Asset Backed Securities. Drunken Risibility.

Asset Backed Securities (ABS) are freely traded financial instruments that represent packages of loans issued by the commercial banks. The majority are created from mortgages, but credit card debt, commercial real estate loans, student loans, and hedge fund loans are also known to have been securitized. The earliest form of ABS within the American banking system appears to stem from the creation of the Federal National Mortgage Association (Fannie Mae) in 1938 as part of amendments to the US National Housing Act, a Great Depression measure aimed at creating loan liquidity. Fannie Mae, and the other Government Sponsored Enterprises buy loans from approved mortgage sellers, typically banks, and create guaranteed financial debt instruments from them, to be sold on the credit markets. The resulting bonds, backed as they are by loan insurance, are widely used in pension funds and insurance companies, as a secure, financial instrument providing a predictable, low risk return.

The creation of a more general form of Mortgage Backed Security is credited to Bob Dall and the trading desk of Salmon brothers in 1977 by Michael Lewis (Liar’s Poker Rising Through the Wreckage on Wall Street). Lewis also describes a rapid expansion in their sale beginning in 1981 as a side effect of the United States savings and loans crisis. The concept was extended in 1987 by bankers at Drexel Burnham Lambert Inc. to corporate bonds and loans in the form of Collateralized Debt Obligations (CDOs), which eventually came to include mortgage backed securities, and in the form of CDO-Squared instruments, pools of CDO.

Analysis of the systemic effects of Asset Backed Security has concentrated chiefly on their ability to improve the quantity of loans, or loan liquidity, which has been treated as a positive feature by Greenspan. It has also been noted that securitization allowed banks to increase their return on capital by transforming their operations into a credit generating pipeline process. Hyun Song Shin has also analysed their effect on bank leverage and the stability of the larger financial system within an accounting framework. He highlights the significance of loan supply factors in causing the sub-prime crisis. Although his model appears not to completely incorporate the full implications of the process operating within the capital reserve regulated banking system, it presents an alternate, matrix based analysis of the uncontrolled debt expansion that these instruments permit.

The systemic problem introduced by asset backed securities, or any form of sale that transfers loans made by commercial banking institutions outside the regulatory framework is that they allow banks to escape the explicit reserve and regulatory capital based regulation on the total amount of loans being issued against customer deposits. This has the effect of steadily increasing the ratio of bank originated loans to money on deposit within the banking system.

The following example demonstrates the problem using two banks, A and B. For simplicity fees related to loans and ABS sales are excluded. It is assumed that the deposit accounts are Net Transaction accounts carry a 10% reserve requirement, and that both banks are ”well capitalised” and that the risk weighted multiplier for the capital reserve for these loans is also 10.

The example proceeds as a series of interactions as money flows between the two banks. The liabilities (deposits) and assets (loans) are shown, with loans being separated into bank loans, and Mortgage Backed Securities (MBS), depending on their state.

Initial Conditions: To simplify Bank B is shown as having made no loans, and has excess reserves at the central bank to maintain the balance sheet. The normal inter-bank and central bank lending mechanisms would enable the bank to compensate for temporary imbalances during the process under normal conditions. All deposit money used within the example remains on deposit at either Bank A or Bank B. On the right hand side of the table the total amount of deposits and loans for both banks is shown.

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Step 1: Bank A creates a $1000 Mortgage Backed Security from the loan on its balance sheet.

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Step 2: The securitized loan is sold to the depositor at Bank B. $1000 is paid to Bank A from that depositor in payment for the loan. Bank A now has no loans outstanding against its deposits, and the securitized loan has been moved outside of banking system regulation. Note that total deposits at the two banks have temporarily shrunk due to the repayment of the loan capital at A. The actual transfer of the deposits between the banks is facilitated through the reserve holdings which also function as clearing funds.

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Step 3: As Bank A now has no loans against its deposits, and is within its regulatory capital ratios, it can make a new $1000 loan. The funds from this loan are deposited at Bank B. The sum of the deposits rises as a result as does the quantity of loans. Note that the transfer of the loan money from Bank A to Bank B again goes through the reserve holdings in the clearing system and restores the original balance at Bank B.

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Step 4: Bank A securitizes the loan made in Step 3 repeating Step 1.

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Step 5: Bank A sells the MBS to the depositor at Bank B, repeating Step 2.

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Step 6: Bank A makes a new loan which is deposited at Bank B, repeating Step 3.

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Step 7: Bank A securitizes the loan made in Step 6, repeating Step 4.

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Since the Deposit and Loan positions of the two banks are identical in all respects in Steps (1,4), (2,5), (3,6) and (4,7) the process can continue indefinitely, resulting in expansion of the total commercial bank originated loan supply independent of central bank control.

This is a simplified version of the flows between loans, deposits, and asset backed securities that occur daily in the banking system. At no point has either bank needed recourse to central bank funds, or broken any of their statutory requirements with respect to capitalisation or reserve requirements where they apply.

The problem is the implicit assumption with reserve based banking systems that bank originated loans remain within the banking system. Allowing the sale of loans to holders outside of the regulated banking system (i.e. to entities other than regulated banks) removes these loans from that control and thus creates a systemic loophole in the regulation of the commercial bank loan supply.

The introduction of loans sales has consequently created a novel situation in those modern economies that allow them, not only in causing a significant expansion in total lending from the banking sector, but also in changing the systemic relationship between the quantity of money in the system to the quantity of bank originated debt, and thereby considerably diluting the influence the central bank can exert over the loan supply. The requirement that no individual bank should lend more than their deposits has been enforced by required reserves at the central bank since the 19th century in Europe, and the early 20th century in the USA. Serendipitously, this also created a systemic limit on the ratio of money to bank originated lending within the monetary system. While the sale of Asset Backed Securities does not allow any individual bank to exceed this ratio at any given point in time, as the process evolves the banking system itself exceeds it as loans are moved outside the constraints provided by regulatory capital or reserve regulation, thereby creating a mechanism for unconstrained growth in commercial bank originated lending.

While the asset backed security problem explains the dramatic growth in banking sector debt that has occurred over the last three decades, it does not explain the accompanying growth in the money supply. Somewhat uniquely of the many regulatory challenges that the banking system has created down the centuries, the asset backed security problem, in and of itself does not cause the banks, or the banking system to ”print money”.

The question of what exactly constitutes money in modern banking systems is a non-trivial one. As the examples above show, bank loans create money in the form of bank deposits, and bank deposits can be used directly for monetary purposes either through cheques or more usually now direct electronic transfer. For economic purposes then, bank deposits can be regarded as directly equivalent to physical money. The reality within the banking system however is somewhat more complex, in that transfers between bank deposits must be performed using deposits in the clearing mechanisms, either through the reserves at the central bank, or the bank’s own asset deposits at other banks. Nominally limits on the total quantity of central bank reserves should in turn limit the growth in bank deposits from bank lending, but it is clear from the monetary statistics that this is not the case.

Individually commercial banks are limited in the amount of money they can lend. They are limited by any reserve requirements for their deposits, by the accounting framework that surrounds the precise classification of assets and liabilities within their locale, and by the ratio of their equity or regulatory capital to their outstanding, risk weighted loans as recommended by the Basel Accords. However none of these limits is sufficient to prevent uncontrolled expansion.

Reserve requirements at the central bank can only effectively limit bank deposits if they apply to all accounts in the system, and the central bank maintains control over any mechanisms that allow individual banks to increase their reserve holdings. This appears not to be the case. Basel capital restrictions can also limit bank lending. Assets (loans) held by banks are classified by type, and have accordingly different percentage capital requirements. Regulatory capital requirements are divided into two tiers of capital with different provisions and risk categorisation applying to instruments held in them. To be adequately capitalised under the Basel accords, a bank must maintain a ratio of at least 8% between its Tier 1 and Tier 2 capital reserves, and its loans. Equity capital reserves are provided by a bank’s owners and shareholders when the bank is created, and exist to provide a buffer protecting the bank’s depositors against loan defaults.

Under Basel regulation, regulatory capital can be held in a variety of instruments, depending on Tier 1 or Tier 2 status. It appears that some of those instruments, in particular subordinated debt and hybrid debt capital instruments, can represent debt issued from within the commercial banking system.

Annex A – Basel Capital Accords, Capital Elements Tier 1

(a) Paid-up share capital/common stock

(b) Disclosed reserves

Tier 2

(a) Undisclosed reserves

(b) Asset revaluation reserves

(c) General provisions/general loan-loss reserves

(d) Hybrid (debt/equity) capital instruments

(e) Subordinated debt

Subordinated debt is defined in Annex A of the Basel treaty as:

(e) Subordinated term debt: includes conventional unsecured subordinated debt capital instruments with a minimum original fixed term to maturity of over five years and limited life redeemable preference shares. During the last five years to maturity, a cumulative discount (or amortisation) factor of 20% per year will be applied to reflect the diminishing value of these instruments as a continuing source of strength. Unlike instruments included in item (d), these instruments are not normally available to participate in the losses of a bank which continues trading. For this reason these instruments will be limited to a maximum of 50% of tier 1.

This is debt issued by the bank, in various forms, but of guaranteed long duration, and controlled repayment. In effect, it allows Banks to hold borrowed money in regulatory capital. It is subordinate to the claims of depositors in the event of Bank failure. The inclusion of subordinated debt in Tier 2 allows financial instruments created from lending to become part of the regulatory control on further lending, creating a classic feedback loop. This can also occur as a second order effect if any form of regulatory capital can be purchased with money borrowed from within the banking system

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