Walker Todd is an adjunct scholar at the Cato Institute’s new Center for Monetary Financial Alternatives, and an Institute grantee. He is also an economic consultant with 20 years’ experience at the Federal Reserve Bank of New York and the Federal Reseve Bank of Cleveland. So to say he has a broad historic view of today’s global financial conditions would be an understatement. In Todd’s view, an opportunity to restructure the banking system along less dangerously systemic lines was lost when Dodd-Frank was adopted. One of the biggest flaws, in Todd’s view, was the reluctance to stress test the banks properly and “get real” as far as the underlying value of their assets were concerned.
In Todd’s view, we got a very bank-friendly bailout which resolved nothing, and in the interview he contrasts this to the period during the Great Depression, when we seemed to know better. The original stress test was developed during the bank holiday, March 4-12, 1933. It is described in Jones (1951, pp. 22-23, 27-30). Jesse Jones already was a director of the RFC and became its head with the coming of the Roosevelt Administration.
During the bank holiday, the RFC and other federal and state bank examining authorities simultaneously examined the nation’s banks and divided them into three categories, A, B, and C. A banks were considered sound; B banks had lost most of their capital but still could pay off depositors in full; C banks had lost all their capital and also could not pay depositors in full at fair market value. A banks were reopened promptly; B banks were reopened as soon as they either raised new capital or made deals with the RFC; C banks were placed into conservatorship to be dealt with later. Banks in conservatorship, however, were allowed to receive new deposits as long as they were segregated from old deposits (Todd, 1993 and 2008).
Asset valuations were at fair market value. It was not until 1938 that the Federal Reserve forced the other regulators to accede to historic cost accounting for banks’ assets. The 1938 examination and accounting change was made to encourage new lending and to enable private investors to acquire failed banks’ assets from the federal authorities without immediate writedowns of their value .
By the end of the bank holiday week, the RFC’s directors decided to pursue a policy of making loans (buying preferred stock with convertible warrants) in banks whose assets “appeared to equal 90 percent of their total deposits and other liabilities exclusive of capital” (Jones 1951, pp. 27-28). The RFC’s aim was “to put pressure on the banks’ stockholders and customers and the people in their vicinities to get them interested in putting capital in and owning their own banks” instead of having the RFC own them. Banks failing the 90 percent test were sent to the “hospital” (category C above).
By December 1933, Jones estimated that around 2,000 of the 12,000 remaining banks (there had been 17,000 before the March holiday) were below the RFC’s 90 percent threshold, with average asset values in that pool not quite up to 75 percent. With the tacit approval of the Senate Banking Committee, one of whose members was Carter Glass of Virginia, an original House sponsor of the Federal Reserve Act of 1913, Jones made a bargain with Treasury Secretary Henry Morgenthau.
Jones promised that, if Morgenthau would certify the 2,000 unresolved banks as solvent on January 1, 1934, when the new federal deposit insurance system was to take effect, Jones and the RFC would see to it that the banks in fact would be solvent within six months. Essentially, Jones contemplated making larger loans to those banks, filling in the gaps that remained between the 75 percent and 90 percent valuation thresholds. Over the next six months, the RFC recruited $180 million more of private capital investments in those banks to reduce the valuation gap of up to 15 percent gap that it was financing. The new private investments were subordinated to the RFC’s claims in the capital structures of the banks receiving that assistance (Jones 1951, pp. 28-30).
The upshot was that we had a financial system that was fully cleansed of its rot and the stage was set for a period of comparative financial stability in the decades ahead. Does anybody seriously think that Dodd-Frank achieved anything close that? Listen to Todd and you’ll get the likely answer.