Mosler TALF Alternative


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Compare the TALF concept with my proposal:

The Fed can instead offer its member banks credit default insurance to support the Fed’s desire to support the lending it’s trying to support with the TALF.

For example:

The Fed can offer member banks default insurance on any AAA rated securities of newly originated auto loans, for a fee of, for example, 1% of outstanding balances.

Insuring against loss eliminates leverage limits on these securities for the banks.

This can be applied as desired to other financial assets the Fed is attempting to support with the TALF.

The advantages of this over the TALF are hopefully more than obvious.

(Yes, this is similar to what I proposed way back during the mortgage insurer crisis.)

Fed’s TALF Program Meets Resistance Over Foreign Worker Rules

by Scott Lanman and Robert Schmidt

Mar 17 (Bloomberg) — The Federal Reserve’s $1 trillion program to jump-start consumer and business lending is encountering resistance from investment firms over a new law that would make it harder to bring in employees from overseas.

Lawmakers inserted rules into last month’s stimulus legislation that prevent firms from replacing fired U.S. workers with foreign employees if they get funds under rescue programs.

Hedge funds, insurers and companies considering joining the plan may balk at hurdles involved in bringing in foreign talent.

The central bank has already delayed introduction of the Term Asset-Backed Securities Loan Facility, or TALF, which was first announced in November and originally scheduled to start last month. A further postponement or a limit to the number of investors participating would hamper the goal of thawing the market for securities backed by consumer and business loans.

“We need to be a little careful about how much we micromanage these financial institutions,” said Clay Lowery, a former assistant Treasury secretary, who is now a managing director of the Glover Park Group in Washington.

The securities industry’s main trade group alerted members to the issue on March 13, six days before the rescheduled start of the TALF.

Companies that apply for a visa on behalf of a foreign worker can’t dismiss employees in similar positions 90 days before and 90 days after requesting the visa, and have to prove they attempted to recruit a U.S. worker first.

Visa Burden

The Fed is working with the Homeland Security Department’s U.S. Citizenship and Immigration Services to provide guidance on the issue.

The law applies the restrictions to any recipient of funds under section 13 of the Federal Reserve Act. The TALF and most other Fed lending programs were authorized under that section.

The visa provision adds a burden to what participants already expected to be a slow start to the TALF, which is aimed at reviving the market for securities backed by auto, education, credit-card and small-business loans.

Fed Chairman Ben S. Bernanke and Treasury Secretary Timothy Geithner are counting on investors such as hedge funds to use cheap Fed loans to buy the securities, helping lenders lower rates and loosen other terms on new loans to consumers and businesses. The Treasury is funding 10 percent of the TALF loans from the $700 billion financial-rescue fund.

The New York Fed, which is administering the TALF, starts accepting applications for loans through the program today at 10 a.m. Originally the Fed planned a two-hour window for applications, then announced March 13 that the period would be extended until 5 p.m. on March 19, saying participants requested more time to complete documentation.


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NY Fed To Begin $200 Billion TALF March 17


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Yes, which is interesting as the banks are the Fed’s ‘designated agents’ for lending.

Seems they could figure out how to continue to use them for that purpose, rather than set up a form of an in house shadow infrastructure to do the same thing.

They are in this way over their heads.

>   
>   The Fed’s now trying to bypass the banks and lend directly to the market via third party >   mediums.
>   

>   
>   On Tue, Mar 3 at 11:30 AM, Mauer wrote:
>   
>   This language below was in the last version of TALF also but it sends a big message.
>   
>   ”Can a newly formed investment fund borrow from the TALF?”
>   ”Yes, so long as it satisfies all the eligible borrower requirements set forth above.”
>   
>   By the way, in Shiller’s new book, Animal Spirits he specifically talks about TALF and says >   that it is a very important part of the recovery program.
>   

Sad but true, though I would say fiscal balance can always do the trick.

And the Fed has failed to utilize its member banks for that public purpose.

>   
>   He seems to think that it is incrementally more important than other programs if you think
>   about how much space he devotes to discussing it.
>   
>   I read part of Koo’s book last night.
>   
>   He really gives fiscal policy a big push. Says that Romer, Friedman and Terin are off base
>   because they don’t give fiscal policy enough credit.
>   

Agreed!

>   
>   His charts as to the level of recovery and the tax revenues that the fiscal stimulus created
>   are very important.
>   
>   He should have been consulted by the administration.
>   
>   He is a big fan of FDR’s stimulus and obviously doesn’t think much of those that caused
>   FDR to cut deficit to zero in 1937.
>   
>   He charts indicate that the economy was well on road to recovery before start of war
>   although you need to give lend lease credit for some of that.
>   
>   But that goes back to the fiscal stimulus again as opposed to monetary.
>   

Yes, exactly.

>   
>   ”Problem here is that most of the borrowing demand – but not all- is likely to be distress
>   debt demand as few households are likely to remain convinced they can maintain a deficit
>   spending profile in this type of macro environment.”
>   
>   ”the Fed’s now trying to bypass the banks and lend directly to the market via third party
>   mediums.”
>   

The fed could set up a program for the banks to deal with that with appropriate fed guarantees and ‘profit caps’.

>   
>   On Tue, Mar 3, 2009 at 11:28 AM, Scott wrote:
>   
>   Like just having the Treasury buy conforming mortgages at 4%.
>   
>   Yes, WAY over their heads.
>   

Exactly!

There are all kinds of creative ways to use the banking system to bring down rates and/or increase funding if that’s what they want to do.

>   
>   On Tue, Mar 3, 2009 at 11:58 AM, Pat wrote:
>   
>   So how does the FED get liquidity to investors if the banks and banking regulations require
>   them not to lend given the current state of their balance sheets and capital.???
>   

Change the regulations.

Use Fed guarantees that put the Fed in the same risk position they are currently in anyway.

>   
>   How do you use the current infrastructure without removing the regulatory constraints?
>   

You alter the regulations which are always a work in progress.

>   
>   Simply put the banks don’t have the balance sheet available to lend at the levels they used
>   to.
>   

With Fed guarantees they don’t need balance sheet any more than the Fed does.

>   
>   We have seen estimates on repo balance sheet that has left the street or really just
>   evaporated in excess of $3 trillion. The correlation between market cap (see below) and
>   balance sheet is very high. So when 3+ trillion goes away from repo those securities
>   bought using repo financing get sold/bought for cash (de-levered / liquidated).
>   

Right. Repo only intermediates.

>   
>   The levered bid for securities disappears not to return w/o balance sheet support.
>   

Right.

Banks are levered institutions and should all have unlimited unsecured lines with the fed, as i have been suggesting for a very long time.

>   
>   That levered bid was VERY LARGE particularly for MBS. The repo market is a very large
>   CP conduit where money providers earn short term market rates financing portfolio
>   manager’s long term positions and for a spread a broker dealer was the pipeline between
>   the 2 entities. The pipeline is tiny now (see market cap graph below) and cannot meet
>   the liquidity needs of the larger market.

Right.

Banks can fill in the gap with appropriate Fed support.

Not that I would recommend filling all the gaps!

But in any case investors can buy bank CD’s and banks can invest in short term loans vs securities if the Fed so desires.

Problem is the Fed doesn’t know how to get from here to there.


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