During the third stage, primary dealers place the securities newly issued by the US Treasury with an investor, a bank or one of its customers (stage 3 of Figure 1). The placing of securities generates a cash transfer from the purchasing bank’s current account with the Fed to the BONY account. The BONY reserves with the Fed, as well as primary dealers’ holdings with BONY, are reconstituted.
CHANGE ON THE LIABILITY SIDE OF THE FED’S BALANCE SHEET
As we will see later, depending on the type of resources used by the end owner to purchase the newly issued securities, the reduction in the Fed’s balance sheet will ultimately be recorded on the liability side of the Fed’s balance sheet either through the destruction of bank reserves, or by a fall in outstanding amounts from the Fed’s reverse repurchase agreements[12], or by a combination of the two (Chart 9).
IMPACT ON BALANCE SHEETS OF NOT REINVESTING TREASURIES: A COMMERCIAL BANK UNDERWRITES THE NEW US TREASURY ISSUE ON ITS OWN ACCOUNT
IMPACT ON BALANCE SHEETS OF NOT REINVESTING TREASURIES A NON-BANKING INVESTOR SUBSCRIBES FOR THE NEW US TREASURY ISSUE BY DRAWING ON ITS DEPOSITS
IMPACT ON BALANCE SHEETS OF NOT REINVESTING TREASURIES A MONEY MARKET FUND SUBSCRIBES FOR THE NEW US TREASURY ISSUE AND REDUCES ITS REVERSE REPOS WITH THE FED
Subscription for securities by a bank
When a commercial bank subscribes for the US Treasury issue for itself, then a simple change to its holdings (securities against reserves) occurs, with no effect on the size of its balance sheet (stage 3 of Figure 1). The Fed’s balance sheet shrinks through a simultaneous reduction in its securities portfolio (on the assets side) and in banks’ reserves (on the liabilities side).
In practice, it seems unlikely that banks will expand their Treasuries portfolios further. The previous increase in their exposure and the uncertainty about the draining speed on reserves, viewed as the most liquid assets in a regulatory sense (cf. below), are the main obstacles. In addition, the unrealised losses recorded on banks’ bond portfolios, following the rise in long-term interest rates, are decreasing CET1 common equity ratios and are disincentivising securities purchases (40% of US G-SIB Treasuries portfolios were recorded at their market value in the “Available for Sale” category during Q3 2022).
Subscription for securities by a resident non-bank agent
When a resident non-monetary investor (household, hedge fund, pension fund or investment fund) subscribes for a security issue by drawing on its deposits, the commercial bank also makes a transfer from its current account with the Fed to the BONY current account and debits the same amount from its customer’s deposit account[13] (Figure 2). In this case, as a result of the debt repayment no longer being fully reinvested, reserves with the Fed are destroyed, the size of the commercial bank’s balance sheet decreases and broad money is destroyed (decrease in customer deposits).[14]
Therefore, while the purchase of assets by a central bank from non-banking agents (QE) results in the “monetisation “ of long-term debt securities, and therefore in the creation of broad money (customer deposits), QT leads to the “demonetisation” of securities[15] and the destruction of money when other non-banking agents take the central bank’s place and purchase the newly issued securities. In this case in point, QT destroys some of the deposits created by QE (Choulet, 2021a; Box 1).
Subscription for securities by a money market fund
THE IMPACT OF QT2 ON MONEY SUPPLYDepending on the resources available to it, a money market fund mainly shifts between holding T-bills and offering secured loans (reverse repurchase agreements) to other financial institutions, such as banks, broker-dealers, hedge funds or the Fed (under the Overnight Reverse Repo Facility, ON RRP)[16].
As we will see, since March 2021, the hierarchy of yields has led money market funds (MMFs) to increase their participation in Fed reverse repos significantly, moving away from T-bills and reverse repos with private counterparties.
Assuming that the yields offered by US Treasury securities are more than the interest from the ON RRP facility, MMFs may choose to reallocate some of the cash deposited with the Fed to the T-bills.
In this scenario, the Fed would record a reduction in its repo borrowings (on its liabilities, Figure 3). In return, it would credit the current account of the intermediary bank (custodian bank), which in turn would credit the money market fund’s deposit account[17]. The assets of the bank (reserves) and the money market fund (deposits) would temporarily increase. The subscription of the securities by the money market fund would result in a decrease in the fund’s deposits and a transfer from the intermediary bank’s account to the BONY account with the Fed. The size and composition of the intermediary bank’s balance sheet would ultimately remain unchanged.
In this case, the reduction in the Fed’s balance sheet would solely be due to a reduction in its repo borrowings from money market funds.
Subscription for securities by non-resident investors
Non-resident investors in US Treasury securities mainly include central banks and financial institutions, such as hedge funds, insurance companies, pension funds and investment funds. With given resources, non-resident agents may, in the same way as resident agents, increase their exposure to Treasuries by drawing on their deposits, by withdrawing from other investments or, for foreign central banks specifically, by reducing their cash "deposits” with the Fed (under the FIMA Reverse Repo Pool, FRRP). The effects would be identical to the effects set out in Figure 2, in the first two cases, and to the effects set out in Figure 3, in the third case.
The impact of QT will depend in particular on the profile of net issues of US Treasury debt securities by maturity, on yield differentials between securities and Fed reverse repos with money market funds and foreign central banks, and even on the spread between yields on money market fund shares and bank deposit rates for households.
“Bumpy” QT: the risk of a shortage in central bank money
As previously mentioned, the reduction in the Fed’s balance sheet will automatically destroy some of the reserves created during the quantitative easing programme. However, for this reason, the first round of Fed quantitative tightening (QT1), which began in October 2017, had to be curtailed after just 22 months, far earlier than the Fed had planned[18]. It had exhausted the stock of "excess" reserves held by banks beyond their liquid asset needs[19], preventing them from meeting demands for cash on the money markets. In September 2019, the money markers seized up, meaning that cash overnight borrowing rates on the repo markets hit record levels and the Effective Fed Funds Rate rose to outside of the FOMC target range for the first time. In order to ease these pressures, the Fed injected emergency liquidity through repurchase agreements and reactivated its outright asset purchase programme (Choulet, 2019; Afonso, Cipriani, Copeland, Kovner, La Spada, Martin, 2021; Copeland, Duffie and Yang, 2021).
A comfortable liquidity position at first glance
Banks’ central bank money needs are driven by a range of constraints. Reserves are first and foremost a way of settling payments on the interbank market.
Since the Liquidity Coverage Ratio (LCR) was introduced in 2015, banks have also had to hold reserves (or, more generally, High-Quality Liquid Assets, HQLA) to cover the net cash outflows over 30 days that would be triggered by a severe liquidity crisis (based on notional outflow or non-renewal rates, as set by the regulator). The regulatory requirements around central bank money for the very large American banks are all the more extensive, as the regulator has required them, on the one hand, since 2013, as part of the resolution plans, to cover their theoretical net cash outflows on an intra-day basis, rather than a daily basis, and, on the other hand, since 2014, to be subject to liquidity stress tests over various horizons (overnight, 30 days, 90 days and 1 year).
However, these regulatory requirements can only be met through large holdings with the central bank. The internal management of liquidity risk, delays between large dealers’ incoming credit and outgoing debit payments, and shallow money markets at the end of the day also affect demand for reserves (Copeland, Duffie and Yang, 2021; Afonso, Duffie, Rigon and Shin, 2022).
Given the large liquidity pool available to banks, the Fed’s ambition to maintain an "ample” reserve supply and the facilities introduced by the US central bank in order to prevent any shortfall in reserves, the risk of shortage seems small for the time being.
A large liquidity pool
DAILY FED REVERSE REPO (RRP) VOLUMES WITH BANKS, GSES AND MONEY MARKET FUNDSThe current stock of reserves with the Fed (around USD3 trillion in mid-December 2022, compared to USD1.38 trillion when the repo market crisis occurred in September 2019) is actually a large liquidity pool that will be able to absorb the quantitative tightening shock.
In addition, the size of the Fed’s reverse repos (ON RRP facility) confirms that there is abundant cash available: since mid-June 2022, money market funds have deposited almost USD 2.2 trillion in the Fed every day (45% of their total assets) as there is no more profitable investment on the market[20] (Chart11).
REALLOCATION OF MONEY MARKET FUND PORTFOLIOSThe increased importance of this facility has, in fact, and in line with the Fed’s objective[21], largely led to MMF holdings being reallocated (away from securities portfolios and repo loans to private counterparties), rather than their resources being increased[22] (Chart12). Since the hike in key rates on 3 November 2022, the ON RRP facility’s yield has become slightly less appealing[23] and MMF cash "deposits" with the Fed have decreased somewhat. Yet, rebalancing their portfolios would cushion the effect of QT on banks’ reserves with the Fed, delaying the risk of a central bank money shortage[24].
In particular, MMFs could expand their agency debt security portfolios again. As a matter of fact, the slowdown in customer deposit growth (Box 1) is prompting banks to seek financing from Federal Home Loan Banks (FHLBs), which have been issuing more debt securities in recent months.
As the Treasury announced T-bill net issues would resume, MMFs could also re-allocate their holdings to US Treasury securities (Figure 3). Finally, primary dealers could request further financing from MMFs in order to lend on foreign-exchange swap markets or on repo markets or, if there is not enough appetite among investors for the long-term securities issued, in order to finance the increase in their long (buy) positions. Other financial organisations, such as hedge funds, could also finance their Treasuries purchases by borrowing from money market funds or dealers, even if price volatility is dampening their appetite (Box 2). Additional demand for secured loans would push repo rates upwards and reduce the relative attractiveness of the ON RRP facility for money market funds. Just as the Fed drained the excess liquidity created during QE (and prevented downward pressure on money market rates), it could resupply the repo markets with liquidities, by lowering the authorised transaction ceiling or reducing the interest rate for the ON RRP facility.
Assuming the extreme hypothesis that MMF cash “deposits” with the Fed are completely exhausted, the theoretical worth of central bank money which could offset the effect of reducing the Fed’s balance sheet could amount to USD 5.36 trillion (combined total of banks’ reserves and MMFs deposits with the Fed as at 14 December 2022), compared to USD 1.38 trillion three years earlier.
THE EFFECTS OF REALLOCATING CASH DEPOSITED WITH THE FED BY MMFS TO PRIVATE REPO MARKETS
IMPACT ON BALANCE SHEETS OF NOT REINVESTING TREASURIES A HEDGE FUND UNDERWRITES THE NEW US TREASURY ISSUE BY BORROWING FROM A MONEY MARKET FUND
Maintaining an "ample” reserves system: a new monetary policy ambition
After being left reeling by the unexpected repo market crisis during QT1 (Pozsar, 2018; Choulet, 2018), the Fed intends to manage the reduction in the size of its balance sheet better[25]. This involves destroying some of the reserves created during QE4, all while maintaining a sufficiently "ample” reserve supply, i.e. large enough to eliminate any stress risk that would require it to inject central bank liquidity urgently.
However, it is still a challenge, even for banking regulators, to estimate the optimal amount of reserves (neither too little nor too much) required for the money markets to operate smoothly. The Federal Reserve Bank of New York monitors two indicators that can assess whether there are too few or too many reserves. According to these two indicators, the current stocks of reserves with the Fed could, for the time being, be described as “ample”.
In its latest monetary policy operations report published in May 2022 (FRBNY, 2022), the Federal Reserve Bank of New York (FRBNY) characterises an “ample” reserves system as one with a reserve-to-GDP ratio above the level recorded in December 2019 (8%). With an average of USD 2.96 trillion in reserves during the final week of September 2022 and a reserve-to-GDP ratio of 12%, based on this indicator, the Fed would have room for manoeuvre in order to reduce the size of its balance sheet (on that date, the reserve stock was above the 960 billion threshold that acts as the boundary between sufficient and insufficient reserves).
By making a number of conservative assumptions about the likely changes in other liabilities on the Fed’s balance sheet, and by using the median of primary dealers’ macroeconomic assumptions, the FRBNY believed that, in order to avoid a shortage in reserves, the reduction in the Fed’s balance sheet should be curtailed by mid-2025[26]. By that time, the Fed’s balance sheet should be around USD 5.9 trillion (22% of GDP) and reserves should be around 2.3 trillion (9% of GDP). At the end of a year in which the Fed’s balance sheet size is expected to remain unchanged, the asset purchase programme would be reactivated in order to keep the reserve stock at 8% of GDP. Assuming both the value of the Fed’s securities portfolio and the value of reserves grow at the same rate as GDP by 2030, at the end of the forecast horizon, the Fed’s balance sheet would stand at USD 7.2 trillion and reserves would stand at 2.7 trillion (i.e. 1.43 trillion and 470 billion less respectively than on 14 December 2022).
In support of the simulations of the reserve demand curve, Afonso, Giannone, La Spada and Williams (2022) estimated that, based on data covering the period from 1 January 2009 to 29 March 2021, the new liquidity requirements gradually introduced following the major financial crisis and the new tools for controlling short-term money market rates[27] shifted this boundary between abundant and scarce reserves.
As a result, if, between 2010 and 2014, a reserve-to-bank-asset ratio of more than 8% was sufficient to be classified as an “ample” reserves situation, then, between 2015 and 2020, this same threshold stood at 11%. Therefore, standing at 13% on 30 November 2022, the reserve-to-bank-asset ratio still looked comfortable (even though the additional reserves only stood at USD 530 billion at this time). Developments beyond the forecast horizon for their study (a second increase in the ON RRP transactions ceiling in September 2021, and the zero or slightly positive gap between the ON RRP rate and the SOFR since June 2021) could pushed the threshold upwards, however[28].
A facility for injecting reserves should there be pressures
With the creation of the Standing Repo Facility (SRF), the Fed also has a new tool for detecting and preventing potential shortages in central bank money (Choulet, 2021b). The facility mirrors the ON RRP facility[29]. All other things being equal, it increases reserves with the central bank and enlarges banks’ (and the Fed's) balance sheets. It enables banks with central bank liquidity needs to temporarily “monetise” securities and aims to eliminate the risk of a comparable incident to the one that occurred in September 2019.
Challenges with assessing central bank money needs
However, caution is still needed. The most recent round of QE did not improve the liquidity coverage ratios (LCRs). Instead, just like QT1, QT2 could negatively affect these ratios. Furthermore, QE4 changed the structure of banks’ balance sheets in such a way that the thresholds reached during the September 2019 repo crisis (level of reserves, reserve-to-GDP ratios and reserve-to-bank-asset ratios) could become less relevant. Finally, the SRF has a number of shortcomings that could make it less effective should there be pressures.
QT2 could negatively affect liquidity coverage ratios
AVERAGE LCR RATIO OF THE 8 US G-SIBSDue to the confidential nature of some information, such as the liquidity risk management in resolution plans or the results of liquidity stress tests, detailed analysis of central bank money needs cannot take place.
In view of the short-term Liquidity Coverage Ratio (LCR) requirement under Basel III, which is less crucial but the only one observable, the (immediately available) liquidity position for the eight largest American banks (JP Morgan, Bank of America, Citigroup, Wells Fargo, Goldman Sachs, Morgan Stanley, BONY and State Street) improved during the third quarter of 2022.
The theoretical net cash outflows (the denominator in the ratios) contracted more sharply than the value of the liquid-asset portfolios[30] (the numerator in the ratios). Therefore, the average LCR of the 8 G-SIBs increased over the quarter. Standing at 119.2% during Q3 2022 (compared to 116.3% during Q22022), this ratio was greater than the prudential requirements (100%) and the level recommended by the Fed (115%). However, it was only 100 bp higher than at the time of the repo market crisis (Q3 2019). Yet, even though QE4 did not improve the LCRs of the big American banks[31], QT1 gradually negatively impacted these ratios (Chart 13).
Increased exposure to liquidity risks?
Contradicting the position of most economists (Copeland, Duffie and Yang (2021), Afonso, Cipriani, Copeland, Kovner, La Spada and Martin (2021)), who argue in favour of maintaining a sufficiently abundant level of reserves, Acharya, Chauhan, Rajan and Steffen (2022), by contrast, believe that repeated injections of central bank money create a moral hazard and could alone fuel potential liquidity pressures on money markets liquidity.
They claim that, during the various rounds of QE, banks, which felt confident about the abundant stock of central bank liquidity available, increased the liquidity service that they provided to their customers (by increasing customer demand deposits in their liabilities and lines of credit to corporations in their off-balance sheets). However, the reduction in banks’ holdings with the Fed, caused by QT1, did not lead to an equivalent reduction in banks’ demandable liabilities, which, according to them, would have caused the pressure seen on the repo markets in September 2019, and then on the Treasuries market in March 2020, to happen earlier.
The liquidity "available” should there be market pressures is thought to be much lower than suggested by the banks’ stocks of reserves with central bank, as, according to the authors, these banks willingly increased their commitments to provide cash to their customers. They conclude that if there is not a sharp reduction in demandable claims on the banking sector, QT2 risks exposing the financial system to further pressure, which will force the Fed to inject further central bank liquidities and increase banks’ dependence on the Fed.
CHANGE ON THE ASSET SIDE OF BANKS’ BALANCE SHEETOf course, banking activity, in its most traditional forms (granting loans and collecting deposits), exposes banks to maturity transformation and liquidity risks, in particular. The introduction of new liquidity regulatory requirements in the wake of the 2008 great financial crisis aimed to reduce these risks and improve banks' abilities to absorb shocks. Even though, as the authors point out, these regulations have increased liquid-asset requirements (as reserves with the central bank), they have also prompted banks to rely more heavily on deposits, particularly from retail customers, which are rightly viewed as more stable than market financing. In addition, the high weighting of deposits in the liabilities of bank balance sheets is, in practice, closely linked to monetary policy measures.
During the various rounds of QE, the Fed’s securities purchases automatically increased the total stock of deposits in the economy (newly created money), while the drop in rates reduced the convenience cost of holding liquid savings with little or no interest paid on them (such as demand deposits). In 2020 and 2021, support packages for American businesses (PPP guaranteed loans) and households (stimulus checks), financed by US Treasury holdings with the Fed and increasing deficits (partly "absorbed” by the Fed as part of QE), boosted growth in deposits.
CHANGE ON THE LIABILITY SIDE OF BANKS’ BALANCE SHEETOf course, periods of monetary tightening should prompt customers to shift towards longer and more profitable investments, while quantitative tightening should automatically destroy some of the money created during QE. However, during QT1, the economic climate was suitable for resuming lending (the traditional channel of money creation), meaning that the weighting of deposits on bank balance sheets fell only slightly. Customer deposits currently account for more than 65% of bank liabilities in the United States, which is beneficial during a period where the cost of market resources is increasing.
This study by Acharya, Chauhan, Rajan and Steffen (2022), however, highlights that the distortion of bank balance sheets (Charts 14 and 15), caused by successive rounds of QE, has probably altered banks’ demands for central bank money. Bank balance sheets have clearly been amended to accommodate the likely fall in reserves and customer deposits for a few months now. Banks’ use of secured borrowings (advances) and unsecured loans (federal funds) with GSEs has increased since the start of 2022. FHLBs’ current accounts and the interest on them have also grown.
The SRF’s limitations
Banks are still not greatly involved with the Fed’s SRF. By mid-December 2022, the list of the Fed’s SRF counterparties contained 17 depository institutions, which are subsidiaries of very large American banks or branches of large foreign banks. There are some limitations to the facility (Choulet, 2021b). The first pitfall is that borrowings from the Fed cannot be centrally cleared (cf. infra).
As we approach the closing of accounts, the liquidity offered by the Fed through the SRF may therefore be inaccessible to primary dealers or depository institutions experiencing the most stringent constraints under their leverage requirements.
Even in 2019, on their own, the Fed’s interventions were not able to ease the pressures that had arisen. Beyond the USD 256 billion of liquidity “borrowed” from the Fed, as part of its repo transactions on 31 December 2019, dealers had partially refinanced their inventories of securities through repo loans from MMFs, which were cleared via the Fixed Income Clearing Corporation (FICC, a subsidiary of the Depository Trust & Clearing Corporation) at USD 276 billion (cf. infra).
In March 2020, faced with rapidly deteriorating financial conditions, the Fed significantly increased the ceiling for its repo transactions. However, demand from primary dealers remained low when compared against the Fed’s liquidity supply, and only the promise of "unlimited” outright security purchases, followed by the removal of reserves and Treasuries from the leverage ratio calculation[32] (see infra), helped to stabilise the markets and lower the Treasuries yield (Eisenbach and Phelan, 2022). The second pitfall of the SRF is the risk of stigmatisation associated with using it.
“Bumpy” QT: the risk of intermediation conditions for Treasuries markets deteriorating
Traditionally viewed as the deepest and most secure market, the Treasuries market has experienced episodes of severe pressure over the past decade[33]. The liquidity of the cash market (where securities are traded) has declined since the start of 2022. Against the backdrop of monetary tightening and fears of a recession, the strengthening of the dollar and the high yield volatility are putting off investors, irrespective of whether they are from the United States or abroad. This climate makes the Fed’s task of reducing its portfolio more complicated. Given the size of the debt to be financed (USD 24 trillion of marketable debt), the prudential constraints limiting the capacity for intermediation by primary dealers are an aggravating factor. (Duffie, 2020 ; FSB, 2022).
Reduced appetite among non-residents
After flagging over the past few years, non-residents’ interest in Treasuries has declined due to the sharp increase in the cost of currency hedging since the start of 2022. The terminal federal funds rate will have to be reached for Treasury yields net of hedging costs to become attractive to non-residents again. Even though it has been designed to provide foreign central banks that do not have swap lines with the Fed with access to dollars, the FIMA repo facility has only slightly encouraged central banks to expand their Treasuries portfolios.
Non-residents: the main creditors of the US federal government
BREAKDOWN OF TREASURIES BY HOLDER SECTORNon-residents are the main holders of US Treasury securities. Their (valued) holdings stood at almost USD 7.3 trillion at the end of September 2022, which equates to 31% of US marketable federal debt (29% of the total stock of Treasuries). By way of comparison, the Fed held 22% of the marketable outstanding, while other resident financial sectors held 37% (pension funds 14%, banks 7%, mutual funds 7% and money market funds 5%, Chart16).
NET PURCHASES OF TREASURIESHowever, the attractiveness of US Treasuries to foreign investors has been in decline for many years now[34]. Even though the value of their portfolios, which are mainly made up of long-term securities, has grown over the past 20 years (buoyed by valuation effects), the weighting of their holdings in the total US federal debt has been falling since the end of 2008 (they then held 57% of the stock of marketable Treasuries and 43% of the total outstanding). Their net purchases of Treasuries have decreased (in particular between 2015 and 2020), both in terms of volume and in proportion to net issues of US Treasury securities[35] (Chart 17).
Non-resident official investors are reducing their exposure
US TREASURY HOLDINGS BY THE REST OF THE WORLDThe drop in the proportion of non-residents among Treasuries investors is solely due to the official sector (central banks, governments, sovereign funds, international organisations, development banks and public financial bodies). After having gradually grown over a number of years, the value of their portfolios has remained broadly stable since March 2013 (USD 3.903 trillion at the end of June 2022, of which 77% were held in custody by the Fed, Chart 18).
However, it fell sharply in proportion to the stock of marketable Treasuries (17% in June 2022, compared to 42% at the end of 2008, Chart 19). Central banks and foreign governments have to some extent turned away from Treasuries, and more generally from the US dollar, in an effort to diversify their foreign exchange reserves[36].
THE DECLINE IN THE WEIGHT OF FOREIGN OFFICIAL INVESTORS AMONG HOLDERS OF TREASURIESConversely, Treasuries holdings by the non-resident private sector (insurance companies, pension funds and hedge funds), have increased in value over the past fifteen years (buoyed by net purchases and valuation effects standing at USD 3.528 trillion at the end of June 2022), all while accounting for a relatively stable proportion of the total Treasuries outstanding (15% compared to 14% respectively, Chart 19).
Therefore, while the official sector was the US Treasury’s primary foreign counterparty in 2008 (74%), in June 2022, it held only 53% of the federal debt held abroad (26% and 47% respectively for the non-resident private sector) [37]. However, as private investors generally have a shorter investment horizon than official investors, their growing weighting could lead to greater interest rate volatility.
The reduction in non-residents’ exposure to the US Treasury (in proportion to the stock of Treasuries) is entirely due to Asia, with Japan and China accounting for the biggest reductions. However, Japan (USD 1.12 trillion in September 2022) and China (USD 933 billion), all agent types included (both official and unofficial, financial and non-financial), are still the two largest creditor economies for the US federal government, far ahead of the UK (663 billion) and Belgium (325 billion)[38]. At the end of June 2022, 49% of US Treasury securities owned by foreign agents were held in Asia, with 34% held in Europe (18% were held in the eurozone), 10% in North America and 5% in South America.
Just like the SRF, the FIMA repo does not appear to have generated strong support or an incentive to increase exposure to Treasuries
US TREASURY HOLDINGS OF FOREIGN COUNTRIESIn order to provide access to dollar liquidity with a greater scope than swap lines alone[39], the Fed introduced a new facility on 31 March 2020[40]. It was first introduced temporarily and was eventually made permanent on 28 July 2021. It enables foreign central banks and international monetary authorities with a FIMA account with the Federal Reserve Bank of New York (FRBNY) to place their portfolios of Treasuries into repurchase agreements with the Fed.
This easy access to dollar liquidity for many countries (in particular, emerging markets), with no bilateral swap agreements with the Fed, aims to eliminate, should there be stresses, the risk of their Treasuries portfolios being sold at low prices[41] or of their repo borrowing with dealers, particularly American dealers, enlarging. The facility therefore aims to stabilise both the Treasuries and repo market, by freeing up space on dealers’ balance sheets to allow financing of hedge funds and asset managers[42].
The authorised transaction volumes are determined bilaterally between the Fed and the central bank of the relevant country or, failing that, capped by the volume of Treasuries held with the FRBNY. Therefore, this facility indirectly aims to encourage emerging economies to expand their portfolios in order to enhance their drawdown potential if necessary.
The Fed does not provide an exhaustive list of central banks that have obtained access to the FIMA repo facility. However, some central banks provided this information: the central banks of Indonesia (08/04/2020), Colombia (20/04/2020), Hong Kong (22/04/2020), Chile (24/06/2020) and Peru (17/07/2020). The central banks of Sweden (20/12/2021) and South Korea (23/12/2021), which are among the nine central banks that were able to access temporary swap lines in 2008 and 2020, also signed repurchase agreements with the Fed.
We have aggregated the value of the Treasuries portfolios for countries that are home to the five central banks which have permanent swap lines with the Fed (hereafter referred to as “PSL countries”), the nine central banks which have temporary swap lines with the Fed ("TSL countries") and the five central banks which do not have swap agreements with the Fed but do have access to the repo facility ("FIMA countries")[43].
ONLY SOME COUNTRIES WITH ACCESS TO THE FIMA REPO HAVE EXPANDED THEIR TREASURY PORTFOLIOSOn an aggregated level, these three groups of countries have seemingly increased their holdings over the last ten years (between +25% and +70%, Chart 20), while the value of portfolios for countries that do not have any agreement with the Fed has only risen slightly (+3%). In March 2020, during the COVID-19 shock, all groups of countries reduced their Treasuries holdings (the valuation effect was also able to play a role), but this reduction was more moderate for PSL countries, however (Goldberg and Ravazzolo, 2022). Subsequently, despite obtaining access to the FIMA repo, the value of the portfolios for “FIMA countries” continued to shrink. However, these aggregations conceal major disparities[44].
Since the FIMA repo was put in place, South American countries (Chile, Colombia and Peru), which have had no limit placed on their potential repurchase agreements with the Fed, have, according to the information available, significantly expanded their portfolios (+24% between December 2019 and September 2022, Chart 21), while Asian countries (Hong Kong and Indonesia), whose access to the FIMA repo is capped (USD 10 billion and USD 60 billion, respectively), have reduced them (-30%).
Limited balance-sheet space for primary dealers
The reduction in the Fed’s Treasuries portfolio will make the US Treasury much more reliant on markets for funding. However, the Basel 3 agreements have reduced primary dealers’ market-maker capabilities on the Treasuries (cash and repo) markets, whether for intermediating the purchase or sale of securities by their counterparties on the secondary cash markets, for warehousing securities which do not find any underwriters onto their balance sheets (as part of outright sales or repurchase agreements), or even for facilitating the circulation of cash and collateral on the repo markets. Two regulatory adjustments (the easing of the SLR leverage constraint and the more common usage of centralised clearing on Treasuries markets) are under consideration. These two adjustments could significantly help to alleviate banks’ capital requirements and should mitigate the risk of the balance sheet constraint exacerbating the stress that may arise should there be an external shock[45] (Chen, Liu, Rubio, Sarkar and Song, 2021).
Reduced market-intermediation abilities
PRIMARY DEALERS’ NET POSITIONS IN TREASURIES AND INTEREST RATE SPREADSMarket-making involves entering a large inventory of securities and many repurchase and reverse repurchase agreements onto market makers’ balance sheets. However, Basel 3 significantly increased the capital requirement linked to the size of bank balance sheets (in particular through the SLR leverage standard[46]).
As a result, it increased the balance sheet cost associated with primary dealer activity, even while the federal government’s financing needs were growing. This not only changed their position, but also significantly affected yields on the financial markets on which primary dealers trade (Duffie, 2020; Jermann, 2020; Du, Hébert and Li, 2022; Du, Hébert and Huber, 2022; Favara, Infante and Rezende, 2022; He, Nagel and Song, 2022). As a result, while they favoured Treasuries borrowings (short net positions) until 2008, primary dealers have since become Treasuries holders (long net positions, Chart 22) [47].
PRIMARY DEALERS’ OVERALL EXPOSURE TO TREASURIESIn addition, the stricter regulations have led primary dealers to choose more unequivocally between market making on the Treasuries market and supplying dollars on the foreign exchange market, and to require higher risk premiums.
The reduced Treasuries absorption capacity among primary dealers would therefore have played a role in denting the "convenience yield" linked to holding an asset viewed as the safest and most liquid, at both a national level[48] (negative swap spreads, even on very long maturities[49]) and an international level (major deviations from the covered interest rate parity)[50]. For many months now, primary dealers’ total exposure to Treasuries has been high (Chart 23).
Yet, as with during QT1, the flattening of the yield curve could result in primary dealer inventories expanding further (compensating for the lack of investor appetite for the securities issued, Chart 22 and Box 3).
THE EFFECTS OF AN EXPANSION IN DEALER INVENTORIES
IMPACT ON BALANCE SHEETS OF NOT REINVESTING TREASURIES PRIMARY DEALERS FINANCE THEIR SECURITIES HOLDINGS WITH MONEY MARKET FUNDS
Relaxing the SLR leverage constraint[51]
The first regulatory amendment that could ease primary dealers’ balance sheet constraints would involve relaxing the SLR leverage standard (Chart 24; Liang and Parkinson, 2020; Favara, Infante and Rezende, 2022).
Fearing that it would hinder banks’ abilities to lend and act as market makers on the Treasuries market while QE4 significantly enlarged bank balance sheets, regulators temporarily eased it during the COVID-19 crisis (Choulet, 2020b).
From 1 April 2020 to 31 March 2021, banks’ reserves with the Federal Reserve and US Treasury securities, irrespective of whether they were pledged as collateral or not, were deducted from the denominator for the leverage ratio for large bank holding companies and their depository institutions. Raised by regulators in March 2021, the issue of a long-term review of the standard has not yet been resolved.
REACTIVATING THE EASING ALLOWED IN 2020 WOULD IMPROVE SLRS BY 90BP ON AVERAGEGiven the size of the Treasuries market and the large amount of reserves required for the money markets to operate smoothly, recalibrating the standard would seemingly be an appropriate step, however. In March 2014, when the US SLR standard was being finalised, the outstanding marketable federal debt was half of its current level. At that time, the Fed was also anticipating the overall stock of reserves to be reduced to just USD 25 billion by the end of 2021 (Quarles, 2021); however, its outstanding stood at almost USD 3 trillion by mid-December 2022 and was overwhelmingly held on the balance sheet of the largest banks, which provide liquidity for the money and Treasuries markets.
According to Eisenbach and Phelan (2022), if there was no QE[52], easing the leverage constraint would stabilise the Treasuries market, provided that this was established as a long-term measure. Otherwise, investors who are not hugely exposed to liquidity risk but fear a future drop in the price of securities would be prompted to sell their assets should there be a shock.
According to these authors, in March 2020, before the “unlimited” QE was announced by the Fed, uncertainty about whether dealers would be able to absorb net sales of securities from investors in need of cash would have prompted some financial institutions, without genuine liquidity needs, to sell their portfolios preemptively, thereby making their expectations self-fulfilling. These authors conclude that the more stringent dealers’ balance sheet constraints are, the more fragile the markets of assets viewed as safe, such as Treasuries, become, due to potential runs on these markets.
Broadening the scope of centralised clearing on Treasuries markets
The second solution would involve broadening the scope of centralised clearing of transactions by primary dealers on secondary (cash and repo) Treasuries markets.
In the United States, just one clearing house (CCP), the Fixed Income Clearing Corporation (FICC, a subsidiary of Depository Trust & Clearing Corporation), acts as the central counterparty on Treasuries markets[53]. Operating based on the novation principle, the FICC takes the legal place of the original seller (or borrower) or buyer (or lender), thereby becoming the buyer for each seller and the seller for each buyer. The trading terms are specified bilaterally during negotiations. Nevertheless, the confirmation of transactions and the delivery-settlement process are delegated to the FICC, which ensures that the transaction is successfully finalised[54].
Through the FICC’s involvement, multilateral clearing of positions (netting) can also occur. For each type of underlying asset given, it calculates the net balance of the positions (subject to clearing) for each of its clearing members[55] (or “direct participants”) vis-à-vis all of their counterparties. Centralised clearing enables members not only to reduce their exposure to (counterparty and operational) risks and unrealised cash flows when transactions are settled, but also to reduce their balance sheets and capital needs[56]. Participants benefit from the clearing service for a set of costs (initial margins and variation margins, FICC operational and liquidity requirements, operating costs, contribution to the FICC default fund and commitment to financing it should there be stress). For the time being, the FICC requires its clearing members to route only transactions between themselves through centralised clearing.
Primary dealers are de facto FICC clearing members. Since 2005, the FICC has also had the Sponsored Service in place, which has enabled some clearing members to act as Sponsoring Members[57]. As a result, they can sponsor some of their counterparties (such as money market funds and hedge funds) into “indirect” FICC memberships[58] and route their transactions on the repo market through centralised clearing.
Sponsoring Members are guarantors for the payment and performance obligations of Sponsored Members[59] (or “indirect participants”). Thanks to the programme, the sponsored counterparties can enjoy attractive rates and the FICC agreement-performance guarantee, even if their sponsor defaults. However, the Sponsored Service is struggling to expand, as the criteria for joining the programme are strict, the programme is limited to overnight operations, sponsorship can be costly and the haircuts imposed by the FICC (2% for Treasuries) are higher than the haircuts applied on the bilateral market (Hempel, Kahn, Nguyen and Ross, 2022).
THE MAJORITY OF PRIMARY DEALERS’ REPO TRANSACTIONS ARE NOT CENTRALLY CLEAREDThe majority of primary dealers’ repo transactions are not currently routed through centralised clearing (Infante, Petrasek, Saravay, Tian, 2022; Kahn and Olson, 2021). On average, during 2022, 46% of the Treasuries repurchase agreements by primary dealers, as well as 60% of their reverse repurchase agreements were entered into bilaterally, with no involvement from the FICC.
25% of their repo borrowings and 34% of their repo loans were cleared centrally with the FICC.27% and 3% of these transactions, respectively, were cleared on the tri-party market, with no centralised clearing. Finally, 2% of their repo borrowings and 3% of their repo loans were entered into on the tri-party market and cleared centrally with the FICC (Chart 25).
Following various recommendations made to address these issues (Duffie, 2020; Liang and Parkinson, 2020; Group of Thirty, 2021; Inter Agency Working Group on Treasury Market Surveillance, 2021 and 2022), on 14 September 2022, the SEC proposed a rule[60] which would require the FICC to take the necessary steps to force its clearing members (i.e. all primary dealers) to route all of their Treasuries repurchase and reverse repurchase agreements and a very large amount of their Treasury purchases and sales through central clearing[61].
This reform, which is very ambitious, is likely to increase dealers’ intermediation capacities by lightening their balance sheets. According to the SEC, it would be a step towards all-to-all trading platforms, where buyers (lenders) and sellers (borrowers) can come together without any intermediaries[62]. Even though the rule allows the margin requirements imposed on clearing members to be adjusted[63], it does, however, risk significantly increasing the costs borne by their counterparties not affiliated with the FICC. Some analysts or lobbyists have already warned that this rule may lead to shallower Treasuries markets, as a result of disincentivising some participants from taking advantage of them.
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The possibility that the Fed will not be able to implement QT2 for the entire planned period due to a major downturn in market liquidity cannot be ruled out[64]. In this regard, taking into account the impact of regulatory constraints imposed on banks, the main intermediaries on money and Treasuries markets, seems essential. During the QT1 programme, liquidity management constraints had hindered the Fed’s plans to reduce its balance sheet. Now, the balance sheet constraints could in turn curtail QT2.
A number of monetary policy or regulatory provisions, aimed more broadly at preventing liquidity risks and boosting the resilience of the Treasuries market, could alleviate these constraints. Some pitfalls may limit the scope of these provisions, however. This is the case in particular for the two repurchase facilities put in place by the Fed (the Standing Repo Facility and the FIMA repo). By providing the opportunity to convert securities into liquidity should there be stress, these facilities were designed, implicitly, to encourage small banks and foreign central banks which do not have swap agreements with the Fed to enlarge their Treasuries portfolios, automatically reducing the proportion of securities that are likely to remain on primary dealers’ balance sheets. Due to, in particular, some of their arrangements (the incapacity to clear positions and the stigmatisation risk for the Standing Repo Facility, the high cost of the FIMA repo facility), membership applications for these two facilities are rare however.
This is the case, then, for the regulatory changes considered. Potentially easing the SLR leverage constraint would give large banks, which are involved in market making, the opportunity to free up balance sheet capacity. However, with no additional review of the method for calculating the surcharges based on systemic importance scores, and given the projected growth in US federal debt, we do wonder whether easing it in such a way would be appropriate. Ambitiously broadening the scope for Treasuries markets’ central clearing would significantly help to reduce primary dealers’ balance sheet constraints. However, it could have the serious drawback of eroding the liquidity on the Treasuries market, by disincentivising some participants from taking advantage of it. It would also take several years to fully implement.
Completed on 15 December 2022