A Capital Fed Ruling

The Fed just released it's latest missive to the big banks, and the answer is capital, lots more capital.

Three cheers for the Fed.

They are increasingly understanding that no matter how much they try to micromanage asset decisions, it's impossible to regulate away risk from the top. And "liquidity" will vanish the minute it's needed. Joke version -- liquidity standards are like requiring everyone on an airplane to carry a thousand bucks, so they can buy a parachute if the engines blow up. Just who will be buying "liquid" assets in the next crash?

So,  just raise capital, lots more capital, and slowly let the rest fade away.

A minor complaint: The Fed did it right but said it  wrong.

..under the rule, a firm that is identified as a global systemically important bank holding company, or GSIB, will have to hold additional capital...

No, capital is not "held." Capital is issued. Capital is a source of funds, not a use of funds. Capital is not reserves.  Please all, stop using the word "hold" for capital.

"A key purpose of the capital surcharge is to require the firms themselves to bear the costs that their failure would impose on others," Chair Janet L. Yellen said. "In practice, this final rule will confront these firms with a choice: they must either hold substantially more capital, reducing the likelihood that they will fail, or else they must shrink their systemic footprint, reducing the harm that their failure would do to our financial system. Either outcome would enhance financial stability."

Issuing (not holding!) more capital does not make firms "bear costs." Firms never bear costs. They pass costs on to customers, workers, shareholders, or (especially for banks!) the government.  The slight argument for higher "costs" is that equity gets to leverage with less subsidized too-big-to-fail debt; that's not a cost, that's a reduction in subsidy. If (if) the cost of equity capital is high by some MM failure, then equity receives higher returns and borrowers pay higher costs. This is a surprising quote. Ms. Yellen is usually accurate in such matters.

But that's a minor complaint. I'd rather they raise capital and explain it wrong rather than the other way around. And of course, I'd rather they keep going. I'm also a skeptic that big banks are "systemic" and little banks are not, and thus should be allowed to continue with sky high leverage. But we'll get there.

Update:

A reader asks why I'm so persnickety about language. In this case, it's important. I think everyone recognizes that more capital leads to more financial stability. When an equity-financed bank loses money, share prices decline, but there are no failures or freezes. However, if you think capital is "held," and it "costly," then you think that banks shifting to issuing equity or retaining dividends to obtain funds has a cost to the economy, and regulators should require as little capital as possible. If you recognize that capital is issued, does not tie up funds, does not reduce the amount available for lending, then your mind is open to obtaining financial stability with lots and lots more capital.