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Giorgio Barba Navaretti

Giorgio Barba Navaretti is Professor of Economics at the University of Milan, Distinguished Visiting Faculty at Sciences Po, Paris, Research Fellow of CEPR and Scientific Director of the Centro Studi Luca d’Agliano.

He serves as President of the Collegio Carlo Alberto Foundation and sits in the Board of several corporate foundations.

He is or has been a consultant for many international organisations, including the European Central Bank, the World Bank, the OECD and the European Commission and for Italian public institutions like the Bank of Italy and the Ministry of Foreign Affairs.

He is a non-executive director of Aon Italia and Fideuram.

He is specialised in international and development economics. He has been working extensively on the economics of multinational firms, on firms’ dynamics and competitiveness and on several international economic policy issues. He has a PhD in Economics from Oxford University and a Degree in Economics from Bocconi University in Milan.

He published many papers in key international academic journals and books, including Multinationals in the World Economy with Anthony J.Venables (Princeton University Press; in Italian Le multinazionali nell’economia mondiale, Il Mulino ) and Made in Torino? Fiat Chrysler e il futuro dell’industria, Il Mulino.

He is a columnist for Il Sole 24 Ore and Editor of “European-Economy. Banks Regulation and the Real Sector”.

Central Banks Digital Currencies: Necessary, Multitasking Policy Instruments?

November 14, 2024 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

Authors

Giorgio Barba Navaretti[1]University of Milan., Giacomo Calzolari[2]European University Institute. and Alberto Franco Pozzolo[3]Roma Tre University.

 

1. Introduction

A large number of initiatives are underway to introduce Central Bank Digital Currencies (CBDCs). Currently, 134 countries, representing 98% of global GDP, are exploring a CBDC, 68 countries are in the advanced phase of exploration and the Bahamas, Jamaica and Nigeria have fully launched a CBDC. In the Numbers section, we map the level of advancement of CBDC projects by country.

Implementing a CBDC entails the digital extension of a currency issued by a sovereign central bank, alongside establishing a digital payment system utilizing this digital currency.

CBCDs are multi-tasking policy tools addressing a wide range of objectives. In the section on institutions, where we briefly summarize many of such initiatives, it emerges clearly that the goals pursued by central banks vary in emphasis and importance depending on the issuing country. These objectives can be distilled into five primary goals: (i) safeguarding monetary sovereignty and ensuring the effectiveness of monetary policy; (ii) maintaining financial stability; (iii) curbing the market power of private entities in digital payments; (iv) protecting the privacy and security of transactions; and (v) promoting the interoperability of payment systems.

CBCDs imply direct public interventions in activities otherwise carried out by private sector players, e.g., digital money (i.e., cryptocurrencies and stablecoins) or carrying out payments (e.g., Visa and Mastercard). Consequently, they affect market configurations, turning them into mixed oligopolies. Mixed oligopolies are characterized by the co-existence of private and public players where the action of public ones, by pursuing other than typical market objectives, should, in principle, favour the achievement of socially optimal outcomes. These outcomes are usually also pursued and continue to be pursued through traditional instruments like regulation, supervision, or competition policies.

Therefore, it is useful to discuss CBDs with respect to the market failures they aim at mending and to the effectiveness of their mending action compared to other alternative

public policy tools. In this editorial, we will follow this approach and rely on the many valuable insights from the articles collected on this issue of European Economy.

We conclude that if we consider each objective individually, there are no compelling arguments for CBDCs being superior to other policy tools. Nonetheless, as discussed, CBDCs can address multiple objectives at the same time. While CBDCs might not be the most effective tool for achieving specific individual goals, their effectiveness lies in the broad range of outcomes they can deliver. Moreover, they do not replace standard oversight, supervision, and anti-trust policies, possibly reinforcing their impact.

In addition, CBCDs also imply snowball effects. If they are accepted, used by market players, and rapidly spread (which is not a small if, as discussed below), they will be hardly reversible. This is not the case for all other policy tools that might achieve the same objectives, especially if they take the form of ex-post market interventions like competition policy and antitrust. Consider, for example, the impact CDBCs have on fostering competition. By directly changing market configurations into mixed oligopolies, they will not suffer the problems of potentially weakening and reverting the actions of competition and regulation authorities: capture, limited information, and partial commitment.

Nonetheless, it is important to acknowledge the significant costs associated with implementing and maintaining CBDCs, which warrants further detailed analysis. Although proper estimates are lacking, a CBDC entails fixed and variable costs across several key categories, including infrastructure (most likely in the order of billions of euros for the case of a European CBDC), operations and maintenance, regulatory compliance, and public awareness.

As thoroughly discussed in this number of European Economy, the design of digital currencies also involves broader policy issues, especially for activities where a sizeable role of private agents may have other implications than pure market efficiency. For example, the issuance of digital coins by private organizations like the big digital platforms – e.g., Libra by Facebook, although it was never introduced – or the diffusion of cryptocurrencies may limit the scope and the effectiveness of monetary sovereignty by central banks, which is, of course, a matter of concern, with inherent risks for financial stability.

There are also considerable geopolitical issues. A first mover in the CBDC space could rapidly expand its influence and secure a dominant position in global payment systems. This dominance could, in turn, diminish the usage and relevance of other national currencies in international transactions and financial markets. This prospect is especially meaningful for currencies currently enjoying a central role in global finance, such as the US dollar and the euro. The digitalization of such currencies might favor a marginalization of national currencies in smaller jurisdictions. Or, in contrast, their dominance could indeed be challenged by other rapidly spreading digital currencies.

A key example of this geopolitical dynamic is the growing concern over the expansion of China’s digital yuan. As China accelerates its development and deployment

of a digital currency, it potentially positions the digital yuan to become a preferred medium of exchange in international trade, especially within regions heavily influenced by Chinese economic activity, such as Asia and parts of Africa. If the digital yuan were to gain widespread acceptance, it could challenge the dominance of the U.S. dollar and the euro in global trade and finance. This scenario alarms the U.S. Federal Reserve and the European Central Bank (ECB), threatening to erode their monetary sovereignty and influence in global markets (see Angeloni and Holden in this issue).

The geopolitical question appears especially relevant from the Euro area perspective, where there is limited interoperability across borders between national market players, and essentially, non-European payment providers carry out the large majority of digital and card payments. Of course, there is an argument for market dominance, especially in a market with sizeable network externalities. Still, several EU official documents and Giovannini on this issue stress that the Euro area faces considerable risks regarding data privacy and regulatory compliance because the dominant players are non-European. In this case, the argument for preserving a large degree of sovereignty in payment systems is based on security concerns rather than arguments of market efficiency.

Summing up, while we disagree that CDBCs are a solution in search of a problem – because the issue of the potential diffusion of unregulated private moneys in a world where payments are mainly electronic is evident and substantial – nevertheless, whether they are the best or only solution to these problems remains an open question that requires careful consideration and further debate.

In what follows, we will outline the main conclusions emerging from this issue, discussing the role of CDBCs in mending the market failures related to the five policy objectives above, and we will also take up other broader issues not being covered by this frame of discussion. We start with examining the impact on the effectiveness of monetary policy, then on competition, and finally, on security and privacy. Before concluding, we will briefly consider the specificities of the case for a digital euro.

 

2. Monetary Policy

One of the main reasons urging central bankers to consider the introduction of a CBDC is the increased competition from private digital currencies. When at the 2019 IMF meetings, Facebook presented its plan for creating a digital currency (initially called Libra and eventually renamed Diem in 2020), the reaction of central bankers was rather fierce. As Davies (this issue) recalls, Benoit Coeuré, a member of the executive committee of the ECB, “described the Libra announcement as ‘a wake-up call’ and called for the ECB to ‘step up its thinking on a central bank digital currency.’”

Indeed, introducing a CBDC can enormously affect the functioning of monetary and financial markets. However, these effects need to be analysed in terms of how the monetary and financial markets would evolve without a CBDC, not how they work now.

In the following paragraphs, we will compare a scenario with a CBDC to the alternative of allowing an increasing role for private moneys, absent a CBDC.

The vast majority of payments are made today using bank money, a form of highly regulated private money. In the current system, private interbank relationships, in which banks regulate their positions by lending and borrowing bilaterally, coexist with payments made by transferring the reserves held at the central bank, which are central-bank liabilities. As shown during the global financial crisis, this dual system was crucial to allow payments through the central bank when the interbank market collapsed.

Because of recent technological innovations, a new realistic perspective has opened up whereby less-regulated private moneys might substitute bank money as the most widely used means of payment. If this were the case, the issuance of money might eventually escape entirely the control of monetary authorities, taking the system back to something similar to a ‘technologically-updated’ Free Banking Era, like the one in place in the United States between 1837 and 1863, in which private banks where issuing their currencies backed by their reserves.

Would this be a problem for the functioning of monetary and financial markets? How should such a system be regulated? Would regulation be sufficient, or would it be preferable to introduce a CBDC, creating a mixed oligopoly in the payment market, with the central bank competing with private money?

To answer these questions, let’s start with the pivotal activity of central banks, maintaining price stability. The Free Banking Era was characterized by a lack of centralized regulation and high variability in the quality and trustworthiness of different banknotes. This led to frequent bank runs and a high degree of price volatility. Due to the lack of a central authority regulating money supply, private banks often over-issued notes relative to their gold reserves, causing inflationary pressures when confidence in a particular bank’s notes waned.

An alternative and less fully market-oriented option was in place in Scotland between 1716 and 1845, where several banks issued their own notes in a competitive banking environment, coupled with prudent regulatory oversight, without causing significant price instability. Scottish banks were required to hold sufficient reserves and were subject to frequent audits, which helped maintain confidence in their notes. The competitive nature of the banking system incentivized banks to preserve the value of their currency, leading to a relatively stable monetary environment.

All in all, when private entities issue money in an unregulated environment, the overall money supply can increase rapidly, leading to inflationary pressures. But if reserve requirements for private issuers are enforced, private money retains its value and is therefore accepted and trusted, thus enhancing liquidity and facilitating transactions, with a potentially stabilizing effect on prices.

Transparency in issuing and managing private money is crucial for sustaining public trust. Equally important is the protection of consumers, ensuring they have access to clear, reliable information about the private currencies they utilize and are safeguarded

against fraud and financial loss. Regulators can uphold these standards by enforcing disclosure requirements and obligating private issuers to publish financial statements and details of their reserve holdings regularly. Additionally, regulatory bodies can establish rigorous auditing procedures to ensure compliance with regulations, enabling the early detection and resolution of potential issues before they become significant problems.

Regulating the conduct of market participants can also prove essential for preventing manipulative practices that can destabilize prices, curb speculative trading, and avoid market manipulation and insider trading, which can lead to volatile price swings. The global nature of many private moneys, particularly cryptocurrencies, also requires strong international coordination among regulatory bodies. International regulatory standards should be established to ensure consistent oversight and enforcement across different jurisdictions. Such coordination can prevent regulatory arbitrage, where issuers move to less regulated environments, and ensure a stable global financial system (a theme crucial in the reaction to Facebook’s Libra project).

It appears that strong regulation and supervision of private money issuance can guarantee the system from the risk of price instability. Interestingly, this seems to be the approach followed in the recent Markets in Crypto-Assets Regulation (MiCAR) approved by the European Parliament and the Council of the European Union in April 2023. MiCAR is very stringent for issuers of money-like instruments, particularly stablecoins, which promise to maintain a stable value by referencing a fiat currency. Issuers of stablecoins must be authorized, meet specific prudential requirements in terms of capital, governance, and risk management procedures, maintain a reserve of assets that fully back the value of the issued stablecoins, and guarantee the right of holders to redeem the stablecoin at par value, promptly and straightforwardly. This approach is very similar to an adaptation to private money issuers of the existing fractional reserve banking system, where commercial banks are indeed intensely supervised and regulated.

Given this potential option of tightly regulating private moneys, how should we consider a mixed oligopoly framework stemming from introducing a CBDC and hence expanding the scope of central bank liabilities to retail payments? A digital form of central bank-issued money, a CBDC would provide a safe, efficient, and most likely widely accepted medium of exchange. This would create a new competitive market environment where a CDBC would coexist with private moneys such as stablecoins. The competition with CDBCs may drive private issuers to improve the quality of their offerings, potentially enhancing stability and usability. In fact, introducing CBDCs would reduce the demand for private moneys unless they provide levels of credibility and stability like those associated with the currency issued by the central bank, thus mitigating risks for price stability.[4]To avoid fragmentation in the monetary system if multiple forms of money coexist it would nonetheless be required to implement a clear regulatory framework which favours interoperability among … Continue reading

Interestingly, in this respect, we should not consider CBDCs as alternative policy tools to regulatory frameworks like MiCAR or supervisory and auditing frameworks for private currencies. But essentially as additional and complementary tools toward the goal of price stability, reinforcing the action of these other standard forms of regulation and supervision. A mixed oligopoly in itself would probably not be sufficient to achieve price stability, as far as money holders would also have the option to use unregulated means of payment.

CBDCs may also bring additional benefits for monetary policies (see Infante et al., in this issue). They can enhance the effectiveness of monetary policy by providing central banks with direct tools to influence the money supply and interest rates (that might eventually also be negative), helping maintain price stability more effectively than traditional monetary policy tools. CBDCs can also facilitate more accurate and timely data collection on economic activity, enabling central banks to make more informed decisions and respond more quickly to economic shocks (Bindseil, 2020; Kumhof and Noone, 2018).

CBDCs can also give central banks greater oversight and control over the digital currency landscape. By monitoring and regulating transactions into and out of CBDCs, central banks can ensure better compliance with monetary policy and financial stability objectives. In this respect, the evidence from Figure 3 in the Numbers section is consistent with the observation that CBDC projects are more advanced in countries where central banks are not encumbered by potentially conflicting responsibilities in banking supervision.

 

3. Financial stability

A key element in the debate between regulating private currencies and introducing a CBDC is their potential impact on financial stability and the overall functioning of financial markets.

The argument is the same as for price stability. It all depends on the quality and pervasiveness of regulation and supervision and on the ability of authorities to enforce prudential behaviour. Even here, CBCDs, by acting directly in the market, can be useful complementary tools to enforce and induce prudential market behaviour especially during times of stress or uncertainty.

There is, however, a further twist in the argument: bank disintermediation. In other words, even though it is very likely commercial banks will manage them, still CBDC wallets will be central banks’ liabilities. If there will be a sizeable shift from commercial banks to central bank accounts, this will imply a disintermediation of the banking system. Of course, this can also occur with cryptos, but given the safer nature of central banks-backed assets, their effect could be especially large. This is consistent with the broad evidence of Figure 4 in the Numbers Section, showing that CDBC projects are more advanced in jurisdictions with lower bank concentration.

The issue is even more relevant in the case of bank runs. If people can quickly and easily transfer their funds from banks into CBDCs, the convenience and speed of digital

transactions could make this process ‘one click away.’ Any sign of instability in the banking sector could lead to a massive shift of funds to CBDCs, precipitating a bank run (see Davies in this issue and Williamson, 2022).

The extent of this potential risk crucially depends on the specific architecture of each CBDC and particularly on the size of available CBDCs. If, as in the plans for the Digital Euro available, CBDCs wallets will be capped, this will limit both the likelihood of bank runs. But also, as argued by Davies in this issue, also the scope of digital currencies.

In extreme scenarios, if banks’ disintermediation really happens, this might considerably endanger financial stability, although it is probably safer if central banks rather than private players enact disintermediation. In the former case, at least, central banks have margins to put in place remedial measures.

There is a counterargument, though; this is also pretty extreme. Banks would perform less maturity transformation, thus strengthening their financial safety (see Infante et al., this issue, and Keister and Monnet, 2022). The final impact would be to transform commercial banks into investment banks. Would the system be more stable? Hard to say. What is sure is that in designing digital currencies, Central banks must carefully evaluate their impact on the banking system.

Given the fast technological evolution in payment technologies, can we conclude that CBDCs are necessary for central banks to guarantee price and financial stability? As argued, it is hard to say in both instances. Certainly, their interplay with other standard regulatory tools is essential in determining their final effect. Although stringent, effective, and coordinated regulation might be sufficient to guarantee a monetary anchor, the regulatory and operational architecture of a CBDC can be a powerful tool to strengthen its efficacy in reaching these goals. Indeed, if we see the relationship between regulatory authorities and market players as a game, where the former try to achieve a policy objective and they may be willing to circumvent regulations in their aim at profit maximization, having devised a reliable CBDC project, even without fully implementing it, can be a powerful tool to make the threat of regulation more credible.

 

4. Market outcomes and market power

By offering a CBDC, central banks can provide a public alternative to private digital payment solutions, possibly promoting competition and preventing excessive market power by private entities. Again, also here the evidence of Figure 4 in the Numbers session of the inverse correlation between concentration in banking markets and the advancement of CBDCs projects is consistent with this presumption,

This is particularly relevant for two reasons. First, cash cannot be used in the ever-expanding digital commerce. This calls for a corresponding evolution in payment systems for central banks to preserve their role in the monetary ecosystem, as discussed above (see also Dhamodharan et al. and Giovannini in this issue).

Second, payments are typically characterized by network externalities, significantly influencing market outcomes. Network externalities occur when the value of a product or service increases with the number of its users. In the context of digital payments, this means that as more people and businesses adopt a particular digital currency or payment platform, the more valuable and indispensable that platform becomes (Dhamodharan et al., Davies and Giovannini, in this issue, and Zeno-Zenkovich, 2023). This creates a self-reinforcing cycle where the most widely adopted digital payment solutions dominate, potentially leading to winner-take-all or tipping markets. Such markets can result in monopolistic control by a few private entities, stifling competition and innovation, as mentioned in Dhamodharan et al. (in this issue). This phenomenon can be seen in the dominance of major credit card networks like Visa and Mastercard and worldwide digital payment platforms like PayPal and Alipay in China, which have established significant market power due to widespread adoption.

Although network externalities and excessive market power can be dealt with ex-ante regulation and ex-post market intervention, such as the antitrust actions, introducing a public CBDC can mitigate the risks associated with these network externalities by offering a CBDC as a government-regulated alternative. Doing so limits the risk of market dominance by private digital currencies, ensuring a more competitive landscape. This environment can prevent any single entity from monopolizing the digital payments market, a common outcome in digital markets characterized by strong network effects, as mentioned by many authors in this issue.

Such a market structure with private operators coexisting with a public actor is known in the Industrial Organization literature in economics as a mixed oligopoly. It has the specificity of combining firms that maximize profits and the publicly controlled actor also aiming at other objectives. Specifically, in a mixed oligopoly within the digital payments market, a public or directly regulated digital payment provider, such as a CBDC, would operate alongside private providers. The CBDC’s objective could be to maximize consumer surplus while private providers would continue to maximize profits. This structure can create a balance where the public CBDC exerts competitive pressure on private entities, compelling them to lower costs and improve services, including price stability, to remain competitive.

By reducing reliance on private payment providers and increasing competitive pressure in the digital payments market, including banks, CBDCs can lower transaction costs, making payments more affordable for consumers and businesses. In other words, CBDCs can reduce the market power of banks and payment providers, transforming economic rents into consumer surplus and enhancing allocative efficiency.

The actual competitive pressure of a CBDC on private operators will depend on two relevant dimensions. First, it will depend on users’ interests and preferences for different digital payment solutions. It can be anticipated that if a CBDC is offered to citizens at little or no cost, and its acceptance by merchants is made compulsory, as seen in many current and planned implementations, this competitive pressure would likely become significant. Also, it is important to recognize that, at least within the ECB’s scheme, public and private operators will not solely function as competitors by introducing a CBDC. They will also engage in distinct yet vertically integrated operations, with Payment Service Providers (PSPs) delivering the payment service at the final point of interaction.

This vertical integration introduces an additional layer of complexity that is often overlooked. From the perspective of the economics of vertical integration in regulated markets, this arrangement raises questions about whether introducing a CBDC could effectively put pressure on PSPs and credit card companies to lower their fees, thereby enhancing competition and reducing costs for end users. A publicly provided CBDC may not automatically lead to reduced fees in vertically integrated markets unless a clear mechanism or regulatory framework compels PSPs and credit card networks to pass on cost savings to consumers. This interplay between competition and vertical integration in the context of a CBDC necessitates further investigation to understand its potential impact on pricing dynamics and market efficiency.

Another potential effect of CBDCs is their impact on innovation. The hybrid model of a mixed oligopoly leverages the strengths of both types of actors, private and public, ensuring that the public’s need for secure and affordable payment methods is met without stifling private sector innovation. The presence of a public player in the digital payment industry can push private providers to innovate more intensively to maintain their market positions. Although the economic literature on innovation in mixed oligopolies is limited, and the relationship between innovation and competition is complex, the increased competitive pressure induced by a CBDC may indeed foster innovation. Private entities must develop new features, improve user experiences, and enhance security measures to compete effectively with a government-backed digital currency. This environment can lead to a more vibrant and innovative digital payment ecosystem, ultimately benefiting consumers and businesses.

To summarize, considering market power, CBDCs have the potential to significantly alter the landscape of digital payments by reducing market power, lowering costs, enhancing financial inclusion, and fostering innovation. Central banks can ensure a more competitive and equitable financial system by introducing a public alternative to private digital payment solutions, addressing current market inefficiencies and future challenges in the evolving digital economy. Given the economic analysis of mixed oligopolies, several market outcomes can be anticipated. First, with the CBDC providing a low-cost alternative, private providers must reduce their fees and offer better services to remain competitive, thus increasing consumer surplus. Consumers benefit from lower transaction costs and improved service quality.[5]Clearly, the design of a subsidized CBDC must carefully consider the risk that private providers could be pressured into lowering their fees to the point of being driven out of the market. This could … Continue reading Second, the competitive pressure from the CBDC can drive private entities to innovate extensively, introducing new features, improving user experiences, and enhancing security measures. This environment fosters a more vibrant and technologically advanced payment ecosystem. Third, the CBDC can enhance financial inclusion by providing accessible digital payment services to unbanked and underbanked populations, ensuring more people can participate in the digital economy. Lastly, the central bank’s dual role as provider and regulator ensures that the digital payment market remains fair and competitive, with stringent oversight preventing abuses of market power and ensuring consumer protection.

But is a CBDC necessary to reach these market outcomes? Why would addressing the specific issues for digital payments require a new public digital payment like a CBDC? Why can it not be obtained with regulation of the existing digital payment means? In principle, similar outcomes can be obtained with regulations. This happened, admittedly with significant delay, in the digital markets and the European regulations, Digital Market Act (DMA) and Digital Service ACT (DSA).

The digital payments landscape is rapidly evolving, and central banks worldwide are grappling with whether to introduce CBDCs or enhance the regulation of existing private digital currencies, or both.

Regulating existing PSPs offers the advantage of utilizing existing infrastructure, reducing the need for new investment and development. Private entities, driven by profit motives, can quickly adapt to changing market conditions and technological advancements, fostering a more dynamic payment ecosystem. This flexibility and adaptability encourage innovation and competition among PSPs. Regulation can also be more cost-effective than developing a new CBDC, as it avoids duplicating infrastructure and technology. It reduces the burden on the government, allowing the central bank to focus on its core responsibilities while ensuring the private sector adheres to regulatory standards. However, regulation is generally not an easy task.

However, regulating PSPs (and issuing private digital currencies) can also be less effective than creating a CBDC. A wide economic literature illustrates the primary limits of regulation: that the regulator is typically less informed than the regulated entities, the risk of regulatory capture, and limited commitment to regulation. Establishing and enforcing comprehensive regulations for numerous private entities can be complex and resource-intensive. Ensuring compliance across different jurisdictions and legal frameworks can be challenging, requiring substantial coordination and oversight. In particular, interoperability between different private payment networks may become an issue, stifling market entry and competition. A regulatory framework should ensure that various payment schemes can interact seamlessly with each other to enhance competition and liquidity and stability in the financial system. The risk is that ineffective regulations stifle competition and innovation in the payment systems.

Overall, if not correctly administered, dominant PSPs might still exercise significant market power, leading to monopolistic behaviours. Ensuring a level playing field among private entities requires continuous and vigilant regulatory oversight to prevent abuses of market power. In this respect, even in this domain of market competition CBDCs can integrate and strengthen regulators’ action.

 

5. Privacy and security

Modern private moneys, such as stablecoins and cryptocurrencies, present unique regulatory challenges due to their technological nature. Regulators should thus develop technological standards to ensure the security and stability of private money systems, including enforcing protocols for secure transactions, preventing hacking and fraud, and ensuring the robustness of the underlying blockchain technology.

The security issues associated with CBDCs encompass a range of concerns due to the public and centralized nature of CBDCs. Key risks include vulnerabilities to cybersecurity threats, such as hacking and digital theft. These are common to all digital financial systems but are especially critical for CBDCs, as they could become a high-value target for attacks, unlike more fragmented private digital money systems. Similar problems would also affect private digital money, which, for this reason, is subject to increasing levels of oversight by regulation authorities. In this case, too, the optimal solution depends on the trade-off between the risk of a fully centralized system managed by public authorities and several decentralized private systems under the oversight of regulatory authorities.

Privacy concerns are also central to the discussion surrounding both private digital currencies and CBDCs. While both forms of digital money raise significant privacy issues, the nature and implications of these concerns differ between the two.

With private digital currencies, the regulatory landscape is primarily concerned with accessing and using private information generated every time a digital payment is made. As these transactions involve releasing sensitive data, there is a pressing need for regulatory frameworks that safeguard user privacy. In the European context, the approach taken by authorities, mainly through the Second Payment Services Directive (PSD2) and the Digital Market and Digital Services Acts, has been to regulate the use of private information rigorously. These regulations ensure that private digital currencies operate within a framework that protects consumer data from misuse and promotes transparency and accountability among service providers.

Although private operators, particularly dominant non-European players like Visa, Mastercard or Paypal are required to comply with the regulations of the jurisdictions in which they operate, which mitigates some risks, there is a broader concern, often articulated especially by European authorities, about the reliance on foreign providers, specifically concerning privacy risks, also reflecting geopolitical anxieties regarding dependence on foreign technologies. In this context, the privacy risks are less about non-compliance and more about the strategic implications of data control by foreign entities.

CBDCs, on the other hand, introduce a different set of privacy concerns, primarily because they are state-backed and centrally managed. One of the most significant privacy issues with CBDCs is the potential erosion of user anonymity. Cash transactions are inherently anonymous, while CBDCs may not be able to offer the same level of privacy. Although CDBCs, notably the digital euro, could potentially incorporate offline functionality with privacy levels comparable to cash, as emphasized by Giovannini in this issue, achieving this result is complex, as the design of a CBDC must also meet regulatory requirements for traceability to prevent illicit activities. The challenge lies in offering ufficient privacy protections while ensuring the system is not exploited for criminal purposes. In this respect, it is somehow of concern that the most advanced CBDC projects have been developed in countries where central banks are less independent, which mostly happens where the form of government is not fully democratic (see Figure 2 in the numbers section)

The traceability of transactions in a CBDC system raises significant concerns. In this issue, Davies warns of the potential emergence of a “Surveillance State,” where central banks could excessively monitor consumer spending patterns, encroaching on personal privacy—a point also addressed by Holden. However, we believe this concern is equally relevant for private digital currencies, depending on their design and the degree of transaction privacy they offer.

In this case it is crucial to analyze privacy concerns against the correct counterfactual. While it might be technically impossible to guarantee the same level of anonymity with a CDBC as with cash, most transactions are already digital and are traced, recorded, and stored by private PSPs. Regulation on the treatment of these data is rather heterogeneous worldwide, and all privacy concerns characterising CDBC transactions extend to transactions with private moneys. Once again, the optimal solution must trade off decentralization under regulatory oversight with centralization under public authorities, with different degrees of attention depending also on how much the state might be able and willing to use this information for coercive purposes (on the matter, see also Holden, in this issue).

Finally, cross-border data privacy presents significant challenges for both private digital currencies and CBDCs. The complexities involved in ensuring privacy across diverse regulatory environments are particularly acute for CBDCs, given their potential for international use (Giovannini in this issue). Private digital currencies already navigate these complexities. However, a state-backed CBDC would need to reconcile these issues on a potentially more significant scale, involving diplomatic and regulatory coordination across jurisdictions.

 

6. A European case for CBDC?

While the previous discussion aimed at covering all the main pros and cons of introducing a CBDC, the case of the digital euro has some specificities of its own, due to the fact that it refers to a currency adopted by different countries that are part of a monetary union with not-fully-integrated financial markets.

The pressing concern within the Euro area is the fragmented state of its payment systems, which remains surprisingly disjointed despite the existence of a single currency, a single market, and an almost completed banking union. The limited expansion of sizeable European players in payment systems and the lack of a seamless, integrated payment landscape have significant implications for the region’s financial efficiency and sovereignty. Currently, the effective interoperability of payment systems in Europe largely depends on non-EU-based credit cards, such as Visa and Mastercard, which account for 46% of all payments, and other e-payment solutions like PayPal. This reliance on non-European providers is a major concern for the European Central Bank (ECB), as it not only undermines the efficiency and increases the cost of cross-border payments but also exposes the Euro area to risks related to data privacy and regulatory compliance, as argued by members of the executive committee of the ECB (e.g., Cipollone, 2024) and by Giovannini in this issue.

The fragmented payment landscape in Europe starkly contrasts the ideals of the single market and of the banking union. Although the Single Euro Payments Area (SEPA) has facilitated cross-border credit transfers and direct debits since its implementation in 2002, there remains a significant gap in the unification of payment systems at the point of interaction, particularly for digital and person-to-person payments. This is due to the lack of technological solutions that make national payment networks interoperable among themselves, a solution that is instead being offered by the Eurosystem through TARGET in the case of interbank transactions. Of course, incentives to provide these solutions were different since TARGET was essential to guarantee a smooth transmission of monetary policy decisions, while the unification of the national payment systems was less of a concern, more so at a time when electronic payments were not as common as today.

Since 2002, several steps have been undertaken by the Eurosystem to foster the interoperability of payment systems. In 2017 the SEPA instant credit transfer (SCT Inst) scheme was launched, allowing the provision of instant payment clearing services by a number of European automated clearing houses, and the TARGET Instant Payment Settlement (TIPS) service in 2018. These schemes allow for instant payments from bank accounts across the euro area. They might, therefore, be used to make electronic payments at any point of interaction, including a shop or an online transaction, for example, through NFC and QR code recognition. However, these technologies were scarcely adopted by PSPs and are not diffused among merchants and consumers.[6]See the ECB’s document. Strengthening the use of TIPS is one of the pillars of the payments strategy of the Eurosystem, complementary to the digital euro.

Interestingly, with the acceleration of the digital euro project, some private sector initiatives have been recently launched. For instance, digital mobile payment frameworks are being developed through collaborations between entities like SIBS in Portugal, Bancomat in Italy, and Bizum in Spain. Additionally, the European Payment Initiative (EPI), spearheaded by central banks in France, Germany, Belgium, and Spain, aims to create a European-based instant payment solution. Remarkably, the EPI plans to leverage the SEPA instant credit transfer scheme and existing infrastructures like the Eurosystem’s TARGET Instant Payment Settlement (TIPS), offering a payment network and a wallet with NFC and QR code capabilities. This seems to mirror the evolution of EURO1, a private sector large-value payment system for single same-day euro transactions at a pan-European level that leverages on TARGET and has been developed by EBA-clearing, a partnership of several large European banks.

In principle, instant payments can provide a reliable alternative to private money for electronic payment. Representing bank money transfers provided by regulated PSPs would create no problems for the conduct of monetary policy and price stability. In fact, this technology is largely used for electronic payments at the point of interaction in China. However, the question remains whether these private sector initiatives can achieve the level of interoperability and integration needed across the Euro area.

And how will they be affected by the introduction of the digital euro? Will it strengthen the interoperability of payment systems across the Euro area borders through its design and implementation more effectively and rapidly than simply enacting policies supporting private sector projects like the EPI? And, in case all projects evolve together, will they be complementary, or will they compete with each other, possibly creating costly redundancies?

In any case, even with the introduction of the digital euro, the role of the private sector in European payments will remain crucial. The ECB’s design for the digital euro foresees a strong role for private PSPs managing digital euro accounts and transactions, including responsibility for identification and possible frauds. According to the project, digital euro wallets will be linked to traditional bank accounts, creating a significant connection between the digital euro and the services PSPs provide in facilitating payments at the point of interaction.

The backing of the ECB fuels a pervasive action, more than any private sector operator could achieve, to address key barriers to interoperability, such as networks. It could, for example, make it mandatory for sales points to offer payments through digital euros. Moreover, by combining payment services with private providers, the ECB could help establish a unified regulatory framework, thus overcoming some of the major impediments that have hindered interoperability to date.

Still, as Dhamodharan argues in this issue (from the perspective of one of the incumbent market players), the success of the digital euro will ultimately depend on whether consumers and businesses perceive additional benefits compared to existing digital solutions already available or those that the market could potentially develop. A key aspect that seems to be overlooked in the debate is the effectiveness of the digital currency from the users’ perspective. If alternatives to the digital euro offer a better user experience to make electronic payments, its diffusion will be smaller. As recalled by Angeloni (in this issue), in China, in the last year for which data are available, transactions per second in digital Yuan were 0.02% of those performed by Alipay alone.

The ECB also pursues a geopolitical issue in addressing the Euro area payment systems. As argued above, in several official documents of the Bank, there emerges a concern that presently, the interoperability of payment systems across the Euro area is provided to a very large extent by non-European operators like VISA and Mastercard. This, of course, raises concerns about compliance with European standards and regulations, including worries for security and privacy. But frankly, even concerning this issue, it is unclear why such concerns could not be addressed more effectively through adequate regulation and supervision. Especially given that interoperability is effectively granted by these operators, although in a framework of excessive market dominance, as discussed earlier.

In summary, the argument that a digital euro is essential for establishing an effective pan-European payment system due to the market’s failure to deliver one is, in our view, somewhat weak on its own. It remains uncertain whether market-driven initiatives, such as the European Payments Initiative (EPI), could ultimately offer viable solutions. Moreover, these goals might be achievable by enforcing a unified regulatory framework across the Euro area or by strengthening the Eurosystem’s oversight framework for electronic payment instruments, schemes, and arrangements (PISA). In any case, addressing the current shortcomings of the Euro area’s payment systems will require tackling key issues such as interoperability, regulatory fragmentation, market power, and user experience, regardless of whether a digital euro is introduced.

 

References

Angeloni, I. (2024). Digital Euro: Catching Up and Browsing the Daisy. European Economy: Banks, Regulation, and the Real Sector, 2024(1): 1-9.

Bindseil, U. (2020). Central Bank Digital Currency: Financial Stability Implications. Working Paper Series No. 2350, European Central Bank.

Chiu, J., and Keister, T. (2022). The economics of digital currencies: Progress and open questions. Journal of Economic Dynamics & Control, 142, 104496. https://doi.org/10.1016/j.jedc.2022.104496

Cipollone, P. (2024). Innovation, Integration and Independence: Taking the Single Euro Payments Area to the Next Level. Speech at the ECB conference on “An Innovative and Integrated European Retail Payments Market,” Frankfurt, 24 April 2024.

Davies, P. (2024). Central Bank Digital Currency: An Idea Whose Time Has Come, or a Dangerous Misstep? European Economy: Banks, Regulation, and the Real Sector, 2024(1): 10-25.

Dhamodharan, R. (2024). Mind the Gap: Assessing the Market Implications of Retail Central Bank Digital Currencies. European Economy: Banks, Regulation, and the Real Sector, 2024(1): 26-40.

Fernández-Villaverde, J., and Sanches, D. (2019). Can currency competition work? Journal of Monetary Economics, 106: 1-15.

Giovannini, A. (2024). Can a Central Bank Digital Currency Overcome Structural Barriers? The Case of the Digital Euro. European Economy: Banks, Regulation, and the Real Sector, 2024(1): 41-67.

Holden, R. (2024). We Need Fedcoin Now: The Case for a U.S. CBDC. European Economy: Banks, Regulation, and the Real Sector, 2024(1): 68-85.

Infante, S., Kim, K., Orlik, A., Silva, A. F., and Tetlow, R. (2024). CBDC: Issues and Prospects. European Economy: Banks, Regulation, and the Real Sector, 2024(1): 86-110.

Keister, T., and Monnet, C. (2022). Central bank digital currency: Stability and information. Journal of Economic Dynamics and Control, 142, 104501.

Kumhof, M., and Noone, C. (2018). Central Bank Digital Currencies — Design Principles and Balance Sheet Implications. Bank of England Working Paper No. 725.

Williamson, S. D. (2022). Central bank digital currency and flight to safety. Journal of Economic Dynamics and Control, 142, 104146.

Zeno-Zencovich, V. (2023). Digital Euro as a Platform and Its Private Law Implications. Media Laws-Law and Policy of the Media in a Comparative Perspective – n. 2/2023, Available at SSRN: https://ssrn.com/abstract=4567354 or http://dx.doi.org/10.2139/ssrn.4567354.

Footnotes[+]

Footnotes
↑1 University of Milan.
↑2 European University Institute.
↑3 Roma Tre University.
↑4 To avoid fragmentation in the monetary system if multiple forms of money coexist it would nonetheless be required to implement a clear regulatory framework which favours interoperability among different means of payment.
↑5 Clearly, the design of a subsidized CBDC must carefully consider the risk that private providers could be pressured into lowering their fees to the point of being driven out of the market. This could shift the market from a mixed oligopoly to a public monopoly, ultimately negating many of the intended benefits of a CBDC.
↑6 See the ECB’s document.

Filed Under: 2024, From the Editorial Desk

Open Banking’s Promise of a Financial Revolution: Are We Falling Short?

April 18, 2023 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

Authors

Giorgio Barba Navaretti[1]University of Milan., Giacomo Calzolari[2]European University Institute. and Alberto Franco Pozzolo[3]Roma Tre University.

 

1. Introduction

Information is the main character in open banking (OB), which is about opening to third parties the access to information that is otherwise captive in a bilateral relationship between the incumbent provider of financial services and the client. With the words of Rivero and Vives in this issue, OB “refers to those actions that allow third-party firms, either regulated banks or non-bank entities, to have access under customer consent to their data through application programming interfaces (API)”.

Specifically, open banking aims at creating a market for customers’ transaction data, obtained (mostly although not only) from payment information. Traditionally, these data were accessible only by the financial intermediary performing the transaction and they were rather cumbersome to transfer. This gave banks the possibility to leverage on the data and extract higher rents from the interactions with their customers. OB allows customers to easily, swiftly and freely transfer their own payment information to any authorized third party of their choice, thus changing the conditions for transactions with their financial intermediaries.

Where does OB come from? The kick start comes from regulation. In the European Union, the starting point was the approval in 2015 of PSD2, the revision of the Payment Services Directive by the European Commission,[4]Directive (EU) 2015/2366, known as PSD2, see the Institutions section below. which requires that financial institutions open up they data in favour of account service information providers (AISP), payment initiation service providers (PISP), and card-based payment instrument issuers (CBPII). In UK, PSD2 was transposed into legislation with The Payment Services Regulation of 2017, leading to the foundation in the same year of the Open Banking Implementation Entity (OBIE), an independent organisation of the 9 largest retail banks in Britain and Northern Ireland aiming to implement open banking. Similar legislations were implemented for example in South Korea and Australia, favouring the diffusion of open banking.[5]See the Institutions and Numbers sections below. Also the market itself and the entry of new fintechs can give incentives to customers to share their financial information to obtain better services, in domains beyond payments, like loans, private banking, and so on.

In general terms, the reasons for opening access to information to third parties are three. First, enhancing competition. New third-party firms can use the information about the client to offer targeted services at better terms than the incumbent. Second, to favour inclusion. Because of a decline in costs, otherwise unbanked, unfinanced individuals may have access to financial services (see Bianco and Vangelisti in this issue). Third, to foster innovation. Competition and the focus on big data and programming interfaces is expected to favor the development of new tools, apps and services.

More specifically, the preamble of PSD2 emphasized the importance of increasing competition and guaranteeing free entry and a level playing field among incumbents and new participants.[6]Paragraph (4) of the preamble recites: “(…) equivalent operating conditions should be guaranteed, to existing and new players on the market, enabling new means of payment to reach a broader … Continue reading However, and remarkably, the Directive focused almost exclusively on data about payment services. In fact, AISPs are guaranteed access only to data of payment accounts, i.e., accounts “held in the name of one or more payment service users which is used for the execution of payment transactions”. All the same, it became increasingly clear to the industry that granting access to customers’ payment information would have also eased the provision of other banking and financial services and the development of a range of innovative products. These developments were also judged positively by regulators. In this regard, it is illuminating that EBA, in reply to a question raised by the Bank of Ireland on the interpretation of the Directive, on 13 September 2019 stated that an AISP is not limited to providing the consolidated information on the different account positions to the payment service user, but with the user’s consent it can also make this information available to third parties.

This evolution towards an even broader OB is envisaged to have the potential to change financial intermediation radically. But for this to happen, two key factors must be present: first, consumers must be willing to share their data, and second, the technology must be in place to ensure seamless data access through the use of APIs and cloud computing. If these conditions are met, OB is expected to change the way financial intermediation occurs.

Yet, there are considerable limits to the diffusion of financial information and to the use of such information for the purposes of enhancing competition, inclusion and innovation. Open banking is essentially about enabling transfers of data and information to some third parties, but not making it generally available. Key to the understanding of the potential impact of this innovation with respect to the three objectives above is therefore the assessment of how information will in fact be spread and used. If we take this perspective, we believe that the scope and the aims of open banking, although potentially groundbreaking, may sometimes be overstated, and its desirable implications cannot be taken for granted.

Information, in principle, is a public good: non rival and spreadable at no (marginal) cost. It gains private value precisely when different forms of protection privacy rules), or property rights (patents and copyright) prevent it from being used as a public good. Even in the case of open banking, information has value, be it for the incumbent or for other third parties, only if it can keep being privatized, at least partly. This creates inherent limits to its complete diffusion and disclosure.

These limitations are relevant for both the supply and the demand of information. On the supply side, OB does not open information concerning a given client to everybody. The owner of the information, the client, decides whether to make it available to well-identified counterparts. Whatever the source of open banking, rules or markets, the starting point is that the client remains the sole owner of the data and information on her or his transactions. This causes an issue of selection. How many potential counterparts are clients willing to disclose their private transactions to? Possibly a small number, because of privacy and because of reluctance to disclose sensitive information. Hence the supply of information will likely be limited.

As for demand, entry of third parties in a given segment of the financial markets will be enhanced by OB only if entrants have some way of preserving at least part of the value of the information. If it were not at least partly privatized by the new third party, the information would have limited value and there would be no demand for it and, ultimately, no entry in the market. Of course, even in a world where information is fully disclosed, capable providers can leverage on freely accessible information to offer highly differentiated products, not fully in competition one with the other, and create value for themselves anyway. Yet, inevitably the value of information declines with its diffusion. Again, this sets, from the demand side, a limit to how extensively information would be spread out.

An additional issue is how the information can be effectively used, and we will discuss this extensively in the third part of this editorial. One option, as argued above, is that the information is granted by the customer to a limited number of selected counterparts. Even opening up the information to a single new provider can be beneficial to the client: compared to the incumbent, the entrant may offer new services or the same services at better conditions. Of course, as argued by several contributions in this issue, things are different if the new entrant is an established bank or a Bigtech i.e., the big digital platforms with strong and entrenched market power in (non-financial) digital markets, rather than a fintech. Still, the ability to offer new services would anyway have a positive impact on competition and innovation, and possibly, through a reduction in the cost of services, to inclusion.

A different scenario could emerge if the data were transferred to a platform, which brokers numbers of potential suppliers of financial services. The platform matches clients with services, and the information likely stays with the platform, i.e., it is not necessarily transferred to the providers of the financial services. This because the platform is the intermediary in a two-sided market and has the technology to use the information for efficient matching. The client can therefore be better off. However, as we will argue below, the platform would enjoy monopoly power and information rents.

Network externalities would also be another distinctive element of this scenario. Only platforms with a very large client base and a large number of potential suppliers can effectively use clients’ data to offer efficiently targeted services. In other words, services based on the use of data and clients’ information generate network externalities which create new monopolistic power and limit the diffusion of information, even if it is used to broker the services of many potential suppliers. The market power built on relationship-based financial intermediation with restricted data access, would be replaced by a new network-based market power with open data. We will discuss the implications of OB for competition extensively in the third part of the introduction. In the following one we first examine which type of financial services can be affected by OB.

 

2. Open banking’s products

Which financial products will be mostly affected by open banking? A distinction is to be made between the existing financial products and the new ones that may be created.

Since open banking is mostly based on sharing payment information, an obvious starting point is to look at payment services. In this respect, payment initiation service providers (PISP) – newly allowed by PSD2 – may compete with existing intermediaries to become the originators of customers’ transactions, favouring a reduction in the costs and an increase in the speed and security of payment transactions. Customers, for example, may authorize a PISP to directly charge their bank current account after their purchases on internet, while simultaneously giving the seller the guarantee that the payment is successful. Since internet purchases are typically regulated through rather expensive credit-card transactions, the benefits of having PISPs is in this case evident

However, focusing on payment services only gives a narrow perspective on how open banking can enhance competition in the market for existing financial products. The possibility of accessing customers’ transaction data will likely impact all markets where this information has value for the provision of targeted services (Fama, 1985). An obvious example is the loan market. Convincing empirical evidence shows that there are significant complementarities between offering the same client a deposit account and a loan (Mester et al. 2002). In fact, it is a common practice for banks to require clients to open a checking account when they are granted a loan. Indeed, information on incoming and outgoing financial flows can be extremely valuable to assess ex-ante the level of a borrower’s riskiness and monitor ex-post its evolution. Financial intermediaries that can access these data have, therefore, a competitive advantage with respect to their competitors, leading to a bundling of the markets for deposits and loans. With open banking, each customer can allow an AISP (account information service provider) to access his transaction data and use them to choose what it considers the best potential lender. If authorized by the payment account holder, an AISP can also make the information available to any third party of his choice. A competing bank could therefore either act as an AISP or obtain information from an AISP on the customer’s transaction data. Clearly, this would whiten the competitive advantage that banks have when granting loans to their deposit holders. The product that would benefit from increased competition made possible by open banking would in this case be traditional bank loans.

Another practice that is rather common among banks is to offer investment products to their deposit holders when they see that their balances on the checking account exceeds levels consistent with normal operativity. In this case, the customer only receives an alert on his liquidity position, and she is free to invest in products other than those offered by the bank where she holds her checking account. However, the bank that has access to the customer’s transaction data still holds a first-mover advantage with respect to potential competitors, and it also has a comprehensive view of the time evolution of the liquidity position of the customer and of its average liquidity needs. Once again, with open banking, a customer can choose to make all this information available to any provider of saving products through an AISP, therefore reducing the competitive advantage of the bank where she holds the checking account.

A parallel issue, emphasized by Redondo and Vives in this issue, is the sharing of information on other financial positions of a customer regarding his saving and investment accounts or his loans and mortgages. While this is not yet a central part of the debate on open banking, there appears to be no reason why the logic applied to transaction data should not be expanded to information on other financial positions.

But open banking is not only expected to increase competition in the markets for existing financial services but also to foster the creation and supply of new financial services. This may open the door to an entirely new business model, where banks become platforms between customers willing to make their data available and sellers of financial services and financial intermediaries willing to offer them products that are specifically targeted to their individual characteristics. While the implications of this potential revolution on the banking industry will be discussed in more detail below, new products are being developed and it is to be expected that a wide range of additional ones will be made available in the future.

At the moment, the fastest growing services seems to be those helping to connect different accounts – e.g., bank, credit cards, and investment accounts – to provide a comprehensive view of the financial position of an individual or a firm. Providers such as Emma (https://emma-app.com/), Tink (https://tink.com/) and TrueLayer (https://truelayer.com) already offer these services, and are extending their line of business in new directions. For example, some providers already offer contemporaneous access to investment platforms, including those allowing to acquire crypto assets, while others offer secure authentication for the access to all different accounts. Other services already available include those that alert customers (and possibly their authorized connections, e.g., parents of minors) when a payment is required that exceeds a given amount or a regular pattern of purchases, helping detect scams and frauds.

As discussed by Bianco and Vangelisti in this issue, an interesting set of services are those targeted to less skilled individuals to manage their finances better, helping them to avoid recurring to credit card loans when cheaper bank loans are available as alternative or alerting them when outflows are exceeding the sustainable pattern that can be foreseen based on past evolution. Indeed, if directed by adequate policies, open banking can be a powerful tool to improve financial awareness and inclusion.

The next steps are difficult to foresee, but they will likely depend on the amount of information that can be extracted from payment data. Detailed information not only on the inflows and outflows of money from an account but also on their origin and destination might allow to reconstruct the pattern of purchase of an individual, making the step towards targeted product advertisement very short. Clearly, this once again opens the Pandora box of the role of Bigtechs such as Amazon or Alibaba, that already collect this information from a different angle. The role of policy and regulation will therefore be crucial in shaping future developments.

The possible uneasiness of many customers to share information with unknown new players gives a strong advantage to incumbents. And while this may be contrasted by enacting regulations that limit access to customers’ information only to reliable and possibly supervised entities, such regulations may not be easy to implement since open banking services are offered through the Internet and may therefore come from entities based all over the world, including countries with loose or non-existent financial regulations on open banking and data protection. Indeed, an adequate balance between limitations imposed by regulation and the need to allow market access to innovative entrants is yet to be found, but certainly necessary.

The market is in rapid evolution. Emma, for example, was founded in 2010 by two computer scientists and has still managed to survive being privately owned. Tink, founded in 2012 by two independent entrepreneurs, has been fully acquired by VISA in 2022, likely planning to leverage its huge customer base. Instead, Yolt, an open banking personal finance management application offered by the Dutch bank ING that started operating in 2017, has already closed its activities.

 

3. The impact on the industry

As discussed above, the actual implications of OB, though, depend on the availability of adequate data flows. If financial customers are not interested in sharing their data or have concerns about privacy, the entire chain of consequences may not materialize. The more mature digital markets provide useful lessons, showing how platform companies successfully convinced users to give up and share their data. Many digital markets offer “freebies”, or zero-price services, such as search engines and recommendations, with monetization taking place on other sides of the market, such as advertising to digital users. This business model has pushed users to embrace the idea, consciously or not, of providing personal information in exchange for services. This could serve as a model for financial markets too, but it will require the development of a platform-based business model that, as illustrated above, would allow retaining the information with the platform intermediary, a model still to come in financial markets.

Assuming that financial consumers are convinced to share data, the question is who are the other financial operators that will receive them. Rivera and Vives, in this issue, convincingly note that if data flow reaches other incumbent operators, like traditional banks, then even if potentially competing, we may not expect significant impacts of data, with additional risks. We know that data availability may induce a “winners-takes-all” condition when companies offer multiple products and services. Again digital markets are an example with their strategies that rely on the reusability of personal data for multiple purposes and services, with an envelopment effect on customers. A realistic outcome of this data flow is a possible increase of market concentration in the hands of fewer traditional financial intermediaries, uniquely placed to offer bundles of services. They are unlikely to be challenged by platforms also offering several products and services, as they are yet to be seen in markets.

Clearly, as argued above, the flow of data mobilized by OB can also reach new players offering specialized and unbundled services, such as payment systems or lending services. Although in this case data could activate new tech players in financial markets such as Fintech, the implications on market structure and outcomes are, again, ambiguous and may not materialize quickly.

In fact, some recent papers in the academic literature (e.g. Parlour et al. (2022) on payments services and He et al. (2023) on lending) have highlighted that empowering Fintech players creates competitive pressure for traditional banks but, at the same time, can produce countervailing effects in terms of price and product discrimination and reduction of consumers’ surplus. Information is a peculiar input in financial intermediation. If the technology used by the new players to manage and elaborate information is significantly better than that of traditional players, this would enable them to segment the market and acquire the surplus of consumers of financial services. In other words, the unique nature of information as an input for financial activities can quickly generate excessive informational advantages for new entrants in terms of new services and better surplus appropriation.

Another risk could emerge when the data flow on financial transactions reaches mostly BigTech firms. These companies may extend their business envelopment and begin offering financial services (some already are, such as in China). On the one hand, this would increase competition, thus benefitting consumers of financial services. On the other hand, the strong envelopment tendency of a platform-business model should not be underestimated. We know from digital markets that these firms leverage detailed users’ information to capture users in several markets, with reinforcing feedback effect induced by even more data from the many services and products they offer. These are the consequences of strong complementarities between services and products (or indirect network externalities), reusability of data for several purposes and products, and specific properties of Artificial Intelligence algorithms employed to process these data.[7]Calzolari et al. (2023) discuss “Scale and Scope” properties of Machine Learning tools that rely on the amount of data and the diversity of data-sources and also study the implications for the … Continue reading Digital platforms have also prospered thanks to a feedback-loop mechanism where more users provide more data, allowing for better algorithms, predictions, and services, thus attracting even more users. OB has thus the potential to favor BigTech companies disproportionally and reinforce their business model with the inclusion and mutual reinforcement of financial services in their ecosystems. Interestingly, BigTech may value the flow of data originated by OB more than traditional banks for the same mechanisms described above and may be quicker and more effective in convincing financial market customers to share data with them.

Will platform-based financial operators able to bundle a variety of services emerge? It is difficult to say at this stage. They may materialize from a transformation of traditional incumbent companies, such as banks, or from BigTech entering the financial market. However, whatever the origin of this development, this could become a radically new scenario with platforms operating as matchmakers between customers of financial services and financial service providers . As a first step, the relevant data might possible refer to payments and deposits, as discussed above, possibly merging this type of information from different banking relationships. So traditional banks and AISPs are currently better placed to become financial platforms at an initial stage. However, the envelopment effects of Bigtechs should not be underestimated. In addition, “Banking as a Service” may further evolve, again under the impulse of regulation, markets and technology, into broader future developments, as it could very much involve many other financial services not only those typically related to banking. The properties of such a market configuration with broad gatekeepers are not necessarily very competitive, as the digital markets have shown and as discussed above.

Padoan, in this issue, indicates what could be effective strategies for traditional banks. Rather than insisting on traditional approaches, the quicker way into the innovation flow for traditional banks seems to be collaborating with new players (or acquiring them). However, we think this will not suffice if the platform model prevails. The changes needed for banks to transform themselves into platform operators and benefit from the network externalities that, if large, they already enjoy, are anyway deep. Offering fintech services in parallel is just one step in creating an enveloping “ecosystem” for their own products or for those of partners.

These long-run effects of OB are challenging to predict at this stage, as they combine several elements, in particular innovative technologies with consequences on screening and matching, flows of data, and business models that are new to financial markets.

In this uncertain and evolving environment, regulation should play a key role. For example, currently, in Europe, the Payment Service Directive “PSD2” only refers to data flowing to payment service providers but not to providers of other financial services, such as saving accounts, credit cards, mortgages, pensions, or insurance. Because of the implications of data flow discussed above, this limited first step into OB could be considered a wise approach. However, this is leaving much of the potential of OB untapped, and, as Dalmasso elaborates in this issue, the limited span of the directive may in itself constrain the potential broader benefits of OB. Regulation should continue to lead the development that OB will have on financial markets, also because increased competition and shifts in profitability will affect financial operators’ charter values, thus inducing increased risk-taking appetite with perilous implications for financial stability.

Currently, the promise of innovative banking platforms remains unfulfilled, as new entrants primarily focus on creating effective application interfaces rather than offering truly ground-breaking financial services. As previously discussed, the impact of OB may remain limited. However, once OB reaches full potential, it will undoubtedly reshape the financial landscape. And it will be essential to guide this process to prevent market tipping and concentrations similar to those seen in digital markets. Historically, policymakers believed that ex-post interventions would suffice to address market power issues in digital markets. However, as we have learned from experience, this is not the case, and regulators have had to catch-up with new regulations like the Digital Market Act (DMA) and the Digital Service Act (DSA). In the case of financial markets, proactive regulation will be crucial to avoid a similar scenario of late intervention. To achieve this, it will be useful to learn from the lessons of digital markets while creating regulations tailored to the unique characteristics of the financial industry. The challenge will be to strike a balance between regulations like DMA and DSA, coexisting with those designed explicitly for financial markets.

 

References

Calzolari G., Cheysson, A., and R. Rovatti (2023) “Machine Data: Market and Analytics”. SSRN, CEPT and European University Institute working paper.

Fama, E. F. (1985). “What’s different about banks?”. Journal of monetary economics, 15(1), 29-39.

He, Z., Huang, J., and Zhou, J. (2023). “Open banking: credit market competition when borrowers own the data”. Journal of Financial Economics, 147, 449-474.

Mester, L. J., Nakamura, L. I., and Renault, M. (2007). “Transactions accounts and loan monitoring”. The Review of Financial Studies, 20(3), 529-556.

Parlour, C. A., Rajan, U., and Zhu, H. (2022). “When Fintech competes for payment flows”. The Review of Financial Studies, 35, 4985-5024.

 

Footnotes[+]

Footnotes
↑1 University of Milan.
↑2 European University Institute.
↑3 Roma Tre University.
↑4 Directive (EU) 2015/2366, known as PSD2, see the Institutions section below.
↑5 See the Institutions and Numbers sections below.
↑6 Paragraph (4) of the preamble recites: “(…) equivalent operating conditions should be guaranteed, to existing and new players on the market, enabling new means of payment to reach a broader market (…). This should generate efficiencies in the payment system as a whole and lead to more choice and more transparency of payment services”.
↑7 Calzolari et al. (2023) discuss “Scale and Scope” properties of Machine Learning tools that rely on the amount of data and the diversity of data-sources and also study the implications for the structure of a market for data.

Filed Under: 2022, From the Editorial Desk

Sustainability and Finance – Why and How?

April 22, 2022 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

1. Introduction

That environmental sustainability should gradually become strictly interrelated to financial activities is a widespread and entirely accepted principle, pursued through financial regulation, supervision, and banks’ and financial institutions’ voluntary actions.

But it is not so obvious why this is the case. If markets were able to internalize environmental costs and risks fully, these should be adequately priced by financial institutions and banks. The allocation of credit and other financial resources would then reflect such costs and risks. And if there were, as there are market failures, these should be addressed by policy instruments targeted explicitly to reducing emissions, like carbon pricing or other fiscal tools, so that financial institutions could then face and respond to adequate pricing signals.

Moreover, by affecting the allocation of assets in terms of their environmental intensity, financial regulations also influence their risk mix. Polluting activities or activities potentially exposed to climate change face physical (environmental damage) and transitional (change in regulation) risks. But green assets are frequently based on new and untested technologies. Hence they are also risky. The ideal mix between these two types of risk should in principle be identified by the objective function of policy makers or social planners, not necessarily by financial regulators.

So, why is there a need for an environmentally-focused action in financial and banking markets? This is one of the two questions addressed in this issue of European Economy. The other one, is how this should and is being done, especially through regulatory and supervisory frameworks, voluntary actions and standards for measuring and disclosing climate and environmental risks.

As for the why, a simple argument is that climate-related risks could impair the ability of central banks to achieve their mandated objectives, for example because climate change and mitigation policies may affect inflation dynamics and also financial stability, as discussed by Campiglio and Lamperti in this issue. Consequently, central banks could directly target green financial instruments in their asset purchase actions.

At the same time, central banks, along with other mandated authorities, could affect the market behaviour of banks and financial institutions through regulatory and supervisory tools. Four other arguments support this type of action.

The first one is that environmentally stringent regulation for financial institutions is less politically costly to be put in place than fiscal instruments affecting the generality of businesses and consumers. Paradoxically, even though nowadays no political party could be elected without a platform explicitly addressing climate change, fiscal tools raising the prices of fossil fuels can give rise to massive political resistance and turmoil, see for example the uprising of the Gilets Jaunes movement in France following a fiscally induced slight increase in fuel prices. At the same time, an effective carbon taxation should be global and fully harmonized through border adjustments. In this respect, a coherent global policy alignment is difficult to implement and faces a lot of resistance, as shown by the recent, pretty generic commitments reached during the United Nation Conference on Climate Change, Cop 26 conference. These policies are necessary of course, but they are not there yet.

Financial institutions are easier to regulate. There is consensus on the need to reduce the riskiness of financial markets in itself, and on the fact that climate change raises high physical risks (e.g. environmental disasters) and transitional risks (e.g. changes in regulation and consequent stranded assets). In that respect, especially banks, have an issue of legacy stranded assets that regulators are bound to face, for example in fossil fuels. Investors are also increasingly sensitive to the pursuance of ESG objectives and are in favour of stringent environmental targets. The risks of investing in green technologies are certainly sizeable and frequently uncertain, but the pressure toward the environmental transition partly reduces the perception of such risks.

A second reason for targeting financial markets is that since fiscal tools are not yet (or are just partially) in place, or in the end they cannot be fully enforced, and consequently market prices do not adequately internalize environmental costs and risks, there is a need for a rapid action, which can more easily be taken by directly targeting financial markets. The mitigation of both physical and transitional risks in asset allocation can more effectively be achieved through financial regulation in the short/medium term. The following section of this editorial discusses this issue at length.

A third one, is that the financial effort required to achieve environmental targets and mitigate climate change is enormous and all resources must be mobilised towards this goal as soon as possible, pressing financial markets in this direction even beyond what would be achievable with mere fiscal incentives.

Fourth and finally, as discussed below, there are failures that cannot be targeted by fiscal instruments and directly pertain to financial markets and interact with pure environmentally induced market failures. For example, credit constraints induced by asymmetric information. Also, De Haas and Beyene et al. in this issue discuss at length how banks generally price environmental risks less than capital markets and how this is also related to the limited perception that depositors, in contrast to direct investors, have on the allocation of banks’ assets. The last part of this editorial will discuss the role of banks vs. capital markets in financing the environmental transition.

As for the how, several contributions in this issue discuss the regulatory and supervisory frameworks adopted or planned (Beyene et al., Mikkelsen et al. and Marullo Reedtz). These, in general, pertain to several domains. First the definition of shared criteria for the measurement and disclosure of the environmental risk, both concerning assets with implicit physical riskiness and those involving transitional costs. Second, the evaluation and inclusion of such risks by financial institutions in their risk appetite frameworks and in supervisory actions and stress tests and the provision by supervisors of clear guidelines. Third, a balanced use of regulatory tools like capital requirements, on the one hand to favour asset allocation towards sustainable investments and, on the other hand, to reduce the risk of rapid divestment from established fuel intensive assets.

The issue focuses especially on the actions of EU institutions, initially triggered by the EU Commission Action Plan on Financing Sustainable Growth in March 2018 and which involves the European Central Bank (ECB), the European Banking Authority (EBA).

Also important are frameworks which imply a voluntary action by financial institutions. In particular, the Task Force on Climate-related Financial Disclosures (TCFD) was established by the Financial Stability Board (FSB) for climate related disclosures and the Net-Zero Banking alliance, which now involves all major financial players. There is an open issue of how far these voluntary arrangements should become compulsory in the longer term.

In what follows, we develop the arguments for why financial regulation should address environmental issues and discuss the different position of banks and capital markets as recipients of such regulatory frameworks.

2. Why financial regulation?

Problems of sustainability of economic decisions are inherent problems of adverse external effects: “the negative effect of production, consumption, or other economic decisions on another person or party, which is not specified as a liability in a contract” (Core, 2017) and therefore is not taken into consideration by a selfish profit or utility maximizing economic agent.

Consider the most debated one: emissions of greenhouse gases causing global warming (Stern and Stern, 2007). Like any other type of pollution, it is a negative externality. Negative externalities have been thoroughly analysed in the economic literature. Two leading solutions have been proposed: limits to production and taxation. Indeed, the most obvious solution in front of a polluter is to force him to stop. But this is an oversimplification because the social costs of completely halting the activities of a polluter can often be higher than the benefits (if Pfizer were marginally polluting to produce vaccines, we would probably be unwilling to force its closure). Welfare maximization requires comparing costs and benefits and set any quantitative limit to production at the level that equates the marginal social costs of production with the marginal benefits. However, this is more easily said than done, especially when producers are in large numbers – coordination on quantity limitations is complex among countries, let aside among single firms – and when the adverse external effects are not instantaneous but delayed in time, as in the case of global warming.

Fixing precise limitations to any activity that generates external effects and imposing them on each economic agent is clearly infeasible. A first option to circumvent this problem is cap and trade policies, i.e. to define a measure of the negative external effect (e.g., tonne of carbon emissions) and price them (see Campiglio and Lamperti in this issue). Once this is done, these policies can go a long way in solving the coordination problems of quantity limitations by allowing firms to trade the right to emit among themselves. Although the decision on how to initially allocate these rights is not obvious, the outcome is efficient, because those firms who incur the lower costs to reduce emissions have the higher incentive to do so. At the same time, the total amount of rights to emit that are granted allows to control the aggregate level of emissions.

Taxation is the alternative to impose quantitative limits, directly or through cap-and-trade policies. Set a Pigouvian tax equal to the marginal external cost – the difference between the (possibly delayed) marginal social cost and the private social cost – and profit maximizing firms will automatically choose the socially optimal production level. Taxation allows to force economic agents to internalize the external effect of their actions, leading to an optimal aggregate level of carbon emissions. According to this view, the optimal strategy to limit greenhouse gas emissions – or any other external effect in production or consumption – is to levy a Pigouvian tax. As such, there is no need to adopt indirect strategies, such as regulations in the financial markets making the cost of funding dependent on how “green” an investment is, so as to “reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth” (EU Commission, 2018).

However, there are at least two main problems with this prescription. One is the interaction of the external effects with other features of the economic system, such as imperfections in financial markets. The other is the evaluation of the joint riskiness of both the impact of the negative external effect (e.g., global warming) and the actions addressing it.

The case of imperfections in the financial markets is relatively straightforward. Consider two firms that must decide whether to invest in adopting a greener production technology. To simplify the analysis, assume for the moment that such technology is readily available, and its cost and benefits are known. One incurs lower costs to adapt to the new technology, but due to credit constraints, it faces high borrowing costs and prefers to renounce investing. The other firm has low borrowing costs, but it is also unwilling to invest since it faces high adaptation costs. Taxing carbon emissions would increase the costs for both firms if they did not invest in acquiring the new technology. The firm facing high adaptation costs may be forced to make the investment, despite the higher adaptation costs, while the credit constrained one may still find unprofitable to invest. An alternative policy, introducing incentives to finance green investments, would instead reduce the borrowing costs for the credit constrained firm, making it more likely to invest in green technology. For reasonable ranges of the differences between the costs of adopting the new technology and the borrowing costs for the two firms, it is possible that financial market regulation allows to achieve a lower level of emissions with the same impact on production. Regulations favoring investments in greener productions or technologies may thus be more effective than directly taxing emissions.

The issue of riskiness is two-faceted (on this theme, see also Campiglio and Lamperti in this issue). On the one side, there is a legacy problem: economic activities started when the global warming problem was underestimated (and therefore Pigouvian taxes were not introduced) can suffer significant losses, causing a surge in the riskiness of the existing portfolio of investments. On the other side, there is a perspective problem because the development and adoption of environmentally sustainable technologies require large investments, typically involving a high riskiness of both private and social returns.

The consequences of the permanent increase in average world temperature caused by greenhouse gas emissions are the object of an intense debate among scientists. Their economic effects are also the focus of a growing body of research (Cruz Álvarez and Rossi-Hansberg, 2021). It seems unquestionable that exceptional risks loom ahead.

From a portfolio management perspective, the problem is whether these risks are priced correctly by investors, particularly by financial intermediaries. If global warming led to extreme events causing radical changes in the economic system – from severe weather conditions to substantial relocations of economic activities – the value of assets held by financial intermediaries would collapse. If provisioning to face these risks was insufficient, a financial crisis would likely unfold. As already seen with the global financial crisis of 2007-2008, this may cause monetary policy problems, calling for radical interventions by central banks.

Provisions may be inadequate for two main reasons. First, investors may be unable to collect and process the vast amount of information required for a sound assessment of the risks caused by global warming. A possible solution would then be to elaborate and provide information on the risks caused by global warming to economic activities, to help investors accounting for their effects in their decisions. As argued by Degryse et al. in this issue, this is already happening, at least in part.

Second, the investors and especially financial intermediaries may not have the right incentives to set aside adequate provisions if they believe that the effects of global warming will be so pervasive to require in any case an intervention by public authorities. We can dub this as a “too-pervasive-to-face” problem. The obvious response to such a scenario is to introduce specific regulations of financial markets forcing intermediaries to cover the risks caused by global warming adequately.

In principles, the rationale for such interventions is not to sustain the funding of investments in greener technologies but to cover the risks caused by greenhouse gas emissions. In fact, such risks may even be unrelated to the production of negative external effects, depending only on how much the existing economic activities are exposed to the consequences of such effects. In practice, requiring higher provisions to cover the risks of the activities more severely affected by global warming will also impact on the allocation of portfolios towards greener investments. First, corporations such as airlines both produce negative external effects and are affected by events extreme weather events caused by global warming. Second, the likely introduction of a Pigouvian tax on polluting corporations is itself a risk that regulations will ask to cover, making it less profitable to conduct these economic activities.

The second type of risk is related to developing and adopting “green” technologies, which is an effective alternative to reducing the level of production in industries that negatively impact the environment. The question is how much shall we invest in this endeavour? Welfare maximization requires comparing the cost of developing and adopting these technologies with the benefit that they guarantee in reducing the external costs. However, both costs and the benefits entail significant risks, which are difficult to evaluate, making it difficult to find the funding required for such investments (as in the well-known cases of R&D financing) especially by financiers like banks and traditional investment funds. In complete and perfectly working financial markets, a Pigouvian tax increases the costs of production, providing an incentive to reduce its levels and, therefore, those of greenhouse gas emissions.

However, Pigouvain taxation may be more challenging to organise, and it can create an additional layer of uncertainty, related to its application through time, relative to a financial regulation that favours financing the development and adoption of greener technologies. As discussed in more detail in the next session, differences in risk aversion across financiers can also impact the adoption and development of green technologies.

Banks vs. markets

Finance and investments are necessary ingredients for a swift green transition. This observation naturally begs the question about the most effective ways to finance the investments that the green transition requires. This question has no unique answer, as it depends on the characteristics of the investing firms and the type of investments. The heterogeneity of firms and investments relevant to the green transition explains some of the mixed results identified in the academic literature and discussed in the articles in this issue of European Economy. We identify three critical factors for financing investments in general and the green transition in particular.

First, to understand the role of finance in the green transition, one needs to move away from the ideal world of the Modigliani and Miller theorem, where the source of finance does not matter for firms (value). In a realistic realm, the “pecking order theory” for finance (Myers and Majluf, 1984, for its adverse selection incarnation and Jensen and Meckling, 1976, for the cost-of-agency one) provides a first helpful step in understanding how firms finance different investments. Ample empirical evidence shows that to address issues of asymmetric information and reduce the cost of financing, firms first rely on retained earnings as the cheapest source of funds and then on external finance, first debt and then equity, with increasing financing costs that reflect the higher associated risk for the external parties.

A second relevant element is that the mentioned hierarchy of financing sources adapts to the “financial growth cycle” of the investing firm and its characteristics, such as size and actual and prospective growth. For example, small start-ups with high growth potential and high risk very often rely on venture capital and private equity.

A third key point is the nature of the investments needed for the green transition. Simplifying and relying on the articles on the present issues of the European Economy, we can identify two types of investment: one aiming at drastic innovations and another helping polluting firms start coping with and reducing their emissions using existing technologies. These types of investments are different. The former is much riskier as it aims at delivering new technologies with a long investment span. The latter is less so and could be seen as “retrofitting” or adapting existing production activities with abatement technologies. Also, the output of the former type of investment is typically intangible, such as with intellectual property rights and trade secrets. Instead, that of the latter is incorporated in production assets, such as renewable energy generation. As we further explore below, these critical differences in risk, investment span, and intangibility have material implications for funding different parts of the green transition.

Combining all these factors, the hierarchy in cost of finance, the characteristics of the investing firms, and the types of investments offers a rich picture to understand how and to what extent sustainable finance can contribute to the green transition. In particular, we are interested in understanding which type of finance is better suited to provide funds for the green transition. Given our three key elements, it is clear that the answer to this question depends on the possible matches between the alternatives, in particular (i) the source of funding, e.g., banks or financial markets, (ii) the characteristics of the investing firm, e.g., established firms or high-growth potential start-ups, and (iii) the type of green investment, e.g., new technologies or existing abatement technologies. The possible matches of the factors (i)-(iii) provide 2x2x2 combinations, some of which are more apt to finance the green transition than others.

In particular, in light of these observations, banks may face relevant issues in financing green investments when associated with certain matches combining points (i)-(iii) discussed above. A first specific problem often mentioned is that the green transition operates in a pre-existing environment where banks provide funds to firms, typically relying on debt contracts and associated collaterals. The green transition is intended to shift activities from pre-existing ones to more environmentally friendly ones. This transition tends to reduce the value of pre-existing technologies and associated assets that banks hold in their accounts. Banks may thus prefer not to contribute with their actions that may accelerate this devaluation of assets and collateral related to dirtier technologies. This observation, also discussed in Degryse et al. and De Haas in this Issue of the European Economy is reminiscent of what we have observed with the Non-Performing-Loans(NPL) crisis a few years ago, where banks avoided for quite some time the write-down of bad debts (see the European Economy 2017 issue n. 1). Although unilaterally, the fear of the risk of an adverse market reaction was understandable, collectively, keeping NPL in banks’ balances contributed to a general instability of the whole sector and required prompt policy interventions.

The problem of pre-existing lending to non-clean investments shares some similarities with NPL and some significant differences. In particular, although NPL banks had clear individual incentives to keep inflated asset values, with the green transition, it is difficult to imagine that each bank individually anticipates and fears the devaluation effects in legacy portfolios and hence perceives the risk of the transition of its lending to innovative green technologies. For example, Beyene et al. (2021) show that banks continue to underprice the risk of asset devaluation for traditional investment due to the green transition, which seems odd with a bank’ strategy of limiting entry green innovative firms with credit rationing. Relatedly, other banks’ characteristics contribute to their attitude towards green investment. Since banks tend to have a shorter investment time horizon than equity markets, they consequently tend to care less for possible future devaluation of assets associated with a high-carbon footprint. In this respect, capital markets seem more apt for prompt corrective action incorporating the increasing environmental risks.

Traditional banks also perceive less pressure to adapt to changing needs and preferences of ultimate funders, in their case depositors, as compared with investment funds. Although attention toward cleaner activities and investments is increasing, traditional banks offer a bundle of many different services to depositors, which may dilute the perception by depositors of the greenness of banks’ asset allocation. Relatedly, the actual exposure of banks towards polluting activities and or the fossil fuel sector is not readily available to banks depositors, as emphasized in Beyene, Delis, and Ongena in this Issue of European Economy. On the contrary, when investors patronize investment funds, the link between the funded projects and the investors’ preferences is more direct and visible. Relatedly, the universal-service characteristic of traditional banks makes it more difficult for banks’ management to keep track of the specific technologies adopted by the firms they lend to. This limited knowledge may ultimately weaken banks’ ability to invest in environmental-friendly innovations.

The different technologies relevant to the green transition can more or less fit what banks can effectively offer and handle. Banks can play a significant role in funding transition investments that allow firms to “retrofit” and adapt their production process towards cleaner approaches. In these cases, borrowers’ traditional assets can offer collaterals that banks can rely on for lending. Instead, financing the developments of drastic innovations for new green technologies may be problematic for banks because these types of innovations typically produce intangible outputs such as patents and trade secrets. As with any type of R&D intense investments, when the outcomes of the investments are intangible and thus non-pledgeable, banks can provide limited funding sources, and capital markets are more apt to address these environments. This is also convincingly emphasized by the papers of De Haas and Degryse et al. on this Issue of European Economy, which illustrate that green patented innovations expand faster in countries where equity finance is more prominent compared with bank lending. This observation is particularly relevant for bank-centric Europe that should channel as much as possible equity funding towards environmental innovations, possibly also rebalancing tax biases in favour of equity rather than debt.

How effective are banks dealing with polluting firms? There is some evidence that banks can price loans incorporating environmental impact. Chen et al. (2021) show that firms that emit more pay higher interest rates than banks, primarily when emissions are associated with more risky borrowers and weak governance. However, the question is whether banks are better able than capital markets to price environmental risks correctly. As discussed by De Haas in this Issue of European Economy, access to credit per-se favours investment in cleaner technologies, although the most relevant factor seems instead the quality and attitude of firms’ management towards environmental issues. Moreover, since banks continue to underprice the risk of asset devaluation for traditional investment, firms relying on carbon-heavy technologies are currently moving away from bonds to bank credit, as documented by Beyene et al. (2021b).

Interestingly, both De Haas and Degryse et al. in this Issue of European Economy have shown that the best outcomes from the credit markets obtain when “green-meets-green,” when banks explicitly commit to green lending match with environmental conscious borrowers that effectively disclose their attitude. In these cases, mutual commitment and disclosure on the two sides of the credit market allow for a cheaper lending cost. An immediate policy implication seems thus that of facilitating credible disclosure of the environmental attitude of both sides of the credit market.

Overall, banks’ difficulty in correctly pricing environmental risks combines several elements, as argued above. The articles in this issue of European Economy provide several policy actions that could redress this problem. Essential in this direction will be improving transparency and disclosure requirements about actual exposure to polluting industries and environmental risks. Moving from a voluntary approach (prone to manipulation and cherry-picking, as shown in Bingler et al. 2021) towards mandatory requirements, such as recently announced by New Zealand, the United Kingdom, and Switzerland seems a fundamental step.

3. Conclusions

In principle, Pigouvian taxation could fully internalize environmental costs and risks, making it useless to introduce ad hoc financial regulations (see Cochrane, 2021, for a view along these lines). But to attain a more sustainable equilibrium in the presence of other market failures, policy interventions in the financial markets can be an effective complementary tool to Pigouvian taxation.

Two main types of interventions have been proposed and are being put in place (see, in particular, Marullo Reedtz and Mikklesen et al. in this issue for a comprehensive analysis). First, the provision of rigorous and standardized information to investors, through the definition of criteria for the measurement and disclosure of environmental risks (e.g., the Taxonomy Regulation of the EU, the Sustainable Finance Disclosure Regulation, the Regulation on European green bonds), and the requirement that large public-interest entities publicly report on sustainability issues (e.g., Directive 2014/95/EU). Second, the explicit inclusion of environmental risks in the bank supervisory framework, including capital requirements and stress tests (e.g., EBA’s Implementing Technical Standards on Pillar 3 disclosures on ESG risks), and in central bank’s analyses (e.g., ECB’s Guide on climate-related and environmental risks).

The ample set of policies proposed in the financial sector will be paralleled by more traditional interventions addressing the effect of negative externalities through taxation and quantitative limitations. These will also impact investment returns (see also the discussion in Giovannini and Tamburrini, in this issue). Overall, the impact on the entire financial industry will be pervasive, affecting the choices and performance of banks, investment funds, insurance companies, and retail investors.

A natural set of questions thus arises. What objective function is driving this process? Who has chosen this objective function? Who is controlling that, when enacted simultaneously, the selected policies point in the right direction to achieve the desired goals?

The answer to the first question is apparently easy: the objective of all proposed policies is to internalize the adverse external effects that make individual choices unsustainable. But this goal requires a precise quantification of the social surplus to be maximized, a daunting task in any welfare analysis. In the absence of a unique solution, the objective function to be maximized should be chosen by citizens, following a democratic process. This observation leads to the answer to the second question that elected governments should determine the objective function to be maximized. While it may be largely agreed that the mandate of financial regulatory authorities reflects the government’s will for financial stability and the general working of financial markets, that such a mandate also reflects government choices on environmental issues is not so obvious. This may call for stricter directives from governments to financial authorities on environmental issues so as to enhance their accountability.

The last question has apparently no answer. Different bodies define different sets of rules, often with a large degree of autonomy. But a body or a framework coordinating the different policies and controlling that their decisions are not contrasting is absent. Given the large number of proposed and implemented interventions, the risk of a lack of coordination is substantial. This calls for a coordination table on environmental issues among all interested bodies. This framework should be set at the European level. In addition, given the global scope of environmental issues, it should be organized at the world level (see also Panetta, 2021).

References

Beyene, W., Delis, M., and Ongena, S. (2021a). Disclosure of Bank Fossil Fuel Exposures. European Economy – Banks, Regulation and the Real Sector, this issue.

Beyene, W., de Greiff, K., Delis, M., and Ongena, S. (2021b). Too-Big-To-Strand: Bond to Bank Substitution in the Transition to a Low-carbon Economy, Swiss Finance Institute, Mimeo.

Bingler, J. A., Kraus, M., and Leippold, M. (2021). Cheap Talk and Cherry-Picking: What ClimateBert Has to Say on Corporate Climate Risk Disclosures, University of Zürich, Mimeo.

Bowles, S., Carlin, W. and Stevens, M. (2017). ‘Market, efficiency, and public policy’. Unit 12 in The CORE team, The Economy. Available at: https://www.core-econ.org. [Accessed on April 17th, 2022].

Campliglio, E., and Lamperti, F. (2021). Sustainable finance policy-making: Why and how. European Economy – Banks, Regulation and the Real Sector, this issue.

Chen, I-Ju, Iftekhar Hasan, Chih-Yung Lin, Tra Ngoc Vy Nguyen, 2021, Do Banks Value Borrowers’ Environmental Record? Evidence from Financial Contracts, Working paper.

Cochrane, J.H. (2021). Testimony of John H. Cochrane to US Senate Committee on Banking, Housing, and Urban Affairs. Available at: https://www.banking.senate.gov/download/cochrane-testimony- [Accessed on April 17th, 2022].

The CORE Team (2017). The Economy: Economics for a changing World, Oxford University Press.

Cruz Álvarez, J.L. and Rossi-Hansberg, E. (2021). The Economic Geography of Global Warming. NBER Working Paper Series, No. 28466. Cambridge, MA: National Bureau of Economic Research.

De Haas, R. (2021). Finance and firms on the road to net zero. European Economy – Banks, Regulation and the Real Sector, this issue.

Degryse, H., Goncharenko, R., Theunisz, C., and Vadasz, T. (2021). The green transition and bank financing. European Economy – Banks, Regulation and the Real Sector, this issue.

European Commission (2018). The Action Plan for Financing Sustainable Growth.

Giovannini, A., and Tamburrini, F. (2021), Sustainable Finance: Three Questions in Search of an Answer. European Economy – Banks, Regulation and the Real Sector, this issue.

Jensen, M.C., and Meckling, W.H. (1976). Theory of the firm: Managerial behavior, agency costs and ownership structure. Journal of Financial Economics, 3: 305-360.

Mikkelsen, D., Viscardi, S., Montes, M., and De Amicis, F.P. (2021). Climate change regulation and supervision in Europe and implications for commercial banks. European Economy – Banks, Regulation and the real Sector, this issue.

Marullo Reedtz, P. (2021). Financing the environmental transition in Europe. European Economy – Banks, Regulation and the real Sector, this issue.

Myers, S.C., and Majluf, N.S. (2021). Corporate financing and investment decisions when firms have information that investors do not have. Journal of Financial Economics, 13: 187-221.

Panetta, F. (2021). A Global Accord for Sustainable Finance. Available at: https://www.project-syndicate.org/commentary/sustainable-finance-global-taxonomy-agreement-by-fabio-panetta-2021-05 [Accessed on April 17th, 2022].

Stern, N., and Stern, N.H. (2007). The economics of climate change: the Stern review. Cambridge University Press.

Filed Under: 2021.2, From the Editorial Desk

Banking and COVID: Past, Present, and Future

May 12, 2021 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

Authors

Giorgio Barba Navaretti[1]University of Milan., Giacomo Calzolari[2]European University Institute., Alberto Franco Pozzolo[3]Roma Tre University.

 

1. The function of banks in emergency

“This time banks are not the problem but part of the solution.”[4]Statement by the General Manager of BIS Agustín Carstens in his interview with Martin Wolf at Financial Times – The Global Boardroom 2nd Edition: Shaping the recovery, 13 November 2020 and … Continue reading This is a statement with several implications and inherent meanings, that we explore in-depth in this issue of European Economy (EE).

First, the absence of wrongdoing. This is an economic crisis that started as an exogenous shock (the pandemic) and not because of financial mismanagement by banks and financial companies: the plaintiff is empty-handed this time. In the aftermath of the great financial crisis (GFC), the leitmotif was that banks’ profits were private and their losses public, as many had to be bailed out by taxpayers. The subsequent reforms in regulation and supervision, the steep rise of capital requirements, and the restrictions on public bailouts were precisely based on the principle that also losses had to be private, borne mainly by shareholders and junior creditors with the ultimate aim to reduce moral hazard in lending and financial allocations. This time, not only the initial shock was exogenous to the banking sector, but it also happened at a time when the industry was acting in good health on safe grounds, as clearly emphasised by Campa and Quagliariello in this issue.

Second, the solution. Banks were crucial in channeling funds to firms and families, indeed so in Europe. Loans to non-financial corporations and households rose substantially in most EU countries during the first half of 2020, as firms needed working capital to withstand a steep reduction in sales and started amassing liquidity as a safety measure, given the remarkable rise in uncertainty (as thoroughly reported by Falagiarda et al. in this issue). Moreover, banks granted moratoria and considerably extended the duration of outstanding exposures. Bank loans also increased in the US, even though firms relied more on the issuance of corporate bonds than their European counterparts. According to Darmouni and Siani in this issue, both investment-grade and high-yield markets reached historical heights after March 2020. Yet, small firms still relied on bank loans. No other economic or financial, or public institution would have been equally pervasive to reach the broad public of firms and households like banks while being thoroughly regulated and supervised to assure the correct implementation of a centrally coordinated nation-wide and EU-level action.

Third, being able to afford to be the solution. As argued, banks were sufficiently capitalised, liquid, and well managed at the outburst of the pandemic (at least a large number of them) to be able to expand their assets without an excessive depletion of prudential capital. Also, because of the restrictions in distributing dividends and because of the moratoria extended to loans, Tier 1 capital, liquidity ratios, and the share of non-performing loans all improved during the crisis (as all the tables and figures reported in the Number section clearly illustrate, and as also argued in the papers by Angeloni and Campa and Quagliariello in this issue).

Fourth, this was possible because banks are subject to strict regulations, in Europe under a common regulatory framework. This had a double advantage. First, the quality of banks’ balance sheets and the extent of their ability to act were well known to the authorities. Second, regulatory authorities knew there were sufficient margins to release many of the prudential provisions of the pre-COVID-19 regulatory framework (e.g., capital buffers) and to introduce some ad hoc prudential measures, such as the restrictions in the distribution of dividends. And also, there was political consensus to do so. Consequently, it was possible to launch a public-private joint action between supervisory authorities, central banks, governments, and the banks themselves, which were at the forefront as the final actors and the enablers of the support operations. Banks would not have been able to act on similar grounds and to a similar extent in a pre-2009 environment. A tighter prudential regulatory framework was essential in creating the preconditions for banks’ “social” action. Also, this could not have happened in Europe if there had not been a Banking Union (although yet to be completed). Ring-fencing and uncoordinated supervisory procedures would have prevented a swift action under comparable conditions within the Union.

Fifth, being part of the solution. For well capitalised and healthy that they were, banks could have never been a solution without several levers of extensive public support: massive liquidity from central banks; extensive public guarantees on new loans; comprehensive regulatory responses, allowing banks to use their capital, liquidity, and countercyclical buffers; suspension of State Aid rules. In Europe, no such action could have been carried out in a pre-2009 environment and in the aftermath of the financial crisis. Governments could not have enacted expansionary measures of support and increased public debt without a massive program of purchase of government bonds by the ECB. At the time, there was no, and there would not have been political consensus for the ECB to carry out a quantitative easing (QE) program first and then the Pandemic Emergency Purchase Program (PEPP). Also, without a Banking Union, it would not have been possible to carry out a coordinated action throughout Europe and also construct sufficient political consensus to soften the prudential requirements set up after the GFC and the Sovereign Debt Crisis and use them countercyclically.

But the next critical challenge is to avoid the solution becoming a problem. For banks to act as responsible social actors during the pandemic, it was necessary, as argued, to considerably smooth the existing regulatory framework. Yet, such a framework was essentially designed to avoid moral hazard, when the banks were indeed the problem: i.e., to provide the right incentives to avoid irresponsible economic behaviour and potential episodes of insolvency. Future problems will be less likely if banks during the pandemic have acted as both economically and socially responsible actors. For example, if the standards applied to the allocation of loans backed by a state guarantee have been adequately stringent. Or if credit forbearance has been granted only to solvent borrowers. Hence at the moment we do not know if banks have carried out economically responsible actions even in the absence of adequate regulatory incentives to do so.

Clearly, to avoid the solution becoming a problem, a crucial aspect is the timing of the steps to go back to normality, which needs to be phased with the evolution of the pandemic and the uncovering of its effects. The legacy of the crisis, the exit strategy, the long-term impact on the banking and financial sectors, and what we have learned from a regulatory perspective are the main issues discussed below.

 

2. The legacy of the crisis and the exit strategy: notes of caution

The aftermath of the pandemic.  

The legacy that the pandemic crisis will leave on the banking sector cannot be underestimated. As argued above, the size and scope of policy interventions have been pervasive, including: (i) monetary policy measures, such as ECB’s Targeted Long-Term Refinancing Operations III (TLTRO III) and Pandemic Emergency Purchase Programme (PEPP); (ii) fiscal policy measures, such as national public guarantee schemes; (iii) prudential and supervisory measures, releasing capital and liquidity buffers, easing the classification of loans and their risk provisioning, and allowing for moratoria on lending. While these measures have been crucial to contrast the effects of COVID-19, they will also have substantial short- and long-run consequences on the banking sector and the economy as a whole.

The moral hazard problems at the core of the debate after the GFC appear not to be an issue in the current situation. Schnabel (2020) explicitly said that “the pandemic has not raised concerns of moral hazard.” Of course banks had no bearing in the economic crisis triggered by the pandemic and were instrumental in supporting households and firms. However, it is not clear whether credit allocation has been biased towards riskier creditors by lifting several prudential conditions. At the same time, cheap credit, moratoria on bank loans, and government guarantees are helping firms to survive, but at the cost of increasing their indebtedness. When support measures will finally be lifted, many borrowers will find themselves more indebted and in a direr condition than before the crisis.

Expansionary monetary policies and government guarantees make it very easy for banks to grant credit, as it is necessary to contrast the pandemic. But they also raise the risk that banks lend to zombie firms, which most likely will not be able to pay back their debts, and the survival of which causes significant distortions in the allocation of economic resources. This would hamper the reorganization of economic activities necessary for an effective process of creative destruction to unfold (Beck et al., 2021). Not all banks have the same incentives to lend to zombie firms, and the available evidence shows that the weaker and less capitalized banks are precisely those that are more likely to do so (Dursun-de Neef and Schandlbauer, 2020; Schivardi et al., 2021 ).
Like all crises, also the pandemic will have a cleansing effect. The acceleration of some trends that were already unfolding will cause a substantial reshaping of profitability across and within economic sectors. Strong firms will sail such rough waters and possibly strengthen their position, while weaker firms will be in trouble. Entrepreneurs should base their decisions on realistic assumptions about their business perspectives, avoiding leveraging on the availability of easy credit to bet for resurrection.

Public spending has increased substantially all over the world in the last year. According to the IMF, the ratio of government debt to GDP in advanced economies has soared by 16.3 percentage points between 2019 and 2020, to 120.1 per cent (by 12.9 per cent in the euro area, to 96.9 per cent). Contingent liabilities related to the guarantees offered on bank loans (see Figure 10, in the Numbers section) may cause a further increase in the coming years.

Expansionary fiscal policies were needed to contrast the effects of the pandemic, and they will undoubtedly be effective in the short run, given the large output gap and the depressed aggregate demand. But government policies need to have a sufficient long-term perspective and the recovery must be sustainable, protracted and sizeable enough for firms to pay back their debts without triggering government guarantees. Adding further concerns to this scenario, moratoria are more widespread in countries with a higher debt-to-GDP ratio (see Figure 17, in the Numbers Section). If government spending during the pandemics and the recovery programs in the aftermath had no impact in the longer term, the unfolding of a new doom-loop between banks and sovereigns might become a possible scenario in the coming years.

Closely related is the issue of NPLs. While their level is still low, they might rise substantially. As reported by Campa and Quagliariello in this issue, the volume of loans classified under IFRS 9 stage 2 – those that are still performing but for which there was a significant increase in credit risk – increased by 24% in 2020. As argued by Angeloni in this issue, banks should set aside adequate provisions to cover for credit risk and keep screening their clients even when government guarantees cover the loans they grant. This is even more so because of the link between NPLs, moratoria, capitalization and profitability: the country share of loans under moratoria which are classified as Stage 2 is higher than the average share of loans classified as Stage 2 (see Figure 12, in the Numbers section), the share of loans under moratoria is larger in countries with higher NPL ratios (Figure 16) and where banks have lower Tier 1 capital ratios (Figure 18) and profitability (Figure 19). Careful attention must thus be paid that banks do not postpone uncovering their losses.

To this aim, asset management companies can be an effective tool to make it easier to sell NPLs at a fair price, avoiding inflated losses because of thin markets or fire sales (which, in turn, could hamper the incentives to uncover them), as suggested by Campa and Quagliariello and Beck in this issue (building on the proposal made by Enria, 2017, in a previous issue of this journal).[5]Although NPLs which will derive from the pandemic are not a legacy of past misbehaviours by bankers, as in the case of GFC, the proposal is nonetheless encountering some opposition at the European … Continue reading

The pandemic crisis also leaves us with a less stringent regulatory framework than what was agreed after the GFC. While this was necessary, an exit strategy must be devised. As argued by Beck in this issue and Beck et al. (2021), the right balance must be found between acting too soon, thus causing a credit crunch during the recovery phase, and acting too late, thus increasing the risk of moral hazard. To help banks and firms make credible budget plans for the coming years, a “forward regulatory guidance” should be provided, setting a clear path ahead. Given current and future uncertainties, such guidance would be more credible and effective if it were state-contingent (i.e., based on economic conditions) rather than time-time contingent (i.e., based on fixed dates in the future).[6]Andrea Enria (2021) in a recent speech suggested a mixed strategy. He argued for the need to move ahead as planned for completing and implementing the Basel III framework on capital requirements, and … Continue reading

Long-run implications  

All the measures described above aim at tackling the short-run legacies of the pandemic crisis, setting the road for a stronger recovery and a sounder financial sector. But long-run legacies of the crisis will also unavoidably affect governments, banks, and firms alike.

Many governments will need to find a way of reabsorbing their massive debts, especially when central banks will phase out the QE. Firm over-indebtedness, especially with banks, will also be a major problem in the medium-run, since it will harm their investment ability. Even more so in the highly productive but riskier activities necessary to reach sustained economic growth.

During the pandemic, some firms have found easier access to the bond market than in the past, as shown by Darmouni and Siani, in this issue (partly thanks to the effects of central bank purchases). Also, in Europe, the number of firms issuing bonds has increased and their average size has declined (Darmouni and Papoutsi, 2020). Bond financing may become a problem if firms cannot roll-over their debt when the next crisis comes.

For firms to have more extensive access to arm-length financing, a larger number of investors should be willing to change their preferences towards higher risk-return strategies. This would be a crucial step to foster the reallocation of activities needed to recover from the COVID-19 pandemic and face future challenges, such as environmental problems. While all obstacles should be removed to facilitate firms’ access to equity markets, including SMEs, a renewed cultural approach to financial investments is also needed. Policies helping firms to switch from government guaranteed bank debt to equity financing, for example along the lines of the proposal made by Boot et al. (2020), would help in this direction. Set within the Capital Market Union framework, their effectiveness would be further enhanced (see Barba Navaretti et al., 2019).

Banks could also play a more active role in helping firms to access the financial markets directly. Margins on traditional banking activities are shrinking due to the current low-interest environment and increased competition from non-bank financial intermediaries, such as in the payment business.[7]As suggested by the results of Bolt et al., in this issue, competition in the payment business is likely to increase in the coming years, due to the acceleration in the diffusion of digital payments … Continue reading A large amount of liquidity available in the financial markets may give way to fintechs to increase lending, for example, through peer-to-peer platforms. Since investment banking has higher margins than traditional lending, underwriting services should be seen by banks as a profit opportunity, rather than as an activity that reduces their loan portfolios’ size.

Also, the evolution of the entire financial intermediation sector, with new players such as fintechs and bigtechs, will undoubtedly push pressure on banks’ profitability. Fintechs had apparently a temporary step-back during the pandemic. This is partly related to the fact that many of these new players like peer to peer landing platforms had no access to relief measures and funding sources and that the public preferred to fly to safety in hardship (see Davies in this issue).

Possibly this has been a temporary accident, as fintechs were not ready yet and diffused enough in Europe to act pervasively during the crisis. But they may come back soon, given the earlier observed speed in the expansion of their business. Also, not all activities faced a set-back. Bolt et al. in this issue have shown that within a few months in lockdown individual payments’ habits have changed and probably permanently at a speed that usually would have taken several years.

The low profitability of traditional banks cannot last forever, with very low, if not still declining, book-to-value records for European banks.[8]Market capitalization of Apple in 2018 was roughly half the combined European listed banks’ capitalization. In 2020, the situation is reversed with Apple now valuing more than the double of the … Continue reading The articles in this issue of European Economy have discussed how banks can regain profitability (see Davies). Overall, there are not so many options available. A combination of traditional approaches, such as cost containment, national and cross-border M&As, and more transformative changes are the likely outcomes.
Excess capacity is still a characteristic of some, although not all, domestic banking sectors in Europe. In some countries, the concentration in the banking sector is already high (notably Spain), and there are narrow margins for other M&As. In others, there are options, notably in Germany and Austria, and also in France and Italy.[9]See https://www.ecb.europa.eu/press/pr/date/2020/html/ecb.pr200608_ssi_table~3054d55051.en.pdf But in this period of uncertainty with an unclear picture on the extent of future NPLs, the value of banks’ assets is uncertain and difficult to assess.

Also cross-country M&As could help to boost banks’ efficiency, and they would be an interesting way forward also in light of the hopeful completion of the Capital Markets Union. But, as highlighted by Davies in this issues, also, in this case, the uncertainty in the value of assets, the yet uncompleted Banking Union (a still missing European Deposit Insurance Scheme) and some potential political opposition, higher than usual in these COVID times, may hamper this pattern in the short/medium term.

Another source of efficiency can come from the adoption of digital technologies, especially for customer engagement applications and the use of artificial intelligence and Big data that can help in credit allocation and asset management modelling. Adopting transformative digital technologies not only opens different sources of profitability but also a re-organization of the banking activities, with a rebalancing of revenues towards non interest based sources (fees and commissions), a useful shift in a negative interest rates environment.

Financial intermediaries would be more of a matching entity, that gains when a transaction takes place. Bigtechs have a similar business model where in many cases profits come from flat-rate subscription fees and the ability to retain customers. The current banking business model is very far from all this, but it could be now the right moment to move more in this direction. Yet, the pace of adoption rate of these technologies by traditional banks is not of the speediest. In this respect, as argued in an earlier issue of this journal on fintechs, banks may rely on third parties such as cloud computing for data storage and analysis rather than developing these technologies.

For regulation and supervision, this will be a process to monitor closely. If regained profitability may stabilize the banking sector, a new business model may come with different risks. It has been shown, for example, that relying more on fees enhances the operating risk of banks.[10]See DeYoung and Roland (2001) and more recently Köhler (2014). Also, as regulators have already noted, outsourcing crucial banks’ activities to third parties implies new risks.

 

3. What have we learnt? Rules as an anticyclical tool and the need for more European integration

Drawing conclusions on the effects of the pandemic on banking and financial markets at this stage is too early. However, the papers in this issue of European Economy help us identify some early observations about what we have learned.

The COVID is an unfortunate and prolonged stress test for the European banking sector and the regulations approved after the GFC, although the presence of unprecedented market interventions confound the test. We have learnt that rules have to be implemented with sufficient flexibility. They can work as powerful anticyclical measures. Using the available margins for releasing capital, liquidity requirements and State-aid rules has been essential to shelter as much as possible companies and households from the worst consequences of the pandemic.

As argued in the papers by Campa and Quagliariello, by Davies, and by Falagiarda et al., adequate capitalization levels were effective in fostering banks’ resilience. However, different banks in different countries will sail through the crisis in very different conditions. How they will exit it will depend not only on the quality of their loan portfolios and on their level of capitalization, but also on how their domestic countries have been hit by the pandemic: the severity of the lockdowns, the sectors of exposure, the effectiveness of the support measures, the state of the public finances etc.

In this framework, it will be difficult not to consider that the process of recapitalization initiated after the GFC was still incomplete. Rescuing banks in a post-COVID-19 banking crisis, if needed, will be just an act of realism: as it turned out to be necessary after the GFC, it would be even more so when the cause of the banking crisis is an exogenous shock like the pandemic.

In light of this, one could try to understand what would have been the COVID-19 crisis had it taken place before the Banking Union, and also what are the challenges ahead for the architecture of European banking supervision and regulation.

A first issue concerns the Single Resolution Mechanism. This was meant to reduce the risk of bail-out and the vicious cycle between banks and sovereigns. However, the bail-in of 8% of a bank’s balance sheet (contained in Banking Recovery and Resolution Directive, to access the Single Resolution Fund) has never been applied, de facto. Several reasons can explain why this Mechanism has not been used so far (see among other Dewatripoint et al. Vox 2021).[11]https://voxeu.org/article/urgent-reform-eu-resolution-framework-needed

What will happen now, in the aftermath of the COVID-19 crisis? In principle, hard hit and undercapitalized banks in need of recovery would face the 8% bail-in rule. However, given the current post-COVID-19 conditions, governments would likely invoke the financial stability exemption to rescue their banks. Especilly if the pandemic evolves into a systemic rather than an idiosyncratic crisis involving more than a small number of banks, as argued by Beck in this issue. Paradoxically, this could lead to a claim of the irrelevance of the Single Resolution Mechanism  – aside from the ex-ante disciplining effect on banks of the threat of its application. This would be an ill-judgement, given the extreme and exceptional conditions we are sailing through, yet it would certainly call for some deep rethinking on how to use public funds in rescuing banks in troubles within a common European framework.

A different perspective emerges if we instead consider jointly the Single Supervisory Mechanism and the Single Rulebook. If these two critical elements of the Banking Union had not been available, then probably the current situation, and the future, would be definitely darker. As we have seen, the increased capital requirements are now paying off. We can claim that, at least so far, even in the case of undercapitalized banks, they allowed for buying time for the public hands to support the economies, without having to worry too much for the banking sector, as far as the lockdowns will not continue in 2022. Also, the banking Union offered a framework for coordinating actions for granting the necessary flexibility in prudential requirements across the Union.

From the COVID-19 crisis we have also learned that it is not true that the only missing piece in the Banking Union is the European Deposit Insurance Scheme. There is still a lot to do in terms of coordination. As mentioned by Campa and Quagliariellio, payment moratoria and public guarantee schemes were launched from governments in a not sufficiently coordinated manner and significantly differed in terms of deadlines, coverage, and conditionality, notwithstanding the efforts of the ECB. This lack of coordination will impact the post-COVID-19 life of banks in Europe.

We also lack a functioning European AMC to deal with NPLs, as mentioned by Angeloni. The current European plans will most likely not materialize in time, and, retrospectively, we missed an occasion in the last phase of the GFC to introduce this tool. Had it been available now, this tense period when NPLs haven’t realized yet, but everybody predicts they will, would have been less haunted by uncertainty.

And we further lack a convincing framework for cross-border banks. This is not a detail. As we argued above, these banks could be a solution for the current situation as a driver of the efficiency of the European banking sector. However, cross-border mergers are unlikely, given the current conditions. Political pressure might oppose such mergers for fear of losing control of national banking systems. Also, the highly uncertain environment in case of resolution of a pan-European bank is a formidable impediment for a cross-border merger. As in the past, the difficulty here is to a conflicting interest of home and host jurisdictions. The Single Supervisory System has made cross-border European banks more likely, but it has not yet lifted several still existing impediments.

As we have argued many times in this journal, a further and stronger integration of European banking and capital markets is a crucial way to improve the banking sector in Europe and certainly for a rapid recovery from the dreads of the pandemic.

 

References

Angeloni, I. (2021). Non-performing loans: an old problem in a new situation. European Economy – Banks, Regulation, and the Real Sector, this issue.

Avgouleas, E., Ayadi, R., Bodellini, M., Casu, B., De Groen, W.P., and Ferri, G. (2021). Non-performing loans – new risks and policies? What factors drive the performance of national asset management companies? European Parliament. Available at: https://www.europarl.europa.eu/thinktank/en/document.html?reference=IPOL_STU(2021)651386 (Accessed on May, 6, 2021).

Barba Navaretti, G., Calzolari, G., Ottaviano, G., and Pozzolo, A.F. (2019). Capital Market Union and Growth Prospects for Small and Medium Enterprises. Development Working Papers 449, Centro Studi Luca d’Agliano, University of Milano. Available at: https://ideas.repec.org/p/csl/devewp/449.html (Accessed on May, 6, 2021).

Beck, T. (2021). Banking and COVID-19 – through the crisis and beyond. European Economy – Banks, Regulation, and the Real Sector, this issue.

Beck, T., Bruno, B., and Carletti, E. (2021). When and how to unwind COVID support measures to the banking system? European Parliament. Available at: https://www.europarl.europa.eu/RegData/etudes/IDAN/2021/659646/IPOL_IDA(2021)659646_EN.pdf (Accessed on May, 6, 2021).

Bholat, D., Thew, O., and Gharbawi, M. (2021). How Has the Covid-19 Crisis Impacted the Use of Machine Learning and Data Science in UK Banking? European Economy – Banks, Regulation, and the Real Sector, this issue.

Boot, A., Carletti, E., Kotz, H.H., Krahnen, J.P., Pelizzon, L., and Subrahmanyam, M. (2020). Corona and Financial Stability 4.0: Implementing a European Pandemic Equity Fund. VOXEU – CEPR. Available at: https://voxeu.org/article/implementing-european-pandemic-equity-fund (Accessed on May, 6, 2021).

Brescia Morra, C., and Guaccero, A., Pozzolo, A.F., Rojas Elgueta, G., Vardi, N., and Zoppini, A. (2021). Non-performing Loans – New risks and policies? What factors drive the performance of national asset management companies? Mimeo, Roma Tre Univesity.

Campa, J.M., and Quagliariello, M. (2021). Lessons from the regulatory response to the Covid-19 crisis. European Economy – Banks, Regulation, and the Real Sector, this issue.

Cartens, A. (2020). Central bank plans to create digital currencies receive backing. Financial Times. Available at: https://www.ft.com/content/428a0b20-99b0-11e9-9573-ee5cbb98ed36 (Accessed on May, 6, 2021).

Darmouni, O., and Papoutsi, M. (2021). The Rise of Bond Financing in Europe. SSRN Working Paper. DOI: http://dx.doi.org/10.2139/ssrn.3748002

Darmouni, O., and Siani, K.Y. (2021). Corporate Bond Issuance and Bank Lending in the United States. European Economy – Banks, Regulation, and the Real Sector, this issue.

Davies, H. (2021). The European Banking Union: Challenges ahead. European Economy – Banks, Regulation, and the Real Sector, this issue.

Dewatripont, M., Reichlin, L., and Sapir, A. (2021). Urgent reform of the EU resolution framework is needed. VOXEU – CEPR. Available at: https://voxeu.org/article/urgent-reform-eu-resolution-framework-needed (Accessed on May 6, 2021).

DeYoung, R., and Roland, K.P. (2001). Product mix and earnings volatility at commercial banks: Evidence from a degree of total leverage model. Journal of Financial Intermediation, 10 (1), 54-84. DOI: https://doi.org/10.1006/jfin.2000.0305

Dursun-de Neef, Özlem, H., and Schandlbauer, A. (2020). COVID-19 and Zombie Lending of European Banks (March 24, 2021). Available at SSRN: https://ssrn.com/abstract=3681937 or http://dx.doi.org/10.2139/ssrn.3681937 (Accessed on May, 6, 2021).

Enria, A., Haben, P., and Quagliariello, M. (2017). Completing the Repair of the EU Banking Sector- A Critical Review of an EU Asset Management Company. European Economy – Banks, Regulation, and the Real Sector, 2017.1, 59-70.

Falagiarda, M., and Petra Köhler-Ulbrich, P. (2021). Bank lending to Euro area firms – What have been the main drivers during the COVID-19 pandemic? European Economy – Banks, Regulation, and the Real Sector, this issue.

Köhler, M. (2014). Does non-interest income make banks more risky? Retail- versus investment-oriented banks, Review of Financial Economics, 23 (4), 182-193. DOI: https://doi.org/10.1016/j.rfe.2014.08.001

Ramos, D., and Lamandini, M. (2021). Non-performing Loans – New risks and policies? What factors drive the performance of national asset management companies? STUDY Requested by the ECON committee of the European Parliament. Available at https://www.europarl.europa.eu/RegData/etudes/STUD/2021/645734/IPOL_STU(2021)645734_EN.pdf (Accessed on May, 6, 2021).

Schivardi, F., Sette, E., and Tabellini, G. (2021). Credit Misallocation During the European Financial Crisis. The Economic Journal, ueab039, DOI: https://doi.org/10.1093/ej/ueab039

Schnabel, I. (2021). The sovereign-bank-corporate nexus – virtuous or vicious? European Central Banks Speech. Available at: https://www.ecb.europa.eu/press/key/date/2021/html/ecb.sp210128~8f5dc86601.en.html (Accessed on May 6, 2021).

Footnotes[+]

Footnotes
↑1 University of Milan.
↑2 European University Institute.
↑3 Roma Tre University.
↑4 Statement by the General Manager of BIS Agustín Carstens in his interview with Martin Wolf at Financial Times – The Global Boardroom 2nd Edition: Shaping the recovery, 13 November 2020 and also by Felix Hufeld, then the President of the Bafin, the German financial regulator, in June 2020.
↑5 Although NPLs which will derive from the pandemic are not a legacy of past misbehaviours by bankers, as in the case of GFC, the proposal is nonetheless encountering some opposition at the European level, as argued by Angeloni in this issue. For a thorough analysis of AMCs, see also Brescia Morra et al. (2021), Lamos and Lamandini (2021) and Avgouleas et al. (2021).
↑6 Andrea Enria (2021) in a recent speech suggested a mixed strategy. He argued for the need to move ahead as planned for completing and implementing the Basel III framework on capital requirements, and at the same time grant other elements of flexibility, like for the Pillar 2 capital requirements.
↑7 As suggested by the results of Bolt et al., in this issue, competition in the payment business is likely to increase in the coming years, due to the acceleration in the diffusion of digital payments during the pandemic and the likely introduction of central bank digital currencies.
↑8 Market capitalization of Apple in 2018 was roughly half the combined European listed banks’ capitalization. In 2020, the situation is reversed with Apple now valuing more than the double of the entire European banking sector.
↑9 See https://www.ecb.europa.eu/press/pr/date/2020/html/ecb.pr200608_ssi_table~3054d55051.en.pdf
↑10 See DeYoung and Roland (2001) and more recently Köhler (2014).
↑11 https://voxeu.org/article/urgent-reform-eu-resolution-framework-needed

Filed Under: 2021.1, From the Editorial Desk

Competing Electronic-Moneys: Why Recent Developments in the Payment System Require Stronger Regulation

October 9, 2019 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

Introduction

In the last years, after decades of lethargy, the retail payment industry has started to thrive. Means of payment which were unthinkable of in the recent past are now available, and innovative services are offered by old and new players. The revolution in information and telecommunication technologies has taken some time to shake what was a very dull and traditional business activity. But with fintech, it has finally arrived.

This revolution has hit all segments of the industry. Not only transferring value has become as easy and cheap as it has never been before, but also what is behind this value has changed substantially.

The arrival of new and disruptive technologies has caused some mayhem in the market. The possibility to offer innovative services has created new profit opportunities, and incumbents in the payment industry are now facing unprecedented threats by aggressive entrants with better technological know-how. As it is always the case in periods of turmoil, it is not necessarily true that innovation leads to welfare improvements. New technologies allow to offer better services, but they may also favor the emergence of monopoly positions, due for example to network economies of scale and the possibility to bundle the supply of goods and services. New types of risks may emerge, that are not fully appreciated by consumers, therefore biasing their choices with respect to what would be socially optimal.

Technology adoption displays very strong path-dependence. Players that will manage to build a strong position in the industry in the coming years will very likely shape its evolution in the future. For this reason, it is of paramount importance to act now to assess the benefits and risks of the new opportunities, and tackle the possible negative externalities with adequate policy interventions.

 

The environment

If we think about how retail payments are generally made, we come out with a handful of alternative options. The most traditional way, and the most common in the majority of countries, is with cash. But debit- and credit-card payments are becoming more and more common. In some countries, smart-phones are supplanting or have already supplanted plastic cards as a support containing the information required to make a payment, and they may also be offering different types of services, not necessarily fully transparent at the eyes of end-users. Finally, we can directly make an order to the financial intermediary where we store our assets to transfer some of them on our behalf to another account, through cheques or money transfers.

In synthesis, cash, debit- and credit-cards, and bank orders make the vast majority of retail payments, even if some of them go through our smartphone. But what are we transferring when we use these means of payment? Cash is fiat-money, a liability of the central bank that we may call central-bank-money. Although it is technically a claim on the central bank, it is outside money and its real value is a function of the credibility of the central bank.

When we do not pay with cash, we are very likely to be transferring bank-money. Obviously, this is the case when we use a cheque or we make a bank transfer. But it is also very often the case when we use a debit- or a credit-card. Bank-money is a liability of a commercial bank, which is one-to-one convertible in cash. It is inside money, whose value is formally guaranteed by the assets of the bank – and by the ample set of regulations that assure that these assets are worth at least as much as the amount of bank-money issued by the bank, i.e. its deposits.

But since recently, when we make a payment with a card or using our smartphone we might also be transferring electronic money. This is a liability of a financial intermediary different from a bank. It can be outside money, as bitcoins, or inside money, as the majority of electronic moneys issued by financial intermediaries around the world. Often, electronic money is also convertible one-to-one into cash, but this is not always the case. Remarkably, from the point of view of a customer, the using experience of paying with a card of a bank is identical to that of paying with a card of a financial intermediary issuing electronic money, although what is behind the value that is transferred can be very different.

 

The choice among the different alternatives

How do we choose among different means of payment? A rationale choice is based on the characteristics of each instrument in terms of its cost of usage, its effectiveness, and its riskiness. The cost of usage and the effectiveness are technological characteristics. Apart when we use cash, making a payment involves the transfer of a certain amount of information. This can be done on paper, as in the case of a cheque, or of the old payments with the credit-card, when a paper slip was produced and sent to the interested counterparties. But in all other cases it is done electronically. More efficient information procedures to match the two sides of a transaction, higher computing power, more user-friendly procedures or interfaces to link purchases and payments are all characteristics that make it more likely that a given instrument is less expensive and more effective.

The riskiness of a means of payment depends instead on a number of different features. A crucial feature is the value that is promised by the issuer. In the case of central-bank-money such as cash, the real value is guaranteed by the central bank and by how well it maintains price stability. Crucially, price stability is expressed in terms of the legal tender, that undertakes the function of unit of account. In the case of bank-money, perfect convertibility with cash is assured by contractual and normative provisions. The nominal value is therefore guaranteed and the real value is the same as that of cash. An identical case is that of electronic-money, which is one-to-one convertible into cash or into bank-money. On the contrary, holders of electronic-money whose value is linked to that of a pool of assets – as for example in the case of the Libra, the currency proposed by Facebook – incur the risk of imperfect convertibility with cash or bank-money. Of course, whether the real value of such an electronic-money is more or less stable than that of central-bank-money depends on the conduct of monetary policy, on money supply by the electronic-money issuer and on the relevant rate of inflation for each consumer. In fact, the real value of an electronic-currency may turn out to be more stable than that of the legal tender, if the central bank is not good at maintaining price stability. The same, at least in theory, could happen with outside electronic-money, such as bitcoins.

A related issue is how this value is guaranteed. In fact, promising one-to-one convertibility into cash is not the same thing as being able to perform it. In the case of bank-money, convertibility is guaranteed by deposit insurance and by bank supervision, which assures that the value of bank’s total assets does not fall below that of deposits. With electronic-money, the value is also guaranteed by the portfolio of assets of the financial intermediary. If electronic money issuers are required to hold assets for a value equivalent to that of the money that they have issued in the form of bank deposits, the guarantee is identical to that on bank-money. If this is not the case, holders of electronic-money may incur higher risks than holders of bank-money, even in case of formal one-to-one convertibility.

An additional source of riskiness is the liquidity of each means of payment. Clearly, even in the case of fully guaranteed one-to-one convertibility into cash, discovering that the money that we hold is not accepted to make a payment, for example because our counterpart fears it is counterfeit, will be a source of problems. Clearly, the risk of liquidity is going to be higher for moneys that do not offer, or guarantee, convertibility into bank-money or cash.

Finally, the riskiness of a means of payment is also related to that of the technological infrastructure that it adopts. The security of the plumbing, as the payment system is known in the jargon of central bankers, is a crucial issue, as the recent frauds at bitcoins exchanges have recently made clear. For this reason, in all countries payment systems are supervised by regulatory authorities.

 

The implications

In the environment described above, the market equilibrium is unlikely to be fully competitive and efficient. A number of factors work against such an outcome. For obvious technological reasons, transferring value within a network of users sharing the same technological platform – what is known in the jargon of the payment system as a closed loop system – is less expensive and more effective than transferring bank-money. These economies of scale emerge because, within a single network, any transfer of value from customer A to customer D amounts to two records in their positions within the system. A money transfer requires instead to record changes in the position of customer A with respect to his bank, call it B, in the position of bank B with respect to the bank of customer D, call it bank C, and in the position of customer D with respect to bank C. If banks B and C want to make the transfer in central-bank-money, a record in their reserve positions with the central bank is also necessary. This requires to standardize information protocols and to connect different computers and servers, all activities that require time and money. Clearly, network-economies-of-scale favor the concentration of the market in the hands of few corporations.

What these corporations will be, is related to a large extent to the effectiveness of the payment experience. Payments are increasingly generated by purchases taking place within platforms offering a large array of services, often owned by bigtech such as Amazon, Alibaba, Facebook, WeChat, Google. Suppliers of such services are in a better position to offer means of payment specifically tailored to the characteristics of their platforms. These corporations have thus strong incentives to create their own electronic moneys and exchange them within the network of their customers, as Alibaba has done with Alipay and WeChat with Tencent, and Facebook is willing to do with Libra. Having few players controlling the entire payment system, and with the ability to bundle purchases and payments, is likely to generate severe anti-trust concerns.

In addition, if such moneys are one-to-one convertible into bank-money or cash, monetary policy will remain in the hands of the central bank. But if this were not the case, a large diffusion of such means of payment might indeed hinder central bank’s ability to conduct monetary policy.

Finally, a subtler issue relates to the value of the information generated by payments. Electronic-money transactions are not anonymous, and can be linked to single purchases. They have therefore enormous value for marketing and lending purposes. How they would be stored, treated and used is indeed a major cause of concern.

The problems listed above are likely to be even more of a concern considering that customers choosing among different means of payment are likely to assign a prominent weight in their choices to cost and effectiveness, underestimating the risk that they incur.

All this, calls for regulatory intervention.

 

What type of regulation

The digital technology advancements we have experienced in the last fifteen years will produce epochal transformations and, if properly directed, will deliver enormous benefits. Payments systems are not immune to these transformations with a process that will have to be governed for the reasons discussed above. In addition, both the payments system and the digital markets that may be bundled with, such as information (Google), social interactions (Facebook), market places for commodities transactions (Amazon and Alibaba) and entertainment (Netflix and Spotify), they all share a common property, namely the presence of strong network externalities. This force has already displayed its effect selecting winners-take-all champions, and levels of concentration and market power that have rarely seen in market economies.

In this environment, we think there is no doubt a need of ex-ante and ex-post interventions to guarantee that innovations in payments systems produce their benefits, still guaranteeing stability.

In particular, operating ex-ante, regulation must grant at least three main objectives. First it must be able to induce transparency for users on the values of the different means of payments. Second, it should let monetary policy authorities to continue lead an effective monetary policy. Third, it must grant effective competition among the different means of payment.

As for the first objective of regulation, it should be noticed that lacking transparency on the value of means of payments, moral hazard issues may emerge with a bad and risky money winning over good and safer ones. This may in the end lead to a complete break-down of the new payment systems. One possibility to obtain value-transparency is that regulation requests any electronic money to be fully backed by perfectly convertible assets such as banks and/or central bank reserves.

As for competition, both ex-ante regulatory intervention and ex-post antitrust activities are important. Regulation should incentivize if not impose interoperability among the different payment systems so that customers can easily transfer their money across different systems. Standardization of protocols to transfer bank and electronic money across financial intermediaries is key for smooth interoperability. An alternative to full standardization that has been put forward in markets with network externalities is multi-homing, where users find it preferable to be active on several possibly competing networks. In the case of payment system this would require having wallets with different digital payments. Clearly, obtaining these outcomes is not easy and may require significant costs, such as duplicating costs of networks, which however will grant significant future benefits, which explains why regulation is needed.

Ex-post antitrust intervention should instead take care of the dominant positions that naturally emerge in markets characterized by strong network externalities. As mentioned above, companies already relying on large customer base will have incentives to expand new payment systems. They will be able to do so also both leveraging on the bundling of their core business with internal payment systems and also on the processing and use of the large amount of information they have on their customers. As shown by past antitrust interventions, bundling is a very powerful strategy that dominant firms tend to use in order to extend their power in adjacent markets. The risk that payments systems become quickly monopolized by the already dominant players is concrete and antitrust authorities must be on the monitor and promptly act if needed. As with regulation this is more easily said than done. Consider for example the recent acquisitions of Instagram and WhatsApp by Facebook. These mergers have been greenlighted on the ground that these companies where active in different markets. However, it is now clear that the business models evolve very quickly in digital and network markets and that possibly unrelated companies may be formidable competitors in a few months-time horizon. Independent Instagram and WhatsApp could have been now competitors to Facebook and Google on the advertising market.

Authorities and regulators should team up to identify the right trade-off between tackling the dangerous issues outlined above and at the same time guaranteeing that the technological developments on payment systems deploy all their windful to users allowing for a modernization of money markets.

 

Filed Under: Next Issue

FinTech and Banks: Friends or Foes?

December 23, 2017 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

From Issue 2017.2 - Editorial

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