Who Likes the Financial Stability Board's Recommendation of a Fee for FX Benchmark Trades?

The Financial Stability Board released a consultative study on FX benchmark rates that includes several items for the industry to consider as well as a couple of recommendations.  One recommendation was to widen the period of the window for calculating rates.  Another was that the banks should charge for the service of filling fix orders.

As it currently stands, the WM Reuters rate, the London Close benchmark which is the fix with by far the largest daily volume, includes a bid, mid-rate and offer rate for each currency pair.  Most large and many small users of the fix are filled at the mid-rate, and thus do not pay any fee or bid offer spread to their bank for filling their order.

Why does this occur?  Banks allow it as the cost of doing business with large customers.  If others are doing it, you need to do it as well - it became a market practice in effect.

Bank customers, of course, would like all trades executed for free, so how did fix trades become the only trade type executed routinely without spread or fee? This occurred as many funds use the WM Reuters FX rates to translate their local currency asset values into base currency values each day.  The investment managers then wanted to execute any trades for that day at the same rate to avoid FX tracking error for their funds.  Many managers also saw these rates as a means to achieve market rates without going through the work of negotiating rates with their banks. Others such as corporates began using the mid rate for execution purposes while hedge funds and others did so for speculative purposes.

While this seemed to be a win for the customers, it was not for the banks.  When the fix began in the early 1990s FX spreads were quite wide compared to today and perhaps the banks could more easily tolerate these "free trades".  Apparently as pressure increased on traders to perform in an environment of reducing spreads, some misconduct occurred, including collusion, as a means to generate profits on these trades.

The FSB's suggestion seems quite sensible to us.  Expecting free services does not. In effect, the actions that traders took in recent years reinforces the adage regarding no free lunches.  Using bid offer spreads or a small commission should reduce this tension between bank and customer.

While not the only change required to benchmark trading, this change is reasonable and should go along way in making this a more rational part of the FX business.

Asset managers and other fix users may not like the concept initially, but its inherent reasonableness and the need to increase market participants' faith in benchmark rates should see customers agreeing.  The devil being in the details, however, the size of any commission or spread (tracking error to many) may be much more controversial.

Bankers' New Clothes? Authors' New Clothes? Whose Clothes are Real?

The Bankers' New Clothes:  What's Wrong with Banking and What to Do about It

We've just finished this popular criticism of modern banking by Anat Admati and Martin Hellwig.  We pay the highest compliment (in our view) that a book of this type can earn:  the authors are right.  Well, backtracking just a bit, the authors are qualitatively right on their central point.

Admati and Hellwig have one clear and dominant message:  banks should have much more equity.  The book pushes risk weighting of assets to the side and complains that modern banks - even after the Credit Crisis - may have equity that is just 3% of total assets.  The authors want 20-30% equity as the minimum rather than 3%.  Say it again - banks should have much more equity!

These bank antagonists spend much of the book (correctly) anticipating bankers' objections and giving sound refutations.  For example, increased capital requirements will not reduce lending IF banks choose to raise equity rather than reduce assets.  Also, bank ROE may certainly decline with increased equity, but the bank shareholders' RISK also declines - making the outcome more of a trade-off than a penalty to equity investors.

The downside of Bankers' New Clothes is everything else.  There is nothing resembling a justification of the 20-30% equity-to-asset prescription.  Admati and Hellwig simply state that bank equity was higher in the 19th century and was in this 20-30% range at the beginning of the 20th century.  This "analysis" is not adequate - the authors would have retained more credibility by admitting this shortcoming themselves.

While Admati and Hellwig give reasonably thoughtful discussions of recent failures of regulation, unholy alliances between governments and banks, the negative consequences of political meddling with banks, and the great desirability to just let banks fail, they then DEFEND and argue for the preservation of regulators, government and political control, and the imperative NOT to let banks fail!!

The Admati-Hellwig thesis is simple (and simple is good!):  force banks to have 20-30% equity relative to assets and don't change anything else.  We like the first part (qualitatively) ....