Global Money Notes #6: QE, Basel III and The Fed's New Target Rate
Global Money Notes #6: QE, Basel III and The Fed's New Target Rate
Global
Economic Research
DISCLOSURE APPENDIX AT THE BACK OF THIS REPORT CONTAINS IMPORTANT DISCLOSURES AND ANALYST
CERTIFICATIONS.
10 June 2016
1 QE and Basel III euthanized unsecured interbank money markets, but not secured interdealer money markets. We will discuss
trends in interdealer money markets on Page 6.
Figure 1 (overleaf) shows the resulting shift in the rate pairs that banks “play off” against
each other: the relevant pairs are no longer within and across private money market
segments but rather unsecured rates and IOER; unsecured rates and centrally cleared
(GCF) repo rates; and unsecured rates and the intermediate points on the Treasury curve.
Matched book money dealing – money market funding of money market lending – is no
longer private on both sides, but rather half private, half public. Banks don’t fund each
other anymore but rather the sovereign – the U.S. Treasury or its subsidiary, the Fed.
Figure 2 (overleaf) shows this shift in action through the matched money market books of
the New York branches of foreign banks. The size of matched books did not change much
since the crisis, but their asset side is entirely different: o/n and term loans to other banks
(fed funds and deposits, respectively) and interoffice loans are out, and HQLA (reserves)
are in. Reverses (or reverse repos, a source of HQLA) are less important but present still.
On the funding side too, interbank (fed funds) trades are gone and what remains are
funding from headquarters and unsecured funding from non-bank customers.
Basel III drove a wider wedge between the new rate pairs than the spread between the old
pairs used to be: the spread between o/n rates used to be razor thin (about a basis point
or two), but the spread between IOER and the effective fed funds rate is 12.5 bps today.
Why? Because banks need every penny of reserves as HQLA against short-term liabilities
(demand for which is driven by customer liquidity needs), and since HQLA is a low-margin
use of balance sheet and balance sheet is no longer infinite but scarce, o/n spreads have
settled structurally wider. Furthermore, Basel III limits leverage and by extension the
amount of balance sheet available to compress spreads – which is practically nil.
And so, high-volume, low-margin private money dealing gave way to Basel III compliance
through public-private money dealing at wider margins (see McCulley and Pozsar, 2014).
Basel III also interacts with QE.
Reserves – the quintessential byproduct of QE – are HQLA and reserves can only be held
by banks. By extension, QE influences the composition of banks’ HQLA portfolios.
During the initial rounds of QE, every penny of reserves added to the system were indeed
excess – in excess of the amount banks needed to comply with reserve requirements.
But when Basel III – and in particular, the Liquidity Coverage Ratio – went live, all reserves
became required: not to comply with reserve requirements but with the LCR (see here).
Banks have no incentive to either borrow or lend reserves these days.
Banks have no incentive to borrow reserves because they already hold more than what‘s
needed to comply with reserve requirements, and they have no incentive to lend reserves
either because if they do their HQLA portfolios would shrink and their LCR would worsen.
The reason why we still have a fed funds (FF) market is because Basel III does not apply
to a small corner of the U.S. banking system – the Federal Home Loan Banks (FHLBs).
The FHLBs are the only banks left in the system that still have an incentive to lend to other
banks on an unsecured basis on scale. On the flipside, the only banks that borrow from
the FHLBs are highly rated foreign banks with an aim to arbitrage the FF-IOER rate pair
and subject to a version of Basel III lighter than that that which applies to U.S. banks.
As we have discussed in previous issues of Global Money Notes (see here and here) the
small size of the FF market (about $60 billion), the small number of FF market participants
(10 lenders and a dozen or so borrowers) and the even balance of power between the two
sides of the FF market make the FF rate prone to trade along a suspiciously straight line.
It appears that informal agreements between the two sides of a small market that’s slowly
(but surely) fading into irrelevance have more to do with where the effective FF rate trades
than the Fed’s new operational framework or the magnetic pull of IOER (see here).
Scrapping the FF rate as the Fed’s policy target won’t be a choice but a necessity, in our view.
MML MMF FF FF
(private) (private) ED ED
CD CD
CP CP
Reverses RPs
HQLA MMF
(public) (private)
Reserves MMF
(Fed) (private)
Reverses
(GCF)
Treasuries
Reserves Unsecured FF FF
(Fed) (customer) ED ED
Reverses CD CD
(GCF) CP CP
Treasuries Reverses RPs
800
700
600
500
400
300
200
100
0
Assets Liabilities Assets Liabilities
June 30, 2007 December 31, 2015
HQLA (reserves) FF sold Balances w/ U.S. banks Balances w/ banks offshore Reverse repos
Loans to HQ (net) FF purchased CP Deposits Loans from HQ (net)
No problem, you say: we have the Fed’s new overnight bank funding rate (OBFR) as an
alternative to the FF rate. Unlike the FF market, the o/n eurodollar (ED) market frequented
by U.S.-based banks is deeper ($250 billion versus $60 billion), more populous (hundreds
of borrowers versus a dozen) and hence more reliable a yardstick of o/n bank funding
conditions. In addition, the OBFR trades on top of the FF rate and also along a straight
line, so the Fed’s operating framework must be doing something right, right? Not so fast…
That OBFR also trades along a straight line has to do with the fact that bank funding desks
use the FF rate as a reference point to price o/n ED deposits. Things get circular…
Furthermore, unlike the FF rate – a yardstick of o/n onshore interbank funding conditions –
the OBFR is a yardstick of mostly offshore (as opposed to onshore) funding conditions and
references mostly customer-to-bank (as opposed to interbank) trades. And that’s a big deal.
It is a big deal because switching from the FF rate to OBFR as the Fed’s policy target is
not without a broad set of existential questions. Were that switch to happen the Fed would
go from targeting an onshore rate to targeting an offshore rate; from targeting an interbank
rate to targeting a customer-to-bank rate; from an operating framework built around
TOMOs (or temporary open market operations) to one centered around POMOs
(permanent open market operations); and by extension, from targeting interest rates by
fine-tuning the amount of reserves to targeting the quantity of reserves in HQLA portfolios
through episodic rounds of asset purchases (regulatory as opposed to quantitative easing).
These massive reserve holdings – representing weeks’ worth of liquidity needs – are the
reason why banks no longer trade liquidity among each other anymore. Everyone’s flush…
In contrast, broker-dealers do not have access to reserve accounts at the Fed. For them
HQLA is Treasuries reversed in through GCF repo trades or Treasuries held outright. In a
30-day storm, broker-dealers won’t have the luxury of running down reserve balances.
They will have to repo out HQLA (their unencumbered Treasury portfolio) from the get go.
In other words, dealers are flush with collateral, not reserves. And collateral ain’t money…
On a day-to-day basis, the interdealer GCF repo market is the main market where liquidity
gets redistributed within the dealer community (between primary and non-primary dealers).
The volatility of the o/n GCF repo rate is similar to what the volatility of the FF rate used to
be when banks too were liquidity constrained, similar to the way dealers are liquidity
constrained today. Figure 3 (overleaf) plots the behavior of the o/n GCF repo rate versus
that of the FF rate: like electrocardiograms, flickers mean life and flatlines the opposite of
life. The o/n GCF repo market is the only functioning money market left standing today.
But the GCF repo market is a market where broker-dealers account for the bulk of activity
and where banks are present only as opportunistic lenders and seldom ever as borrowers
(banks typically lend in the GCF repo market if the o/n GCF repo rate is above IOER and
typically don’t borrow as repos encumber collateral, reduce HQLA and worsen one’s LCR).
And because it is broker-dealers that do the bulk of borrowing and lending in interdealer
markets, capping a repo target rate in a crisis is possible only if dealers too have access to
the discount window (IOER serves as a ceiling for the o/n GCF rate only in normal times,
not crisis times). President Dudley’s recent speech on Amelia Island arguing for discount
window access for primary dealers should be understood in this context. In specific:
“Now that all major securities firms in the U.S. are part of bank holding companies and are
subject to enhanced prudential standards as well as capital and liquidity stress tests,
providing these firms with access to the Discount Window might be worth exploring.”
President Dudley’s call to emancipate the Fed from Lender of Last Resort (for banks) to
Dealer of Last Resort (for the system as a whole – both traditional and shadow) despite
the spirit of the Dodd-Frank Act (which limits the Fed’s 13(3) lending authority) may signal
the Fed’s discomfort with the OBFR as a target rate and preference for a repo rate instead.
After all, a local interdealer repo target rate would get around the global customer-to-bank
aspects of OBFR. But then the Fed has be comfortable with a target rate that’s a funding
rate for shadow banks, not banks – there… the devil’s ugly head popped up again.
And even then, don’t forget that before DoLR and a repo target rate become reality, the
Fed will have to get a lot of lawyering done in a climate that’s all but cooperative.
Until we hear more about DoLR, do know that the OBFR is the only game in town.
Is it essential that an alternative reference rate be capped by the Fed’s discount window?
Most definitely. When the relationship between the FF and Libor rates broke down in 2007
(i.e., when the par exchange rate between onshore and offshore dollars broke down) the
Fed had to roll out dollar swap lines to regain control of Libor (the old reference rate).
OBFR is capped by the swap lines (see here) but if the target becomes a repo rate, the
Fed – learning from experience – will prefer to have a mechanism for control in place…
1.2 5.6
1.0 5.5
0.8 5.4
0.6 5.3
0.4 5.2
0.2 5.1
0.0 5.0
FF effective (July 1st 2003 - July 1st 2004) FF effective (November 1st, 2014 - November 1st, 2015)
o/n GCF Treasury repo (January 1st, 2015 - November 30th, 2015) FF effective (July 1st, 2006 - July 1st 2007) [RHS)
1.75
1.50
1.25
1.00
0.75
0.25
o/n RRP o/n RRP o/n RRP
0.00
o/n 1M 3M 6M 1Y 2Y 3Y 5Y 7Y 10Y o/n 1M 3M 6M 1Y 2Y 3Y 5Y 7Y 10Y o/n 1M 3M 6M 12M o/n 1M 3M 6M 12M o/n 1M 3M 6M 12M o/n 1M 3M 6M 12M
Banks Primary Dealers Bank Funding Curve Primary Dealers Private Cash Pools Public Cash Pools
(HQLA curve) (HQLA curve) (unsecured) (matched books) (safe asset curves)
Source: Federal Reserve, DTCC, The Bank of New York, Credit Suisse
2 All repo rates mentioned on this page refer to o/n tenors and Treasury collateral.
9. The steepness of the unsecured bank funding curve beyond the 30-day point is
structural and reflects the price of “freedom”: three- and six-month funding have no
HQLA requirements and with term funding banks can do anything they please.
10. The Fed’s foreign repo pool is most definitely a policy tool. The Fed’s repos with
foreign central banks and multilateral organizations pre-date the tri-party repo system
and are executed on a bilateral basis. They return cash early, at 8:30 AM, in an era
when repo trades that settle through the tri-party platform – including o/n RRPs with
the Fed – return cash at 3:30 PM. Investors find out the rate they will earn overnight
at around 4:00 PM – so late because the Fed needs time to finish its daily survey of
where dealers got funded during the day. The rate paid by the foreign repo pool is
very close to the o/n GCF repo rate but it is not the same. Our instinct says that it
matches the volume weighted average rate of o/n GCF repo trades done both
bilaterally and on a tri-party basis and which the Fed derives from the above dealer
survey. And so the Fed pays a market rate. But the fact that the rate on the foreign
repo pool matches a market rate and hence does not influence interdealer repo
rates does not mean that it does not impact things elsewhere. Since late 2014, the
rate paid by the foreign repo pool has been “surfing” the structural widening
between o/n GCF and tri-party repo rates and has been consistently yielding more
than Treasury bills. Over this period, the foreign repo pool morphed into a superior
alternative to bills – nothing beats o/n trades with the Fed with an 8:30 cash return
yielding more than term bills. As foreign central banks traded out bills and into the
foreign repo pool – greased by an apparently secret removal of “the constraints
imposed on customers’ ability to vary the size of their investments” – the effective
supply of Treasury bills increased by $250 billion. And since o/n tri-party Treasury
repos, Treasury bills and o/n RRPs with the Fed are substitutes (see point 4 above),
$250 billion in extra bills meant $250 billion worth of bids not hitting primary dealer’s
shrinking balance sheets begging for o/n tri-party trades they cannot make, and that
much in bids not hitting the Fed’s o/n RRP facility. If the o/n RRPs facility and
Treasury bills are substitutes and the foreign repo pool and Treasury bills are
substitutes as well, then the o/n RRP facility and the foreign repo pool are
substitutes too. Both facilities are full allotment but one at an administered price and
one at a market price, and both facilities are in the business of providing safe, short-
term assets in an era where quantities matter more than prices.3 So to reiterate, the
foreign repo pool is a policy tool. And just like the use of metaphors from physics to
describe how FF trades, saying that the foreign repo pool is not a policy tool when in
fact it is confuses, rather than illuminates at a time of change. In Exhibit 4 (see Page
7 above) the foreign repo pool is marked by a black dot – an allegory for the foreign
repo pool as the system’s wandering black hole…
And with all that dig in, and enjoy Money Markets after QE and Basel III…
3 The foreign repo pool is in a league of its own. Central bank facilities are either fixed price, full allotment (where the central bank
sets the price and the market determines the quantity) or fixed size, variable price (where the central bank sets the size and the
market determines the price). Oddly, the foreign repo pool is neither: its size is full allotment and its rate varies with the market
(in fact its rate is the interdealer market rate). It is a gift wrapped in gold: giving an interdealer rate for a segment of cash pools in
violation of the hierarchical nature of money markets, where only dealers should earn the interdealer rate and only those private
cash pools that are big enough to extract a pound of flesh from primary dealers. The foreign repo pool flattens the hierarchy…
← inside spread →
Banks as opportunistic lenders
↓
0.25
↑
Hard floor and outside spread
0.00
15 16
o/n RRP (cash pools/MFs to Fed) o/n TRP (cash pools/MFs to dealers) OBFR (cash pools/MFs to bank)
EFFR (FHLBs to banks) o/n GCF (inter-dealer) IOER (banks to Fed)
Source: Federal Reserve, DTCC, The Bank of New York, Credit Suisse
0.50
↑
Soft floor to the o/n GCF repo rate
0.25
0.00
15 16
o/n RRP (cash pools/MFs to Fed) o/n TRP (cash pools/MFs to dealers) OBFR (cash pools/MFs to bank)
EFFR (FHLBs to banks) o/n GCF (inter-dealer) IOER (banks to Fed)
US ECONOMICS
James Sweeney
Head of US Economics Xiao Cui Zoltan Pozsar
+1 212 538 4648 +1 212 538 2511 +1 212 538 3779
[email protected] [email protected] [email protected]
BRAZIL ECONOMICS
Nilson Teixeira
Head of Brazil Economics Iana Ferrao Leonardo Fonseca Paulo Coutinho Lucas Vilela
+55 11 3701 6288 +55 11 3701 6345 +55 11 3701 6348 +55 11 3701-6353 +55 11 3701-6352
[email protected] [email protected] [email protected] [email protected] lucas.vilela @credit-suisse.com
EUROPEAN ECONOMICS
Neville Hill
Head of European Economics Giovanni Zanni Sonali Punhani Peter Foley Anais Boussie
+44 20 7888 1334 +44 20 7888 6827 +44 20 7883 4297 +44 20 7883 4349 +44 20 7883 9639
[email protected] [email protected] [email protected] [email protected] [email protected]