Does our financial system need a systemic risk
regulator? Common wisdom is turning
toward an affirmative answer to this question, but many doubt the wisdom of
adding a new layer of bureaucracy to our already-Byzantine system of financial
regulation. Plus, they say, markets
already offer many ways to hedge risks, and traders should be smart enough to
avoid these kinds of problems in the future.
But a risk regulator is the right way to go, and critics
should take a lesson from post-Medieval British farmers.
Well into the 19th Century, English cows, sheep,
pigs, and other livestock grazed on the “commons:” shared pastures which anyone
could use. But the commons were always
depleted, with barely enough grass to support the herds that used them, to
everyone’s detriment.
Why couldn’t the owners conserve resources more
rationally? In a 1968 essay, Garrett
Hardin labeled this phenomenon the “tragedy of the commons” and outlined its
basic logic. True, everyone is better
off if fewer animals graze on the commons, but each individual user has
incentives to increase the size of his herd past the socially efficient
point. After all, the gains from these
additions accrue solely to the one who adds a cow, while the costs are spread
across all users. As a result, voluntary
deals to restrain herd size fall apart, and all suffer as a consequence.
How does this relate to the regulation of financial
systems? Well, from time to time markets
are subject to panics, bank runs, and other system-wide failures. When these happen, the costs are borne by all
members of the financial community, not to mention ordinary people who look to
the banks for loans and financing for their projects. And these panics are more likely to happen
when there are lots of risky assets in circulation. So all would agree that everyone is better
off when banks restrain their use of risky assets.
But just like the English farmers, investment bankers know
that if they add just one more risky bet to their portfolio, they will retain
all the profits that result if it goes well, while the costs of systemic
failure are spread out to everyone else.
So they have incentives to add to their portfolio, as does everyone else
in the system until – well, until what’s happening now happens.
Notice that the problem is not that the bankers aren’t smart
enough to avoid trouble. Quite the
reverse: trouble comes precisely because the bankers, like the herdsmen before
them, are able to accurately calculate their own costs and benefits from
alternative actions. And the problem
isn’t the lack of risk management tools either: each bank can be individually
safe and sound, hedging its own bets, while the system as a whole teeters on
the verge of collapse.
How to escape the dilemma?
We can’t do what the herdsmen did, which is fence in the commons and
assign private rights to grazing land – no regulatory barrier could be high
enough to prevent problems Wall Street from spilling over into Main Street.
How about the other extreme: regulate which assets can be
bought and sold, to make sure that the system doesn’t have to take on
unacceptable levels of risk? This puts
the heavy hand of government right in the middle of the financial marketplace,
which is surely a recipe for disaster.
Since when are government officials better at measuring expected returns
than bankers? And do we really want to
force traders to get government approval before pressing the button on every
deal? Business would fly away to foreign
exchanges faster than you could say “Long Term Capital Management.”
But there is a middle ground: use market mechanisms to align
the incentives of traders, making them face the true social costs of their
actions. Buyers of assets with
undiversifiable risk over a certain level would pay a fee into a central
insurance fund, with the payment proportional to the size of the deal and its
riskiness. Just like FEMA requires
homeowners who build their houses on floodplains to buy insurance in the case
of storms, financial firms would contribute to a rainy-day fund, to be used to
stabilize asset values in the case of market meltdown.
This scheme would accomplish a number of purposes
simultaneously. First, it would help
ensure that banks don’t engage in transactions whose individual benefits to the
investors are outweighed by the risk they impose on the rest of society. Second, it would create a stockpile of
reserves, so that when the banking system does go into a tailspin, the money to
bail them out (or at least the first installment) would come from the banks
themselves, rather than the taxpayers.
And third, it could get our financial system back in order using market
incentives, rather than heavy-handed government interference, to do the hard
work.
Moving in this direction will take resolve and cooperation
from Congress, the administration, regulatory agencies, and most importantly
the firms themselves. And there are
still many details that will need to be worked out so that the system runs
efficiently, without huge costs of oversight.
But the rewards are great as well: a financial system that is
well-regulated is a boon not only to borrowers and taxpayers, but, as is now
abundantly clear, to the players in the financial system as well.
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