) since 1976. The red bar is the current unemployment rate (sorted by the current unemployment rate).

Fourteen states and D.C. now have double digit unemployment rates.

New Jersey, Indiana, and Missouri are all close.

Three states are at record unemployment rates: Rhode Island, Nevada, and Florida. Several others - like California, Delaware, North Carolina and Georgia - are close.

by Calculated Risk on 10/21/2009 09:11:00 AM

From Reuters: U.S. architecture billings up in September-AIA

... The Architecture Billings Index was up 1.4 points at 43.1, matching July's level, according to the American Institute of Architects.

The index has remained below 50, indicating contraction in demand for design services, since January 2008.
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A measure of inquiries for new projects, however, rose to 59.1, its highest in two years -- "an encouraging sign," said AIA Chief Economist Kermit Baker.

"Some larger stimulus-funded building activity should be coming online over the next several months, partially offsetting the steep decline in private commercial construction," Baker said.

Click on graph for larger image in new window.

This graph shows the Architecture Billings Index since 1996. The index has remained below 50, indicating falling demand, since January 2008.

Note: Nonresidential construction includes commercial and industrial facilities like hotels and office buildings, as well as schools, hospitals and other institutions.

Historically there is an "approximate nine to twelve month lag time between architecture billings and construction spending" on commercial real estate (CRE). This suggests further dramatic declines in CRE investment through most of 2010, if not longer.

by Calculated Risk on 10/21/2009 08:56:00 AM

The MBA reports: Mortgage Applications Decrease

The Market Composite Index, a measure of mortgage loan application volume, decreased 13.7 percent on a seasonally adjusted basis from one week earlier. ...

The Refinance Index, also adjusted for the holiday, decreased 16.8 percent from the previous week and the seasonally adjusted Purchase Index decreased 7.6 percent from one week earlier.
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The average contract interest rate for 30-year fixed-rate mortgages increased to 5.07 percent from 5.02 percent, with points increasing to 1.13 from 1.11 (including the origination fee) for 80 percent loan-to-value (LTV) ratio loans.

Click on graph for larger image in new window.

This graph shows the MBA Purchase Index and four week moving average since 2002.

The Purchase index declined to 268.8, and the 4-week moving average declined to 284.

Note: The increase in 2007 was due to the method used to construct the index: a combination of lender failures, and borrowers filing multiple applications pushed up the index in 2007, even though activity was actually declining.

by Calculated Risk on 10/20/2009 10:18:00 PM

A couple of interesting articles and a daily summary ...

From MarketWatch: Treasury to introduce program to help small banks

The ABA and other bank lobby groups for small banks are seeking to have Treasury develop a program to provide TARP funds to small stressed banks -- those with less than $5 billion in assets -- on the cusp of a default that haven't received TARP funds.

And I thought everyone agreed that the FDIC closing small failing banks - albeit slowly - was an example of how bank problems should be resolved. Now we have "Too small to fail"?

Philly Fed Chairman Charles Plosser, in a speech tonight, questioned the effectiveness of many of the recent Fed actions: Sound Monetary Policy for Good Times and Bad

As the crisis unfolded and problems arose in different parts of the financial system, the Fed responded by trying to increase liquidity in several markets through special lending programs. These programs may have had some stabilizing effects on markets and may have lowered some spreads. Yet, without defining in advance a systematic and consistent approach to such lending, these programs also raised uncertainty — in this case, about who would or would not have access to the various facilities. This was illustrated when the Term Asset-Backed Securities Loan Facility (or TALF) was announced. Many market participants lobbied for expanding the categories of securities eligible for the program. Did these multiple lending programs keep lenders on the sidelines waiting to see which asset classes the Fed would support and which it would not? Did this delay the healing of the financial markets?

Bank of England Governor Mervyn King criticized the lack of reform and 'too big to fail'. Here is the text of King's speech. Or see The Telegraph and The Times for excerpts.

Housing Starts were flat in September. And I also posted a short comment on why the focus should be on housing starts (and new home sales), and not existing home sales - and why (briefly) I think a V-shaped recovery is not going to happen: Housing and the Economy

I posted some HAMP Modification Documents and some discussion of a trial modification. Note: Reposted documents with all personal information removed.

There was much more discussion of the first-time home buyer tax credit today. The White House expects to announce a decision in the next couple of weeks.

DataQuick reported that California Mortgage Defaults Trended Down in Q3 . This will be a record year for default notices, and DataQuick also noted that defaults are moving up into higher priced areas.

Note: I recently changed the page layout. It now has the last 5 posts, and then short excerpts and links to previous posts.