Too big to fail


"Too big to fail" is a theory in banking and finance that asserts that certain corporations, particularly financial institutions, are so large and so interconnected with an economy that their failure would be disastrous to the greater economic system, and therefore should be supported by government when they face potential failure. The colloquial term "too big to fail" was popularized by U.S. Congressman Stewart McKinney in a 1984 Congressional hearing, discussing the Federal Deposit Insurance Corporation's intervention with Continental Illinois. The term had previously been used occasionally in the press, and similar thinking had motivated earlier bank bailouts.
The term emerged as prominent in public discourse following the 2008 financial crisis. Critics see the policy as counterproductive and that large banks or other institutions should be left to fail if their risk management is not effective. Some critics, such as economist Alan Greenspan, believe that such large organizations should be deliberately broken up: "If they're too big to fail, they're too big." Some economists such as Paul Krugman hold that financial crises arise principally from banks being under-regulated rather than their size, using the widespread collapse of small banks in the Great Depression to illustrate this argument.
In 2014, the International Monetary Fund and others said the problem still had not been dealt with. While the individual components of the new regulation for systemically important banks likely reduced the prevalence of TBTF, the fact that there is a definite list of systemically important banks considered TBTF has a partly offsetting impact.

Definition

Federal Reserve Chair Ben Bernanke also defined the term in 2010: "A too-big-to-fail firm is one whose size, complexity, interconnectedness, and critical functions are such that, should the firm go unexpectedly into liquidation, the rest of the financial system and the economy would face severe adverse consequences." He continued that: "Governments provide support to too-big-to-fail firms in a crisis not out of favoritism or particular concern for the management, owners, or creditors of the firm, but because they recognize that the consequences for the broader economy of allowing a disorderly failure greatly outweigh the costs of avoiding the failure in some way. Common means of avoiding failure include facilitating a merger, providing credit, or injecting government capital, all of which protect at least some creditors who otherwise would have suffered losses.... If the has a single lesson, it is that the too-big-to-fail problem must be solved."
Bernanke cited several risks with too-big-to-fail institutions:
  1. These firms generate severe moral hazard: "If creditors believe that an institution will not be allowed to fail, they will not demand as much compensation for risks as they otherwise would, thus weakening market discipline; nor will they invest as many resources in monitoring the firm's risk-taking. As a result, too-big-to-fail firms will tend to take more risk than desirable, in the expectation that they will receive assistance if their bets go bad."
  2. It creates an uneven playing field between big and small firms. "This unfair competition, together with the incentive to grow that too-big-to-fail provides, increases risk and artificially raises the market share of too-big-to-fail firms, to the detriment of economic efficiency as well as financial stability."
  3. The firms themselves become major risks to overall financial stability, particularly in the absence of adequate resolution tools. Bernanke wrote: "The failure of Lehman Brothers and the near-failure of several other large, complex firms significantly worsened the crisis and the recession by disrupting financial markets, impeding credit flows, inducing sharp declines in asset prices, and hurting confidence. The failures of smaller, less interconnected firms, though certainly of significant concern, have not had substantial effects on the stability of the financial system as a whole."

    Background on banking regulation

Depository banks

Prior to the Great Depression, U.S. consumer bank deposits were not guaranteed by the government, increasing the risk of a bank run, in which a large number of depositors withdraw their deposits at the same time. Since banks lend most of the deposits and only keep a fraction actually on hand, a bank run can render the bank insolvent. During the Depression, hundreds of banks became insolvent and depositors lost their money. As a result, the U.S. enacted the 1933 Banking Act, sometimes called the Glass–Steagall Act, which created the Federal Deposit Insurance Corporation to insure deposits up to a limit of $2,500, with successive increases to the current $250,000. In exchange for the deposit insurance provided by the federal government, depository banks are highly regulated and expected to invest excess customer deposits in lower-risk assets. After the Great Depression, it has become a problem for financial companies that they are too big to fail, because there is a close connection between financial institutions involved in financial market transactions. It brings liquidity in the markets of various financial instruments. The crisis in 2008 originated when the liquidity and value of financial instruments held and issued by banks and financial institutions decreased sharply.

Investment banks and the shadow banking system

In contrast to depository banks, investment banks generally obtain funds from sophisticated investors and often make complex, risky investments with the funds, speculating either for their own account or on behalf of their investors. They also are "market makers" in that they serve as intermediaries between two investors that wish to take opposite sides of a financial transaction. The Glass–Steagall Act separated investment and depository banking until its repeal in 1999. Prior to 2008, the government did not explicitly guarantee the investor funds, so investment banks were not subject to the same regulations as depository banks and were allowed to take considerably more risk.
Investment banks, along with other innovations in banking and finance referred to as the shadow banking system, grew to rival the depository system by 2007. They became subject to the equivalent of a bank run in 2007 and 2008, in which investors withdrew sources of financing from the shadow system. This run became known as the subprime mortgage crisis. During 2008, the five largest U.S. investment banks either failed, were bought out by other banks at fire-sale prices or were at risk of failure and obtained depository banking charters to obtain additional Federal Reserve support. In addition, the government provided bailout funds via the Troubled Asset Relief Program in 2008.
Fed Chair Ben Bernanke described in November 2013 how the Panic of 1907 was essentially a run on the non-depository financial system, with many parallels to the crisis of 2008. One of the results of the Panic of 1907 was the creation of the Federal Reserve in 1913.

Resolution authority

Before 1950, U.S. federal bank regulators had essentially two options for resolving an insolvent institution: 1) closure, with liquidation of assets and payouts for insured depositors; or 2) purchase and assumption, encouraging the acquisition of assets and assumption of liabilities by another firm. A third option was made available by the Federal Deposit Insurance Act of 1950: providing assistance, the power to support an institution through loans or direct federal acquisition of assets, until it could recover from its distress.
The statute limited the "assistance" option to cases where "continued operation of the bank is essential to provide adequate banking service". Regulators shunned this third option for many years, fearing that if regionally or nationally important banks were thought generally immune to liquidation, markets in their shares would be distorted. Thus, the assistance option was never employed during the period 1950–1969, and very seldom thereafter. Research into historical banking trends suggests that the consumption loss associated with National Banking Era bank runs was far more costly than the consumption loss from stock market crashes.
The Federal Deposit Insurance Corporation Improvement Act was passed in 1991, giving the FDIC the responsibility to rescue an insolvent bank by the least costly method. The Act had the implicit goal of eliminating the widespread belief among depositors that a loss of depositors and bondholders will be prevented for large banks. However, the Act included an exception in cases of systemic risk, subject to the approval of two-thirds of the FDIC board of directors, the Federal Reserve Board of Governors, and the Treasury Secretary.

Analysis

Bank size and concentration

Bank size, complexity, and interconnectedness with other banks may inhibit the ability of the government to resolve the bank without significant disruption to the financial system or economy, as occurred with the Lehman Brothers bankruptcy in September 2008. This risk of "too big to fail" entities increases the likelihood of a government bailout using taxpayer dollars.
The largest U.S. banks continue to grow larger while the concentration of bank assets increases. The largest six U.S. banks had assets of $9,576 billion as of year-end 2012, per their 2012 annual reports. The top 5 U.S. banks had approximately 30% of the U.S. banking assets in 1998; this rose to 45% by 2008 and to 48% by 2010, before falling to 47% in 2011.
This concentration continued despite the subprime mortgage crisis and its aftermath. During March 2008, JP Morgan Chase acquired investment bank Bear Stearns. Bank of America acquired investment bank Merrill Lynch in September 2008. Wells Fargo acquired Wachovia in January 2009. Investment banks Goldman Sachs and Morgan Stanley obtained depository bank holding company charters, which gave them access to additional Federal Reserve credit lines.
Bank deposits for all U.S. banks ranged between approximately 60–70% of GDP from 1960 to 2006, then jumped during the crisis to a peak of nearly 84% in 2009 before falling to 77% by 2011.
The number of U.S. commercial and savings bank institutions reached a peak of 14,495 in 1984; this fell to 6,532 by the end of 2010. The ten largest U.S. banks held nearly 50% of U.S. deposits as of 2011.