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     Aug 24, 2007
Page 3 of 5
Central bank impotence and market liquidity
By Henry C K Liu

primary credit for short-term contingency funding should be viewed as appropriate and unexceptional by both [bank] management and supervisors". Still, banking being a traditionally conservative industry, such stigma persists about discount window borrowing. The above-market price of the discount rate cut on August 17 by the Fed by half from its100 basis points cap to 50 basis points over the Fed Funds rate target to facilitate discount borrowing had to be qualified with a public repeat of Fed policy that such



borrowing does not reflect weakness in the borrowing banks. Yet the cut in the discount rate reflects weakness in the entire banking system, a message not missed by astute market participants.

When a bank borrows from the Fed's discount window, it increases the funds it has in its reserve account held at the Fed, which the bank can apply towards meeting its reserve requirement. Thus, ceteris paribus (all other things being equal), one would expect that when required reserves are higher, discount window borrowing would be higher.

Reserve requirements are the amount of funds that a depository institution must hold in reserve against specified deposit liabilities. Within limits specified by law, the Federal Reserve board of governors has sole authority over changes in reserve requirements. Depository institutions must hold reserves in the form of vault cash or deposits with Federal Reserve banks. The dollar amount of a depository institution's reserve requirement is determined by applying the reserve ratios specified in the Federal Reserve board's regulation D to an institution's reservable liabilities, which consist of net transaction accounts, non-personal time deposits and euro-currency liabilities.

Since December 27, 1990, non-personal time deposits and euro-currency liabilities have had a reserve ratio of zero. The reserve ratio on net transactions accounts depends on the amount of net transactions accounts at the depository institution. The Garn-St Germain Act of 1982 exempted the first $2 million of reservable liabilities from reserve requirements. This "exemption amount" is adjusted each year according to a formula specified by the act. The amount of net transaction accounts subject to a reserve requirement ratio of 3% was set under the Monetary Control Act of 1980 at $25 million. This "low-reserve tranche" is also adjusted each year. Net transaction accounts in excess of the low-reserve tranche are currently reservable at 10%.

Reserve balance driven by interbank payments
The demand for reserve balances is increasingly being driven by growth in interbank payment activity rather than by minimum reserve requirements. Interbank payments are processed over Fedwire, the large-value payment system owned and operated by the Fed. The value of aggregate Fedwire payments increased from roughly $1.3 trillion a day in 1992 to roughly $3 trillion a day in early 2004. These payments are funded from an aggregate reserve balance that, as of the first quarter of 2004, averaged only $11.5 billion.

To facilitate an efficient payment system, the Fed allows banks to maintain limited negative reserve balances during the business day at a low cost, currently 27 basis points at an annual rate, but imposes a stiff 400 basis point penalty on negative balances held overnight. Before 2003, banks faced with an unexpected negative balance late in the day might have gone to the discount window, but they might have remained reluctant. The new primary credit facility reduces the perceived stigma of borrowing from the Fed, and banks in this situation would borrow from the central bank and pay a penalty capped at 100 basis points over Fed Funds rate.

The Clearing House Interbank Payments System (CHIPS) is a privately operated, real-time, multilateral, payments system typically used for large dollar payments, owned by financial institutions, and any banking organization with a regulated US presence may become an owner and participate in the network.

The payments transferred over CHIPS are often related to international interbank transactions, including the dollar payments resulting from foreign currency transactions, such as spot and currency swap contracts, and euro placements and returns. Payment orders are also sent over CHIPS for the purpose of adjusting correspondent balances and making payments associated with commercial transactions, bank loans and securities transactions.

Since January 2001, CHIPS has been a real-time final settlement system that continuously matches, nets and settles payment orders. In June, CHIPS processed $2.645 trillion of payments. CHIPS typically handles about 300 payments ($90 billion in gross, $36 billion net) in its queue at the end of the day.

Liquidity risk in the interbank payment system
Liquidity risk is the risk that the financial institution cannot settle an obligation for full value when it is due even if it may be able to settle at some unspecified time in the future. Liquidity problems can result in opportunity costs, defaults in other obligations, or costs associated with obtaining the funds from some other source for some period of time.

In addition, operational failures may also negatively affect liquidity if payments do not settle within an expected time period. Until settlement is completed for the day, a financial institution may not be certain what funds it will receive and thus it may not know if its liquidity position is adequate. If an institution overestimates the funds it will receive, even in a system with real-time finality, then it may face a liquidity shortfall. If a shortfall occurs close to the end of the day, an institution could have significant difficulty in raising the liquidity it needs from an alternative source.

Systems that postpone a significant portion of their settlement activity in dollars toward the end of the day, such as CHIPS, may be particularly exposed to liquidity risk. These risks can also exist in Real Time Gross Settlement (RTGS) systems such as Fedwire. Systems or markets that pose various forms of settlement risk also pose forms of liquidity risk.

With the average daily turnover in global foreign exchange (FX)transactions at over $2 trillion, the FX market needs an effective cross-currency settlement process. Continuous Linked Settlement (CLS) is a means of settling foreign-exchange transactions finally and irrevocably. CLS eliminates settlement risk, improves liquidity management, reduces operational banking costs and improves operational efficiency and effectiveness.

CLS Bank based in New York is an Edge Corporation bank supervised by the Federal Reserve. CLS Bank is a multi-currency bank, holding an account for each settlement member and an account at each eligible currency's central bank, through which funds are received and paid. Technical and operational support is provided by CLS Services, an affiliate of CLS Bank.

CLS Bank, while eliminating the bulk of principle risk through its payment-versus-payment design, retains significant liquidity risk, as funding is made on a net basis, and pay-in obligations may need to be adjusted in the event that a counterparty is unable to fund its obligations. Other systems, including securities settlement systems, may also be subject to liquidity risks.

To manage and control liquidity risk, it is important for financial institutions to understand the intraday flows associated with their customers' activity to gain an understanding of peak funding needs and typical variations. To smooth a customer's peak credit demands, a depository institution might consider imposing overdraft limits on all or some of its customers. Moreover, institutions must have a clear understanding of all of their proprietary payment and settlement activity in each of the payment and securities settlement systems in which they participate.

Clearing balance requirements represent obligations to hold reserves that are set at the discretion of a bank before each reserve maintenance period. Only balances held at the Federal Reserve during the two-week reserve maintenance period are eligible to satisfy clearing balance requirements. A bank is penalized for ending any day overdrawn on its account at the Fed, as well as for failing to meet its requirements by the end of the maintenance period.

To obtain the necessary reserves to avoid these fees if unable to borrow the necessary amount of reserves from another bank, a qualifying bank may borrow reserves directly from the Federal Reserve at its discount window facility under the primary credit program, at a rate typically set not more than 100 basis points above the target Fed Funds rate. This spread between the primary credit rate and the Fed Funds rate target is generally viewed as representing a de facto penalty associated with being deficient. This penalty was cut in half on August 18. The Federal Reserve does not pay interest on reserves held in excess of requirements. Thus, the opportunity cost of holding excess reserves is a bank's marginal funding cost, which is represented by the Fed Funds rate.

To provide banks with some flexibility in meeting their requirements for avoiding these penalties and costs, the Fed allows banks to apply excess reserve balances held in one maintenance period to meet reserve requirements in the following period, in an amount up to 4% of reserve requirements in the second period. Similarly, a bank may end a period up to 4% short of its reserve requirements and pay no penalty, as long as it holds sufficient excess reserves in the following period to offset this deficiency.

Fed actions aim at mutually contradicting objectives
The Federal Reserve action on the discount rate tries to meet its short-term responsibility to keep financial markets functioning by injecting funds into the banking system. At the same time, the Fed tries also to macro manage the economy in containing inflation by tightening the money supply through interest rates increases.

For almost a century since its establishment in 1913, the Fed has been engaged in a continuous battle between inflation and economic growth by standing on both sides of the conflict to keep a balance. This conflict is a structural malady of market capitalism. Recurring economic recessions or depressions lead to

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