Our banks are too big to fail, too few to be competitive

Today every single one of these entities has disappeared as a genuinely independent concern, wholly or partly acquired by the majors (with competition concerns waived by the ACCC), or merged with one another.

Before the crisis, Australia’s banks were not explicitly government-backed. And taxpayers had never guaranteed bank deposits before (or conceived of providing such guarantees for free as they currently do), nor had they ever guaranteed the banks’ institutional debts.

The taxpayer-owned central bank, the Reserve Bank of Australia, had also never lent to the banks on the much longer-dated and more flexible terms that it offered as the financial markets meltdown started to gather momentum, and continues to offer to this day.

The reason taxpayers had not got into the business of bailing out private banks was because of a well-founded fear of “moral hazard”. That’s the concern that once you start insuring away a private company’s risk of failure, you remove the critical disciplining influence of free markets. And executives will, over time, start behaving less responsibly, and expose taxpayers to even greater risk of loss.

Banks have nevertheless always been different to private companies because they perform a vital social function: they take our short-term savings and transform them into long-term loans. They run this constant “mismatch” between the term of the funding they receive from depositors (eg: mums and dads) and the length of the loans they give to businesses and households.

As a result, banks have always risked insolvency if their funders rapidly withdraw their money. In the 1890s, before the RBA existed, most of Australia’s private banks failed. That’s why we now have a public “central bank” that lends directly to the private banks. And it’s the reason we have a banking regulator, APRA, to ensure that the banks hold enough “capital” to cover liquidity shocks.

We were compelled to write this op-ed because we’re convinced that the policymaking surrounding Australia’s banking system has been predicated on a flawed and risky paradigm: the frequently referenced — by APRA and the RBA — trade-off between “competition” and “financial stability”, which ends up favouring a more concentrated industry.

Today Australia’s prosperity relies on four colossal banks — or “oligopolists” — worth about $50 billion each. They control 80-90% of all financial transactions executed across the country. Importantly, the introduction of government guarantees for the first time during the GFC bequeathed them with a unique comparative advantage.

In contrast to their smaller rivals, the four majors are now regarded by credit rating agencies and investors alike as “too big to fail”. The majors get the benefit of credit ratings that have been explicitly lifted “two notches” higher than they would otherwise be because Standard & Poor’s thinks they alone can depend on “extraordinary government support” in a crisis.

This helps them raise money much more cheaply than their smaller peers, which in turn means it is almost impossible to compete effectively against them. Size thus begets more size.

Some recent advertising campaigns have claimed that “the banks are at war for your home loan”. Both the new head of the ACCC, Rod Sims, and we disagree. A few weeks ago Sims concluded:

“Normally four players in a market should lead to a lot of competitive activity. In the banking sector it seems to need more because even though there are four of them there is a lack of full and effective competition.”

While they rank among the 30 largest banks in the world, Australian policymakers have worked surprisingly hard to have the four majors excluded from the extra capital charges that global regulators are sensibly insisting the biggest, and most “systematically important”, banks hold.

For several years we’ve suggested this is misguided and symptomatic of a worrying oligarchy between Australian banks and their policymakers. Last month the IMF agreed with us, arguing that Australia’s major banks should, in fact, be forced to hold extra capital as systematically important institutions. More capital means less leverage and less taxpayer risk. So why exempt the majors, particularly when they have designs on higher-risk growth strategies overseas?

An additional capital buffer for systematically important banks would also be an intelligent disincentive to becoming too big to fail. And it recognises a point we’ve made for some time: in many ways the catastrophic risks posed by smaller and simpler banks, like Bendigo & Adelaide, Bank of Queensland, and Members Equity, are a fraction of those threatened by the majors.

In all properly functioning financial markets there is an inexorable trade-off between risk and return. The higher the risks you take, the higher the returns you generate. But in Australia this maxim has been turned on its head: in Australia, the supposedly lowest risks banks with the highest credit ratings — the majors — are somehow able to yield the highest shareholder returns. In contrast, the smallest banks, with the lowest credit ratings, produce much lower returns on equity. This complete reversal of the inverse relation between risk and return is the purest possible illustration that taxpayer subsidies are being used for the benefit of the banking oligarchy to the detriment of meritocratic democracy.

During the GFC, most of the smaller banks did not use the taxpayer guarantees of wholesale debts because the premium paid for the guarantee was, ironically, based on the banks’ credit ratings. This made it cheapest for the major banks to use the government’s insurance, which they did in vast volumes. It was peculiar that Treasury decided to price its insurance using the same rating agencies that had missed so many of the moral hazards that triggered the crisis in the first place.

A more subtle example of how the system encourages extreme size is the terms on which the banks borrow from the RBA. When doing so, banks have to pledge an asset as collateral to get RBA funding. Included in the list of “eligible” assets the RBA will accept as collateral is any senior debt issued by an Australian bank. But historically that debt had to have a credit rating — yes, there it is again — of A- or higher, which excluded the debts issued by smaller regional banks and building societies. Since the major banks were among the few that qualified for the RBA’s funding, this helped further support investor demand for their bonds, and thus lowered their cost. While this month the RBA cut the minimum rating to BBB+, this still excludes several smaller banks and building societies.

*This article was first published at Property Observer