Dodd-Frank Worsens Covids Risk
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Hal Scott argues for restoring the Fed’s crisis-era powers to mitigate financial contagion risks, emphasizing the need for pre-emptive action & international coordination through the G20.

, "...Here’s what should be done immediately:First, the Fed should reactivate all the facilities it created in the crisis and any additional ones it believes necessary, so it is ready to be the strongest possible lender of last resort—to do whatever it takes, consistent with its present legal authority. This includes making U.S. dollars available to other major central banks through currency swaps. And the Treasury secretary should announce his approval of these efforts, consistent with the requirements of Section 13(3). Second, financial regulators should modify their rules and supervision to stimulate liquidity in the interbank and repo markets. Third, Congress should restore all the powers it took away from the Fed, FDIC and Treasury during the crisis. Fourth, international coordination through the Group of 20 must be accelerated.This is a global problem...."
Hal Scott, "Dodd-Frank Worsens Covid’s Risk,"Wall Street Journal, March 11, 2020, https://www.wsj.com/articles/dodd-frank-worsens-covids-risk-11583961933
Dodd-Frank Worsens Covid’s Risk
Coronavirus is contagious. So is financial panic.
The spread of the novel coronavirus could cause a run on the financial system leading to a deep recession. Severe stock-market drops and increased demand for liquidity are warning signals. Bank equity capital has increased by $750 billion to $2.1 trillion since 2007, but a panic could still overwhelm well-capitalized banks. We need to restore the weapons to fight contagion that Congress took away during the last financial crisis. Strong pre-emptive action would greatly diminish the risk of a panic.
The previous systemic threat to the financial system was spurred by the failure of Lehman Brothers in 2008. That threat came from within the banking system in the form of bad housing loans. This time is different. Wall Street risk-taking isn’t to blame for the coronavirus.
In 2008 the Fed supplied needed liquidity to the banking and nonbanking financial sector, the latter through its authority under Section 13(3) of the Federal Reserve Act. Meanwhile, the Federal Deposit Insurance Corp. expanded the limits of deposit insurance, among other things providing unlimited protection for transaction accounts. The Treasury Department offered guarantees to money-market funds.
Once the crisis abated, however, there was growing public concern about “moral hazard”—that government backstops and guarantees created incentives for risky behavior. In response, the Dodd-Frank Act of 2010 limited the Fed’s lender-of-last-resort powers for nonbanks, an increasingly important part of the financial system. Fed loans to nonbanks can now be made only with the approval of the Treasury secretary. They must be done through a broad program, unlike the one-off rescue of AIG, and must meet heightened collateral requirements. Loans to nonbanks must be disclosed to congressional leaders within seven days and to the public within one year. Loans to banks must be disclosed within two years. While disclosure is usually desirable, in this situation it creates the specter of future stigma that deters financial institutions from seeking even badly needed Fed funding. Even before the current crisis, banks’ use of the discount window had dropped to record lows.
Dodd-Frank also prevents the FDIC from expanding guarantees to bank depositors without congressional approval, as it did in the credit crisis. And the Treasury is now prohibited from guaranteeing money-market funds. These legislative changes make it difficult for the Fed and other regulators to deal effectively with a financial panic.
Government agencies have compounded the problem of their own weakness with regulations that make it harder for financial firms to lend to each other. The liquidity coverage ratio, the Fed liquidity stress tests, and the “living wills” process require the largest banks to meet stiff liquidity requirements that can result in liquidity hoarding.
Even before the coronavirus sent markets tumbling, the scarcity of liquidity was a big problem. The 9% spike of overnight repurchase agreement, or repo, rates last September caused the Fed to supply as much as $75 billion a day to the repo market. Although the demand for such support had fallen to about $26 billion by the end of February, it rose to $100 billion on March 4. The Fed responded Monday by raising the minimum support offered to $150 from $100 billion. While this change is welcome, it falls short.
Here’s what should be done immediately: First, the Fed should reactivate all the facilities it created in the crisis and any additional ones it believes necessary, so it is ready to be the strongest possible lender of last resort—to do whatever it takes, consistent with its present legal authority. This includes making U.S. dollars available to other major central banks through currency swaps. And the Treasury secretary should announce his approval of these efforts, consistent with the requirements of Section 13(3). Second, financial regulators should modify their rules and supervision to stimulate liquidity in the interbank and repo markets. Third, Congress should restore all the powers it took away from the Fed, FDIC and Treasury during the crisis. Fourth, international coordination through the Group of 20 must be accelerated. This is a global problem.
China, Europe and Japan already have many of these powers. Policy makers in the U.S. need them too. Bold action can prevent a panic before it starts. The public knows the situation is serious and wants the government to act.





























Ed Comment: I LOVE to see Main finally admitting my chief criticism of their work -- criticism I published that surely they read: "The negative consequences of a crisis are due to both the crisis itself but also to the imbalances that precede a crisis." As you (Steve) recall, those were imbalances their proposed solution stupidly advocated perpetrating after the crisis as a solution to the crisis. Failing to see that allocations prior to the crisis were onetime and could not continue growing forever was a preposterously stupid oversight on their part. Ironically, I was also the one who recognized it might not be a misallocation, just a one time expansion of an allocation that could not continue to expand at the same rate forever, much less expanded in the face of the crisis as they initially proposed. It showed an utter lack of understanding of what caused the crisis--an expansion of risk-averse (offshore ) savings that destabilized an inherently unstable banking system (that costs more than it was worth to stabilized privately rather than publicly--hence the slowest recovery since ww2).
Amir Sufi and Alan Taylor argue that financial crises are predictable and foreshadowed by credit and elevated asset prices. The negative consequences are a function of both to the crisis itself but also preceding imbalances, “…Financial crises have large deleterious effects on economic activity, and as such have been the focus of a large body of research. This study surveys the existing literature on financial crises, exploring how crises are measured, whether they are predictable, and why they are associated with economic contractions. Historical narrative techniques continue to form the backbone for measuring crises, but there have been exciting developments in using quantitative data as well. Crises are predictable with growth in credit and elevated asset prices playing an especially important role; recent research points convincingly to the importance of behavioral biases in explaining such predictability. The negative consequences of a crisis are due to both the crisis itself but also to the imbalances that precede a crisis. Crises do not occur randomly, and, as a result, an understanding of financial crises requires an investigation into the booms that precede them…”
“…For financial crises to be seen as a distinct, important, and disastrous type of event, we might first ask: how damaging are they? and how frequent?The associated downturns are much more adverse than a typical normal recession. We present a headline summary in Table 1. Using local projections (LPs, see Jorda`, 2005), the deviation of real GDP per capita y is estimated h years after a crisis event. In the first two panels, the event is a crisis year and the baseline is trend; in the last two panels the event is the peak of a financial recession (a crisis within ±2 years) and the baseline is a normal recession. To start, using the simpler crisis year definition, Table 1a shows that at a 6 year horizon, real GDP per capita is lower by about 5%-6% following crises, relative to trend. Table 1b shows the result is not driven by the great global crises, the synchronized distress in many countries seen in the interwar depression and the 2008 Global Financial Crisis. Next, aligning events using business cycle peaks as in Jorda, Schularick, and Taylor ` (2013), Table 1c shows that over 6 years, real GDP per capita is lower by about 4% after financial peaks, relative to normal peaks. Table 1d shows this is also not driven global crises, with a deviation of about 3% still seen…”

“…The raw event frequency summary for the onset of financial crises is given in Table 2, and it is also noteworthy that, despite the unusually calm period from 1946 to 1970, when no financial crisis events were seen in advanced economies and very few in emerging economies, the incidence of financial crisis recessions has been large in recent decades, and comparable to outcomes in the turbulent 1870 to 1939 period….”
“…The empirical evidence we survey supports the view that financial crises are indeed predictable, especially by credit and asset price growth. Support has also built up for the view that deviations from rational expectations are an important component in explaining this predictability. In general, the findings in the literature fit a broader trend in macroeconomics towards the study of the booms that precede economic downturns; or, as (Beaudry, Galizia, and Portier, 2020) put it, “putting the cycle back into business cycle analysis.”…”
“…We highlight two interesting findings in Baron, Verner, and Xiong (2021), notably: first, declines in real bank equity returns R B are the best coincident classifier of conventional narrative financial crisis binary events, compared to many macroeconomic and financial variables; second, bank equity returns are a strong predictor of subsequent growth slow downs and credit crunches, based on an LP analysis, even controlling for real nonfinancial equity returns R N, a result we discuss in more detail below. A third result also bears mentioning: banking panics (runs by depositors/creditors) on their own have small macro-financial consequences—it is the bank failures that matter most. Obviously, panics can happen without failures, and failures without panics, in theory and in the data. This finding is important since much debate centered on whether the key locus of the crisis problem is runnable funding outbreaks (roughly, liquidity), or systemic failures (roughly, solvency). The empirical record points to the latter as the more serious issue in terms of macroeconomic consequences, and justifies the central use of solvency and failure criteria in the traditional narrative definition of a financial crisis…”
“..In sum, both measures—bank equity crashes and the traditional narrative indicator— reflect emergent problems on bank balance sheets. They are not perfectly correlated, and the failure-based narrative indicator still provides the most discriminating information: BVX count 197 narrative failure events, and out of these 193 are called as crises (98%); but out of a count of 269 bank equity crashes, only 138 are called as crises (51%). This shows that the inclusion of data on bank equity declines complements the narrative approach with useful auxiliary information….”
“…To confront the issue of whether asset price booms also contribute meaningfully to elevated financial crisis risk, Jorda, Schularick, and Taylor (2015b) collate further data series on equity and housing prices for the long-panel of advanced economies. They develop a “bubble indicator” based on whether the asset price in a given year is more than one s.d. above its de-trended value (using a lowpass filter) and whether there is also a subsequent large correction. An illustration of this approach is in Figure 6c, where the sample is again restricted to recession peaks, and the logit estimation is augmented to include a bubble indicator for either asset price. When there is no bubble in either asset price, crisis risk is generally low. In contrast, when there is either kind of bubble, crisis risk is significantly elevated, by a factor of roughly 1.5 in the mid-range of credit growth
“…Some illustrative evidence is shown in Figure 7a using local projections. The outcome variable is private credit to GDP, denoted CREDGDPct, from the Jord`a, Schularick, and Taylor (2017) bank loan measure, and the sample is the long-panel of advanced economies. The shock is a change in the degree of financial liberalization, treated as exogenous, according to a set of indices constructed by Kaminsky and Schmukler (2008) for the period 1973-2005, a range of dates which closely encompasses the great era of financial liberalization in both advanced and emerging economies. The index used here is the standardized sum of three measures of the domestic financial sector, the stock market, and the capital account. The figure clearly shows that in the 5 years after a financial liberalization event, changes in credit to GDP, which were on a positive long-run postwar trend anyway, had a tendency to accelerate even more rapidly….”
“…Illustrative evidence on trends around financial crises are shown in Figure 8 for the JST long panel. Using an event-study approach, the average evolution of each variable is plotted relative to the peak year of the cycle. Averages are displayed separately for normal recessions (solid blue line) and financial crisis recessions (dashed red line). The first row of four charts shows the familiar timing of events and macro aggregates. Crisis probability is of course high in the ±2 year window around a financial crisis recession, by construction, given the JST peak classification; it is negligible in normal recessions, although it is not exactly zero except in year zero, since nearby financial crisis events may be associated with a different nearby cyclical peak in JST. Real GDP per capita growth decelerates after a recession peak, but much more so in a financial crisis recession as expected. Likewise, a recession is associated with the onset of a disinflationary period of several years, but the trend is much more pronounced in a financial crisis recession. Finally, the fourth chart shows that financial crisis recession peaks are preceded by credit booms and followed by credit crunches much more so than normal recessions. The second row of charts in Figure 8 shows some interesting financial market covariates using selected asset prices. The first chart shows the Krishnamurthy and Muir (2017) normalized credit spread, which is the percent difference of the credit spread from its country mean (so 0% means the spread is equal to this average), and clearly spreads are tighter than average (50% lower) before a financial crisis recession peak, and much wider immediately after (50%-100% higher), compared to the minimal variation seen in normal recession events. The next chart shows the Baron and Xiong (2017) real total return on bank equities, which is a little high before a normal recession peak and indistinguishable from zero after; but near a financial crisis recession peak, bank equities experience a very large run up before, and a large crash afterwards, with significant negative real returns (note that these are log×100 units). Finally, we can see that distress clearly spills over into broader aggregate asset prices, where the onset of a financial crisis recession event similarly implies much larger and predictable reversals for investors exposed to the stock market or housing market, as shown in the last two charts….”