Европейская денежная система
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Nowadays and in our industrial economies, runs may occur mainly in textbooks. They have little relevance in reality because, since Bagehot, many antidotes have been adopted: deposit insurance, the regulation of capital adequacy and large exposures, improved licensing and supervisory standards all contribute to the preservation of depositors' confidence and minimise the threat of a contagion from insolvent to solvent institutions.
A less unlikely case is a rapid outflow of uninsured interbank liabilities. However, since interbank counterparties are much better informed than depositors, this event would typically require the market to have a strong suspicion that the bank is actually insolvent. If such a suspicion were to be unfounded and not generalised, the width and depth of today's interbank market is such that other institutions would probably replace (possibly with the encouragement of the public authorities as described above) those which withdraw their funds. It should be noted, in this respect, that the emergence of the single euro money market lowers banks' liquidity risk, because the number of possible sources of funds is now considerably larger than in the past.
Given all of these contingencies, the probability that a modern bank is solvent, but illiquid, and at the same time lacks sufficient collateral to obtain regular central bank funding, is, in my view, quite small. The textbook case for emergency liquidity assistance to individual solvent institutions has, as a matter of fact, been a most rare event in industrial countries over the past decades.
28. What if this rare event were nevertheless to occur and cause a systemic threat? The clear answer is that the euro area authorities would have the necessary capacity to act. This is not only my judgement, but also that of the Eurosystem, whose decision-making bodies have, as you can imagine, carefully discussed the matter. I am not saying that we are, or shall be, infallible; no one can claim such a divine quality. I am saying that there are neither legal-cum-institutional, nor organisational, nor intellectual impediments to acting when needed. In stating this, I am aware that central banks may be the only source of immediate and adequate funds when a crisis requires swift action, while solvency remains an issue and failure to act could threaten the stability of the financial system.
In these circumstances the various national arrangements would continue to apply, including those concerning the access of central banks to supervisors' confidential information. As is well known, such arrangements differ somewhat from country to country.
29. The criticism I have referred to also underestimates the
Eurosystem's capacity to act. To the extent that there would be an overall
liquidity effect that is relevant for monetary policy or a financial
stability implication for the euro area, the Eurosystem itself would be
actively involved.
The Eurosystem is, of course, well equipped for its two collective decision-making bodies (the Board and the Council) to take decisions quickly whenever needed, whether for financial stability or for other reasons. This readiness is needed for a variety of typical central bank decisions, such as the execution of concerted interventions or the handling of payment system problems. Indeed, it has already been put to work during the changeover weekend and in the first few weeks of this year.
A clear reassurance about the capacity to act when really needed should be sufficient for the markets. Indeed, it may even be advisable not to spell out beforehand the procedural and practical details of emergency actions. As Gerry Corrigan once put it, maintaining "constructive ambiguity" in these matters may help to reduce the moral hazard associated with a safety net. I know of no central bank law within which the lender-of- last-resort function is explicitly defined.
The question of who acts within the Eurosystem should also be
irrelevant for the markets, given that any supervised institution has an
unambiguously identified supervisor and national central bank. As to the
access to supervisory information, the lack of direct access by the
Eurosystem should not be regarded as a specific flaw of the euro area's
institutional framework, as has been frequently argued, since this
situation also exists at the national level wherever a central bank does
not carry out day-to-day supervision.
30. Finally, the criticism reflects an overly mechanistic view of how a crisis is, and should be, managed in practice. Arguing in favour of fully disclosed, rule-based policies in order to manage crises successfully and, hence, maintain market confidence, is almost self-contradictory. Emergency situations always contain unforeseen events and novel features, and emergency, by its very nature, is something that allows and even requires a departure from the rules and procedures adopted for normal times or even in the previous crisis. Who cares so much about the red light when there is two metres of snow on the road? As for transparency and accountability, these two sacrosanct requirements should not be pushed to the point of being detrimental to the very objective for which a policy instrument is created. Full explanations of the actions taken and procedures followed may be appropriate ex post, but unnecessary and undesirable ex ante.
31. So far, I have focused on the provision of emergency liquidity to
a bank. This is not the only case, however, in which central bank money may
have to be created to avoid a systemic crisis. A general liquidity "dry-up"
may reflect, for example, a gridlock in the payment system or a sudden drop
in stock market prices. The actions of the Federal Reserve in response to
the stock market crash of 1987 is an often cited example of a successful
central bank operation used to prevent a dangerous market-wide liquidity
shortfall. This kind of action is close to the monetary policy function and
has been called the "market operations approach" to lending of last resort.
In such cases, liquidity shortfalls could be covered through collateralised
intraday or overnight credit, or auctioning extra liquidity to the market.
The Eurosystem is prepared to handle this kind of market disturbance.
VI. CONCLUSION
32. In my remarks this evening, I have looked at the euro area as one that has a central bank which does not carry out banking supervision. This would be normal, because in many countries banking supervision is not a task of the central bank. What is unique is that the areas of jurisdiction of monetary policy and of banking supervision do not coincide. This situation requires, first of all, the establishment of smooth co-operation between the Eurosystem and the national banking supervisors, as is the case at the national level where the two functions are separated. The most prominent reason for this is, of course, the scenario where the provision of liquidity from the central bank has to be made in a situation that is generated by problems of interest to the supervisor. But beyond that, I do not know any country in which the central bank is not very closely interested in the state of health of the banking system, irrespective of its supervisory responsibilities.
33. In my view, we should move as rapidly as possible to a model in
which the present division of the geographical and functional jurisdiction
between monetary policy and banking supervision plays no significant role.
I do not mean necessarily a single authority or a single set of prudential
rules. Rather I mean that the system of national supervisors needs to
operate as effectively as a single authority when needed. While the causes
of banking problems are often local or national, the propagation of
problems may be area-wide. The banking industry is much more of a system
than other financial institutions.
34. I am clearly aware that we are far from having a common
supervisory system. But since the euro has just been launched and will
last, we have to look in prospective terms at what needs to be set in
place. There is no expectation, at least to my mind, that the division of
responsibility in the euro area between the central bank and the banking
supervisory functions should be abandoned. Although the Treaty has a
provision that permits the assignment of supervisory tasks to the ECB, I
personally do not rely on the assumption that this clause will be
activated. What I perceive as absolutely necessary, however, is that co-
operation among banking supervisors, which is largely voluntary but which
finds no obstacles in the existing Directives or in the Treaty, will allow
a sort of euro area collective supervisor to emerge that can act as
effectively as if there were a single supervisor. This is desirable in the
first instance to render the supervisory action more effective against the
background of current and future challenges and, second, to assist the
Eurosystem in the performance of its basic tasks.
TABLES
Table 1. Market share of branches and subsidiaries of foreign credit institutions as % of total domestic assets, 1997
From EEA countries From third countries
TOTAL
Branches Subsidiaries Branches
Subsidiaries
AT 0.7 1.6 0.1 1.0
3.4
BE 9.0 19.2 6.9 1.2
36.3
DE 0.9 1.4 0.7 1.2
4.2
ES 4.8 3.4 1.6 1.9
11.7
FI 7.1 0 0 0
7.1
FR 2.5 NA 2.7 NA
9.8
IR 17.7 27.8 1.2 6.9
53.6
IT 3.6 1.7 1.4 0.1
6.8
NL 2.3 3.0 0.5 1.9
7.7
SE 1.3 0.1 0.1 0.2
1.7
UK 22.5 1.0 23.0 5.6
52.1
Source: ECB report "Possible effects of EMU on the EU banking systems in the medium to long term" (February 1999).
Table 2. Assets of branches and subsidiaries of domestic credit institutions in foreign countries as % of total domestic assets, 1997
In EEA countries In third countries
TOTAL
Branches Subsidiaries Branches
Subsidiaries
AT 2.6 NA 3.7 NA
NA
DE 12.0 7.3 7.8 0.9
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