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Speeches and Testimony |
Ricki Helfer Chairman Federal Deposit Insurance Corporation
before the
Phoenix, Arizona
I grew up in Tennessee, where people have a reputation for
independence -- one that they earned before Tennessee was even a
state. At the end of the Revolutionary War, the pioneers who lived
in what is now Tennessee, but was then North Carolina, declared
themselves a "free and independent state" they called "Franklin."
Disgruntled by the treatment they received from the North Carolina
state government, they formed a legislature, elected a governor,
and, to underscore they were serious, established a militia. They
asked the United States Congress for recognition. From their log
cabins in Appalachia, they sought international support. North
Carolina, my birth state, pursued reconciliation -- a policy that,
after four years, was successful in bringing the Tennessee settlers
back into the North Carolina community, at least for a time. When
I grew up in Tennessee, every student learned about the streak of
independence -- and the sense of community -- that we inherited
from our ancestors.
History, as it was taught then, was comprised of both fact
and reflections on experience. Reflecting on our experience as
Tennesseans led to the conclusion that we enjoyed a dual legacy of
independence and community. The lessons of history were that we
would think for ourselves -- and act together to achieve our
common purpose. Those were not bad lessons then, when daily
life in small towns in Tennessee reinforced them, nor are they bad
lessons today.
The towns in which I grew up were served by community
banks. If I had to define a community bank, the type of bank that
you manage, I would not do so with asset or deposit figures, or
statistics about offices or employees, even though the vast majority
of you have numbers to be proud of. Reflecting on my experience,
I would say that a community bank is one where the banker knows
his or her customers -- not as numbers -- but as neighbors. You
offer the services of the financial world to people whose names
you know. Because of your experience, you also have a reputation
for thinking independently -- and for working together to achieve
the purposes you share.
You need to use your talents for independent thinking and
for working together to continue to benefit from Federal deposit
insurance. In very recent years, the value of deposit insurance has
been seriously questioned for the first time since Congress created
it in 1933.
I am here today to talk about the value of Federal deposit
insurance to the community banker -- and to the communities and
customers you serve, as well as to all Americans. I will also talk
about how we have improved our approach to Federal deposit
insurance in the past few years to address some of the problems we
have encountered and to make it even better for the future. Finally,
I want to discuss why proposals to change our system by lessening
coverage or privatizing deposit insurance would undermine public
confidence in the banking system, and why a recent proposal to
change the way that we resolve the largest bank failures would
destroy the Federal deposit insurance system, if enacted.
As I have noted before, the FDIC was created in the darkest
moment of the Great Depression. Nine thousand banks failed in
the three years before the FDIC was created. The year following
the creation of the FDIC, only nine insured banks failed. As Carter
Golembe recently pointed out, at the time of its creation many
lawmakers saw Federal deposit insurance as the means to assure
the continued existence of the community bank by restoring public
confidence in our diverse, dual banking system. These banks, like
many of yours, served small businesses, farmers, and the other
people of the community in which they operated.
The supporters of federal deposit insurance thought that,
without the services of the community bank, the community could
wither. This was not a baseless fear: The elimination of more than
20,000 banking offices from 1921 through 1933 had left a large
number of communities without banking facilities.
As two noted banking experts pointed out in 1941 after
examining the results of these closures: "To the extent the lack of
suitable banking facilities is a factor in weakening the smallest
communities and in bringing about a greater concentration of
population and business in the larger centers, it leads to social
losses, for wealth and productive capacity are reduced. Abandoned
houses, empty factories, and deserted farms are visible symbols of
such losses," these experts said.
In the late 1920s and early 1930s, communities throughout
the United States were filled with these visible symbols of loss. It
is not much of a coincidence, however, that the National Bureau of
Economic Research dates the end of the Great Depression as
March 1933, the month and year when the FDIC was created. In
restoring public confidence in the banking system, the FDIC gave
Americans the security to dream of a better future, and to work
toward that future.
Has the confidence that Americans had in deposit insurance
been justified?
Almost half a century after the FDIC was created, we
confirmed that it was indeed justified. From 1980 through 1994,
1,617 banks were closed or received FDIC financial assistance.
We have evidence that, throughout this recent crisis, Federal
deposit insurance was the anchor for public confidence in the
banking system. In 1989 the American Banker commissioned
Trans Data Corporation to survey 1,009 adults throughout the
continental United States on their confidence in banking.
Ninety-five percent of the respondents to that survey said that the
Federal deposit insurance fund was important to them. Nine out of
10 of the respondents expressed confidence in the current
insurance system. When asked what they would do with their
money if there were no deposit insurance, 36 percent said they
would keep it at home. Only 18 percent said they would keep their
funds in a depository institution.
In 1989, it was no secret that the industry was facing
difficult times. By 1994, however, the industry had improved
dramatically.
Late that year, the Gallup Organization was commissioned
to do a statistically valid national survey of 1,002 households that
used banks for at least some of their financial needs. The results of
that survey, published in October of 1995 -- showed that, despite
the greatly improved health of the industry, 94 percent of the
respondents agreed that FDIC insurance was important to them --
virtually the same percentage as the American Banker survey in
1989.
It is clear that in bad times and in good, FDIC deposit
insurance has been one of the few certainties in an uncertain
financial world. Federal deposit insurance has given three
generations of Americans a sense of security. The public has
confidence in you, in large part, because the public has confidence
in the FDIC. The public has confidence in the FDIC because our
independence from the political process gives us the freedom to
make difficult decisions and to take swift and effective action in
addressing bank failures.
Significantly, in the 1980s and early 1990s -- the worst
crisis of the post-depression era -- our strong insurance fund
granted us the political independence we needed to make the hard
decisions necessary to take care of problems as they occurred.
Compare our experience to that of the old, defunct Federal Savings
and Loan Insurance Fund. It did not have the financial means to
address the problems in that industry, and its regulators lowered
capital standards, eased other regulatory rules, and even tried
forbearance to keep troubled S&Ls -- and a troubled S&L industry
-- alive until the S&L industry could grow out of its problems.
That strategy did not work. Ultimately, industry losses were many,
many times what they would have been had problems been
addressed promptly.
The FDIC, too, had its problems with some thrifts during
that period -- the Bank Insurance Fund-insured savings banks. In
contrast, because we had a strong fund, we had the means to
address failing and failed institutions quickly. Because we had a
strong insurance fund, we could make the hard decisions necessary
to turn other troubled institutions around through strict plans to
improve performance. One of the lessons of the 1980s and early
1990s could not be clearer: a strong, politically independent,
insurance fund is essential to deal with problem institutions in
times of stress.
A strong insurance fund and effective bank supervision
work hand-in-hand to maintain stability.
Another lesson of that crisis was that the FDIC could
reduce losses to the insurance funds by more market discipline in
the bank regulation and resolutions process. Market discipline is
as important for banks as it is for any other business. Because
public confidence is necessary for stability in banking, however,
small insured depositors are granted certainty. That certainty is the
price for stability.
Such certainty should not, however, be given to creditors,
large depositors and shareholders -- because they can and should
bring market discipline to the process.
Since 1991, the FDIC has been required by law to accept
the proposal from a potential purchaser of a failed bank that is the
least costly to the insurance fund of all the proposals we receive.
In more than half of the failures in 1992 -- 66 out of 120 --
uninsured depositors received less than 100 cents on each dollar
above $100,000. That was a significant increase in uninsured
depositors experiencing losses as compared to 1991, before the
change in the law went into effect, when fewer than 20 percent of
the failures involved a loss for uninsured depositors.
Since the least cost test has been applied by the FDIC, large
depositors and creditors should understand that they are at risk for
losses on their exposures to banks -- and that is the point: these are
the parties best able to make sophisticated judgments about the
health and strength of a financial institution -- not small depositors.
In addition, over the past few years we have undertaken
two reforms in deposit insurance that give shareholders a greater
incentive to curb excessive risk taking at their institutions: one is
higher risk-based capital standards, and the second is risk-related
insurance premiums. Risk-based capital standards expose
shareholders of an institution to greater loss. Risk-based premiums
are designed to reduce income in institutions that take on excessive
risk. That reduction in income is aimed at giving shareholders
reason to curb the excesses.
The FDIC stands in the place of the insured depositor. Our
examiners assess the condition of institutions because the insured
depositor generally cannot. As a supervisor,
we bring regulatory discipline to bear because the small depositor
cannot bring market discipline to bear. The FDIC recognizes,
however, the role that market discipline plays, and it will continue
to explore ways to assure that sophisticated financial interests have
reasons to care what happens to an insured bank.
In spite of these reforms, a small but vocal number of
critics say that the deposit insurance system would be improved by
even more market discipline, either by reducing insurance
coverage or privatizing the FDIC. There was ample market
discipline between 1929 and 1933 when more than 9,000 banks
failed in this country, but the price was too high in terms of the
instability of the system. In reducing deposit insurance coverage to
put insured depositors more at risk, we would undermine the
absolute confidence that the American public has in the deposit
insurance system. The reason is simple -- deposit insurance
assures confidence because it is a certainty, and certainty cannot be
lowered by degrees -- it cannot be fine-tuned. Anything less than
certain is uncertain. If we lower deposit insurance coverage once,
the implicit message for the American people is that we would do
so again. We can offer absolute certainty because the deposit
insurance system is backed up by the "full faith and credit" of the
Federal government.
Privatizing the FDIC would replace that "full faith and
credit" guarantee with something else -- a finite fund, perhaps, or
cross guarantees by banks. The experience with private and
state-sponsored deposit insurance plans in the 1980s and early
1990s, however, suggests that the limited pool of resources on
which finite funds draw inspires less confidence than does the
unlimited unconditional guarantee the Federal government offers.
Private insurance plans may be able to handle isolated
failures successfully, but our experience in this century and the last
one is that limited plans have difficulty handling failures in waves.
They are therefore not good at stemming panic or contagion and
cannot assure stability.
Further, if private insurance is substituted for Federal
deposit insurance, a private insurance plan facing depletion of its
fund during a crisis would likely have to seek financing from the
banking industry or other private sources of funds at the same time
that the economy may be weak and the banking industry is having
difficulties.
Moreover, if the private insurance supplier fails, the
Congress may have to act to restore public confidence.
Congressional action might not happen quickly and could occur
only after serious damage has been done and costs have been
significantly increased. Market discipline is important, and we
should rely upon it whenever we can, but historical fact suggests
that when the banking system is under stress, the stability of the
system should come first.
In the 1980s and early 1990s the FDIC and other bank
regulators focused on maintaining the stability of the system.
Some have asked whether we provided too much protection to
uninsured depositors, creditors, and shareholders -- especially in
larger bank failures. They have questioned whether the desire to
maintain stability led the FDIC to extend protection beyond
insured depositors in too many instances, undermining the
beneficial effects of the market discipline that large creditors and
shareholders can provide.
It is easier to answer "yes" to these questions with the
benefit of hindsight than it probably was to see the problems in the
midst of the crisis. It may have been that bank regulators were too
cautious in their approach to larger institutions. In some cases, the
decisions might well be made differently today. If the regulators
were too cautious, I believe their decisions were made in an effort
to preserve communities, although with hindsight, they may have
-- prior to 1991 -- lowered the standard of what was "too big to
fail."
It is, nevertheless, a fact of life, that there are some --
although probably not many -- whose failure would present a risk
to the banking system either because of the institution's size or
because of its relationships with other institutions. The issue for
all of us is how to preserve the system without unfairly
advantaging the large creditors and shareholders of the bigger
institutions.
The Federal Deposit Insurance Corporation Improvement
Act significantly reduced the discretion regulators have to deal
with large failing banks. Importantly, however, the law leaves us
with enough flexibility to achieve a solution where the failure
would present a genuine risk to the system. The FDIC is permitted
to use Federal deposit insurance funds to resolve a bank failure if
the resolution does not meet the least cost test only if the Secretary
of the Treasury -- in consultation with the President, determines
that there would be "serious adverse effects on economic
conditions or financial stability." Such a decision can be
undertaken only after a super majority of the members of both the
FDIC Board of Directors and the Board of Governors of the
Federal Reserve System vote in favor of the action. That is a high
standard of accountability, particularly when one considers that the
recommendation would, of course, have to be defensible to the
Congress.
The law requires that any deposit insurance funds used in
such a resolution be replaced by an after-the-fact special
assessment on the liabilities of insured banks, a requirement which
would mean that large banks would pay a bigger share in
replenishing the insurance fund.
These standards mean that it is far less likely that the FDIC
will cover large depositors, creditors, and shareholders when a
large bank fails. These standards assure greater market discipline,
and greater fairness -- in resolving bank failures.
Nevertheless, a few critics seem to hold the view that, if the
least cost test cannot be met, then only taxpayer funds should be
used to address potential systemic problems. Such a view fails to
recognize that all of us will benefit if a systemic problem is averted
-- including banks of all sizes, and bank customers. Because we
are all affected by our economy -- and because our economy rests
on the foundation our financial system provides -- we have a
community of interest in preserving the stability of the banking
system. That community of interest encompasses everyone in our
nation -- including bankers on Main Street -- and on Wall Street.
The argument that we should rely only on taxpayer funds to
resolve bank failures that pose systemic risk is contrary to much of
what we learned in the past 15 years. As we saw in the S&L
experience of the 1980s, waiting for appropriations to resolve
failures resulted in denial, delay, and greatly increased costs. Our
political system has many virtues, but efficiency is not one of its
greatest. In the event of a large bank failure, what would be the
advantage of leaving the financial system at risk while we attempt
to address the failure through the legislative process? We have
seen that when the banking system is under stress in a crisis, swift
and decisive action maintains public confidence. That was the
lesson of the 1930s -- and the lesson from the crisis of the 1980s
and 1990s.
Congress created the FDIC -- as an independent agency --
to take action when necessary. We see that, while history does not
repeat itself, the business cycle does. We do not know what will
drive the next wave of bank failures -- or when that wave will
occur. The purpose of deposit insurance, however, is to spread risk
so that problems in individual institutions do not result in
catastrophe for all. For Federal deposit insurance to work, the
coverage must be comprehensive and universal. Federal deposit
insurance is an asset for every banker, every bank customer, every
American. It is of special significance, however, for the
community banker because it puts you on equal footing with the
big banks. Regardless of your size, the people of your community
can have faith that their insured deposit is safe in your institution.
You supported resolving the problems of the Savings Association
Insurance Fund to assure that there would be no doubts about
Federal deposit insurance coverage. I am confident that you will
continue to recognize that we all have a community of interest in
maintaining the independence of the Federal Deposit Insurance
Corporation and the continued strength of the Federal deposit
insurance system.
Thank you.
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Last Updated 06/25/1999
communications@fdic.gov
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