Why Not Break Up Citigroup?

Simon Johnson, the former chief economist at the International Monetary Fund, is the co-author of “13 Bankers.”

Earlier this week, Richard Fisher, the president of the Federal Reserve Bank of Dallas, captured the growing political mood with regard to very large banks, observing, “I believe that too-big-to-fail banks are too dangerous to permit.”

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Market forces don’t work with the biggest banks at their current sizes, because they have great political power and receive almost unlimited, implicit subsidies in the form of protection against downside risks — particularly in times like these, with Europe’s financial situation looking precarious. Mr. Fisher added:

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Downsizing the behemoths over time into institutions that can be prudently managed and regulated across borders is the appropriate policy response. Then, creative destruction can work its wonders in the financial sector, just as it does elsewhere in our economy.

Mr. Fisher is a senior public official and also someone with a great deal of experience in financial markets, including running his own funds-management company. I increasingly meet leading figures in the financial sector who share Mr. Fisher’s views, at least in private.

What, then, is the case in favor of keeping mega-banks at their current scale? Vague assertions are sometimes made, but there is very little hard evidence and often a lack of candor on that side of the argument.

So it is refreshing to see Vikram Pandit, the chief executive of Citigroup, go on the record with The Banker magazine to at least explain how his bank will generate shareholder value. (Viewing the interview requires registration, however.)

Citi is one of the world’s largest banks. According to The Banker’s database, which includes data from the end of 2010, it had total assets of just under $2 trillion — putting it in the top 10 worldwide. Over all, The Banker places it as No. 4 in its “Top 1,000 World Ranking.” Citi is No. 39 on the Forbes list of the top 500 global companies, with total employment of 260,000.

Is there indication in Mr. Pandit’s vision that mega-banking will be good for the rest of us in the future? Don’t look for Citi to drive any kind of rethinking of the consumer market in the United States; Mr. Pandit just wants to downsize that part of his business.

The engines of growth, Mr. Pandit said, will be “the global transactions services business” and “emerging markets.”

Transaction services are important, but they do not require a very large balance sheet; these can equally well be performed by a network of small, nimble financial firms. Global commerce existed for centuries before banks built up risks that are large relative to their home economies.

And emerging markets are risky. Mr. Pandit is essentially betting that Citi can ride the cycle in those countries. Probably there will be relatively good profits for a number of years, and this will justify high compensation levels. But when the cycle turns against emerging markets, as it did in 1982, what happens?

In 1982, Citi had a large loan exposure in the emerging markets of the day — Latin America, and the Communist nations of Poland and Romania — and it was saved from insolvency by “regulatory forbearance,” meaning that the Federal Reserve and other regulators did not force it to recognize its losses. Citi was a relatively big bank at that time, but much smaller than it is today.

And its complex global operations are exactly what would make it very hard to put through orderly liquidation under Dodd-Frank. I argued here in March that there is no meaningful resolution authority for global banks; before and after that post I’ve taken this point up in private with senior officials in the United States and Europe responsible for handling the potential failure of such entities.

No one disagrees with my main point: we cannot handle the collapse of a bank like Citigroup in “orderly” fashion.

Jon Huntsman put mega-banks on the agenda for the Republican primaries, with a blistering commentary in The Wall Street Journal a few weeks ago: “Too Big to Fail Is Simply Too Big.”

Other contenders for the Republican nomination have followed his lead, including most recently Newt Gingrich. Whoever ends up going head to head with Mitt Romney is likely to make good use of this very theme — because Mr. Romney already has so much financial support from the top of Wall Street, it will be very hard for him to respond effectively.

Breaking up the biggest banks is not a fringe idea to be brushed off. Mr. Fisher is speaking for many people who work in financial services, who agree that the big banks are not good for the rest of us. Mr. Pandit’s interview just reinforces this point.

Any Republican candidates who say they are fiscally responsible must eventually confront this issue: What was the role of big banks in the enormous recession and consequent vast loss of tax revenue since 2008? Which sector poses clear and immediate danger to our fiscal accounts, looking forward — and in a way that is not yet scored properly in any budget assessment? As Mr. Fisher put it, rather graphically,

Perhaps the financial equivalent of irreversible lap-band or gastric bypass surgery is the only way to treat the pathology of financial obesity, contain the relentless expansion of these banks and downsize them to manageable proportions.

I suggest that Mr. Fisher could reasonably begin with Citigroup.

More Transparent Bank Stress Tests Are Needed

Simon Johnson, the former chief economist at the International Monetary Fund, is the co-author of “13 Bankers.”

Europe and the United States both need to conduct another round of stress tests on their banks, with a model similar to what was done in the United States in 2009, but with a more negative downside scenario — in particular, assessing the effects of a major sovereign debt problem in the euro zone.

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The point of such a scenario is to determine how much equity financing banks need to have if the world economy turns ugly. If the big banks raise more capital in advance, we are less likely to see economic downturn again become financial catastrophe.

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The prevailing wisdom about Europe is that it faces primarily liquidity problems. In this view, a few of the larger countries have had trouble rolling over their debts, and some leading banks need help with short-term financing. The European Central Bank can assist with both by buying government bonds and lending to banks and, in the most optimistic interpretation, the consequent political discussions will help strengthen European Union integration.

There are two problems with this positive spin on recent events. The first is that sovereign debt problems can easily become solvency issues — that is, more about whether countries can afford to service their debts rather than whether they can raise enough cash at reasonable rates in any given week. The key issue is growth — if Italy, Spain and others can show they will grow reasonably quickly, then debt relative to gross domestic product will decline, and rosy projections will be back in fashion.

But if signs of growth do not return soon, perhaps over three to six months, the next downward revision to forecasts will spread deeper debt pessimism. And any markdown for global growth prospects, including for reasons outside Europe’s control (such as overheating in China’s residential property market), would also not be helpful over the coming year. My Peterson Institute policy paper with Peter Boone in July suggested some potential escape routes, but the summer so far has produced only further attempts to muddle through.

The more immediate Achilles heel is banking. The virtues of big European banks were extolled by some Congressional representatives during the Dodd-Frank legislation in spring 2010. What a difference a year makes; not many members of Congress would today endorse anything about European banking, given all the problems that have emerged.

The main immediate problem for Europe is that we still don’t know exactly the condition of its major financial institutions. The Europeans have run bank stress tests twice recently, in mid-2010 and again earlier this year. But in both cases the tests were far too lenient and banks were not required to raise enough capital.

They should have been compelled to increase their equity funding relative to their debt, in order to create a greater buffer against future losses.

The 2009 banking stress tests in the United States can also be criticized for not including a scenario that was sufficiently negative. In recent weeks the market has expressed great skepticism about Bank of America, its inherited liabilities, future business model and, most of all, the adequacy of its capital.

Most likely, Bank of America needs to be broken up, with the continuing businesses funded with equity to a level that could withstand adverse legal outcomes and a deep recession. (For more background on how to think about bank equity, see the recent testimony of Paul Pfleiderer to the financial institutions subcommittee of the Senate Banking Committee; anyone working on banking policy in Europe or the United States should read this.)

Dodd-Frank created pre-emptive intervention powers, at the behest of Treasury and the Federal Reserve, with part of the rationale being that these could be used to prevent a megabank’s slow death spiral from becoming a market panic.

In “13 Bankers,” James Kwak and I expressed considerable skepticism that this could work — it just does not fit with the history and politics of regulation in the United States, within which even the Treasury secretary defers to what Bloomberg News calls the “Wall Street Aristocracy.”

The American 2009 Supervisory Capital Assessment Program, known as SCap (pronounced ESS-cap), was designed to reveal potential stressed capital levels and, as a result, the 19 companies covered by SCap have since increased their common equity by more than $300 billion.

Unfortunately, weakness at Bank of America generates systemic risk, undermines overall market confidence and magnifies the risk of another recession; this is exactly what SCap is supposed to have avoided — but failed to do because it was not sufficiently tough.

The Comprehensive Capital Analysis and Review stress tests, known as CCar (pronounced SEE-car), concluded in April 2011, were even less helpful. These were much less transparent, focused more on companies’ internal capital planning processes. The Fed did sensitivity analysis of the companies’ own stress tests; this is not exactly reassuring, given how badly the industry’s own models have failed in the recent past — including in the events that led up to the Fed’s $1.2 trillion of emergency loans in 2008.

Yet the European stress tests to date must be rated a notch or three below even the CCar in terms of transparency and communication of information that allows market participants to make informed decisions. The latest round, conducted by the European Banking Authority through July 15, did not even examine what would happen if a sovereign borrower had to restructure its debts — exactly what Greece was working on during the same time frame. (To be precise, there was some “sovereign stress” in the tests but very little compared with what we have seen and could see.)

This is worse than embarrassing. It creates exactly the wrong kind of uncertainty around European megabanks, including their operations in the United States and potential spillover effects.

In part this happened because the European Banking Authority is new — it came into existence on Jan. 1 — and not sufficiently powerful relative to national bank supervisors, many of whom are stuck in an old mindset where transparency is bad and full disclosure of banks’ balance sheets is scary. (The low capital levels of European banks was described more fully this week in a Bloomberg article.)

But partial facts and distorted information flow are exactly what creates fear and instability, not just in Europe but much more broadly.

If euro-zone leaders want to make any progress on governance reform, they should immediately strengthen the banking authority and call for a new round of stress tests. These tests should include a deep recession scenario in Europe, as well as disruptions to sovereign debt financing. At the same time, the Federal Reserve should acknowledge that the CCar was not enough; it’s time for a new round of tough stress tests here, as well.

The notion that bank equity is socially expensive and should be minimized is an idea whose time has passed — as Anat Admati, Peter DeMarzo, Martin Hellwig and Professor Pfleiderer have argued. It is time to find ways to strengthen the equity funding of major financial institutions around the world, quickly, fairly and effectively — a point that was made clear in the recent hearings held by Senator Sherrod Brown, Democrat of Ohio.

Any further delay risks worsening the global slowdown.