Tale of Two Countries: Canadian and American Banking System

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Diverse Experiences with Banking System

Tale of Two Countries: Canadian and American Banking Systems

J.D. Han

King’s College, UWO

I. The American Story

1. Characteristics of U. S. Banking

Industry

 Pre-1863 State Banking only

1) Dual Banking System

Some banks are regulated by the state agency and others by the Federal agency

1863

1913

1934

National Banks (Act) emerging

Federal Reserve System

Federal Deposit Insurance Corporation

2) Multiple Regulatory Agencies: “Crazy Quilt System”

 The Office of the Comptroller of the Currency

: in primary charge of “Charter” for national banks

 Fed

:in secondary charge of national banks, and in sole charge of bank holding companies

 FDIC and State Banking Authorities

: in charge of state banks with FDIC insurance

 State Banking Authorities

: in sole charge of state banks without FDIC insurance

3) Fractured Banking Industry

A Large # of Banks: 12,000 until the early 1990

Many Lacking “Scales of Economies

> only 325 banks have assets above $1 billion (’94)

-> until recently, some states had “Unit Banking System”.

-> Consolidation and Simplification: Key Issue of

Presidential Reforms

2. Historical Background

1) Federa l versus State Struggles for Hegemony

-

“The Wizard of Oz as a Monetary Allegory” by H. Rockoff

Background: Depression in the 1890s

Allegories:

Dorothy: an Average conscientious true American

Tornado

Wicked Witch of the East- Eastern Business and Financial Interests

Munchkins -Average Americans

Scarecrow -Western Farmer

Tin Woodman- Unemployed Industrial Workers

Cowardly Lion “William Jennings Bryan”

Wicked Witch of the West - Grover Cleveland silver shoes: magic water that melt the witch: solution – watershed – inflation (through printing money)

A Lesson: So much socio-political problems and regional interests were intertwined with

Monetary policies (and banking practices):

The complexity of the current banking system of the U.S. is a on-goint legacy of the long tradition of these complicated political Struggles between regions, parties and interest groups.

2) Anti Trust Acts of 1920s to 1930s have shaped the U. S. Banking System

 McFadden Act of 1927: limits and prohibits inter-state banking and branching

 Glass-Steagall Act of 1933: Anti-Trust Act separating Banks and Commerce

* Apparent Rationale Underlying the Separation of

Commercial and Investment Banking: Glass-Steagall

Act

In favor of Specialized Banking as opposed to Universal Banking

If banks are engaged in securities business, there may occur

 Conflicts of Interests;

Unfair Competition;

Risk of Safety and Soundness;

Concentration of Power;

Unfair Stretch of Federal safety net

3) Turn Around

1.Evolution of Bank Holding Companies

2. Reigle-Neal Act of Interstate Banking and Branching Act

(1994)

: Opening up M & A for “Efficiency” in banking sectors

2.

Gramm-Leach-Bliley Financial Modernization Act (1999)

: Banks are allowed to form Financial Holding Companies across industries and even to carry out “merchant banking” or equity investments in nonfinancial firms.

* *Ground for Changes: Gramm-

Leach-Bliley Act

-Economics

: Cost Savings

: Risk Diversification

-Legal Issues on Conflict of Interests can be resolved by “Mezzanine Finance” and “Lender

Liability and Equitable Subordination”

* How American Banks Merge?

The number of banks has been decreasing

16000

While mergers between banking groups have slowed, there has been a move towards diversification as the barriers between commercial and investment banking have finally broken down.

14000

12000

10000

8000

6000

4000

2000

0

'75 '80

# of Banks

'85 '90 '95 '00

II. Canadian Story

1. Evolution of Canadian Financial

System

Tradition of

“Four Pillar System” :

Trust, Mortgage, Fiduciary Business

Chartered Banks

Insurance

Securities Industry

(Credit Unions)

Towards

Full Service Banking

2. Reforms in the Canadian Bank Act

 1954

: Banks were allowed to go for household lending and to make mortgage loans insured by NHA

 1967

: the 6% ceiling on the mortgage loans was removed

 1980

: banks were allowed to have mortgage loan companies and venture capital companies.

 1987

:banks were allowed to underwrite corporate securities

: abolishing the Canadian equivalent of “Glass-

Steagall Act”

 1992

: banks were allowed to own trust companies

: banks were permitted to offer a number of inhouse activities, such as portfolio management, and investment counseling .

: required reserves are to be phased out.

 1999

:Bill C-67

 2000-2001

Bill C-38 and Bill C-8

3. Current Characteristics

 A Small # of Banks

 Big Five Sisters dominate market

 Highly Regulated and Protected Inbound from

International Competition

 Highly International Outbound

4. Other Apparent Differences between U. S. and Canada

U.S.

 Big Increases in Mortgage

Backed Securities

<S & L companies’ mismatch of maturity terms of Assets and

Liabilities

 Big Surge of Money Market

Mutual Funds

<- way to get around `Regulation

Q’

Canada

 Not Much

 No Big Surge

5. Changing Characteristics of

Canadian Banking Industry

 Chart 9 of C. Freedman

III. Japanese Banking System

 Post WWII Japanese banks were reorganized by the U.S. Occupying Army

 Yet, they have been distinct from the U.S, banks

 Notably, Japanese banks have been allowed to hold equities and to participate in management of non-financial corporations

Japanese Banks are allowed to own Equities:

Banks are lenders as well as owners

Pros:

-

-

Reduces bankruptcy costs for society (legal cost; disruption cost)

Sumitomo Bank revived Mazda in the 1970s

-

-

Reduces monitoring cost of Principal-Agent Problem

(Sun Bae Kim, Banking and Commerce: The Japanese

Case)

Makes banks share ‘Upside Returns’ and ‘Calculated

Entrepreneurial Risk and Venture’

Cons:

-

-

-

Stock Market Crash leads to Loss of Bank

Assets

Moral Hazards: “Too Big to go bankrupt”

IV. European Banks

 Universal Banking offering a wide spectrum of services and products

as opposed to “Specialized Banking”

 Fully Merged

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