The RTC and the Escalating Costs of the Thrift Insurance Mess

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							                                                                                                                      May 15, 1991


                                                 6GONOMIG
                                               GOMMeNTORY
                                                 Federal Reserve Bank of Cleveland




The RTC and the Escalating
Costs of the Thrift Insurance Mess
by Christopher J. Pike and James B. Thomson




jTXlmost daily, the news media report           The purpose of this Economic Commen-
on the ever-growing cost of resolving the       twy is to describe briefly the structure
savings and loan (thrift) insurance crisis.     of the RTC and the condition of its bal-
                                                                                             "The long-term challenge facing the
A year ago, the administration estimated        ance sheet, and then to examine the fac-
                                                                                             RTC will be properly managing bil-
that the present-value cost of resolving        tors that may be impeding its progress       lions of dollars of assets that come
the insolvency of the now ^defunct Fed-         in closing insolvent thrifts and returning   from the resolution of failed thrifts
eral Savings and Loan Insurance Corpo-          their assets to the private sector.          and disposing of those assets in a
ration (FSLIC) fund was $130 billion.                                                        timely and efficient manner."
With the passage of time and the contin-        • Creating a Public
ued deterioration of the troubled portion       Salvage Mechanism                                                 David C. Cooke,
of the thrift industry, current estimates of    In early 1989, the public began to recog-           Executive Director of the RTC'
the final cost of the FSLIC bailout are         nize the size and scope of the insolvency
half again as high. Taxpayers, who are          of the FSLIC fund. At that time, the offi-
paying a substantial portion of this bill,      cial estimate of the present-value cost of
wonder why the cost continues to in-            resolving the FSLIC's insolvency was
crease and why the Resolution Trust Cor-        approximately $130 billion. As noted in
poration (RTC) appears to be slow in            a previous research paper, this loss,
ending the thrift problem.                      borne largely by taxpayers, is unprece-
                                                dented—there are none of even remotely
Although the RTC is reported to have            comparable magnitude in American his-
resolved many thrifts, it has not done so       tory. The combined costs of the federal
quickly or completely. From its incep-          bailouts of New York City, Lockheed,
tion in August 1989 through February            Chrysler, and Continental Illinois Bank
1991, the RTC has disbursed $ 111.4 bil-        did not even reach $9 billion. Thus, the
lion. Of the $98.3 billion used to resolve      FSLIC bailout is in a class by itself, a
366 thrifts, $64 billion has been invested      truly world-class white elephant.3
in receivership assets and is potentially
recoverable (see tables 1 and 2). How-         Handling this white elephant is a colos-
ever, the RTC has returned to the private      sal and complicated undertaking that has
sector less than one-third of the initial
                                               required new legislation, a new institu-
receivership assets of these institutions.
                                               tional structure, and a new approach.
In addition, there may be as many as
                                               The signing of the Financial Institutions
510 additional insolvent thrifts that will
                                               Reform, Recovery, and Enforcement Act
eventually have to be resolved. Critics
                                               (FIRREA) on August 9,1989 marked
charge that the sluggishness of the
                                               the first significant step toward resolving
RTC's salvage operation is partially
                                               the thrift insurance mess. The primary
responsible for the escalating costs of
                                               objective of this bill, which provides the
resolving the thrift insurance mess.
                                               most comprehensive restructuring of
the thrift industry since the Great De-                            TABLE 1 SOURCES AND USES OF RTC FUNDS:
pression, is to resolve troubled thrifts                                   INCEPTION THROUGH FEBRUARY 28,1991
expeditiously and with minimal detri-
                                                                                                                                   $ Billions
ment to the economy.
                                               SOURCES
 FIRREA established an entirely new            Treasury appropriations                                                               18.8
 regulatory structure for thrifts and          Federal Home Loan Bank contributions                                                   1.2
 created the RTC to oversee thrift resolu-     Resolution Funding Corporation borrowings                                             30.1
 tions from January 1,1989 through             Federal Financing Bank borrowings
 August 9,1992.4 It also created the             Total external sources                                                             106.0
 Resolution Funding Corporation (REF-          Repayments from conservatorships                                                       2.0
CORP) to provide for off-budget fund-          Repayments/dividends from receiverships                                              _LL6
ing of the RTC. The RTC's initial fund-          TOTALSOURCES                                                                       119.6
ing consisted of $18.8 billion in direct
                                               USES
Congressional appropriations of tax-
payer money, $18 billion of taxpayer           Resolutions and receivership funding                                                  98.3
funds allocated by a drafting error in         Advances and other disbursements to conservatorshipsa                                 11.3
FIRRE A, $1.2 billion from Federal             Federal Financing Bank interest                                                      _L8_
                                                 TOTAL USES                                                                         111.4
Home Loan Banks, and $30 billion from
the proceeds of REFCORP bond sales.            NET FUNDS AVAILABLE                                                                    8.2
These bonds represent an additional tax-
                                               a. Net of conservatorship advances transferred to receiverships.
payer liability, because although the in-      SOURCE: Resolution Trust Corporation, RTC Re\iew, vol. 2, no. 2, February 1991.
terest on this debt is to be paid by thrifts
(through higher deposit insurance pre-
miums and assessments on Federal
Home Loan Banks), the U.S. Treasury is         $64.0 billion currently held by the RTC                up any profit..." and "...wipe out value
to repay the principal and is ultimately       in receivership assets. Junk bonds ac-                 more quickly than you might imagine.1,,7
responsible for the interest payments.         count for a smaller percentage of the
                                               assets on the RTC's balance sheet —                    There are also indirect costs of the RTC's
• The Pace of Insolvent                        roughly 9 percent as of April 15,1991.                 warehousing of assets. Capital that could
 Thrift Resolutions                                                                                   be used to resolve additional thrift insol-
Since its inception, the RTC has taken         The delayed pace at which the RTC is                   vencies is tied up, reducing the speed at
366 failed savings and loan institutions       returning assets to the private sector                 which the RTC can execute more resolu-
into receivership. Unfortunately, in the       can increase the total resolution costs                tions. Unfortunately, this delay adds to
majority of these cases the resolutions        in two ways. The first is the deteriora-               the final costs of resolving the thrift in-
cannot be considered complete, because         tion of these assets while they remain                 surance mess, as operating losses and
the RTC has failed to return a large per-      in the government's hands. One econo-                  deterioration of asset quality at insolvent
centage of the resolved thrifts' assets to     mist contends that the RTC lacks the                   thrifts continue to add to the cost of
the private sector. As of March 1, 1991,       proper incentives to maintain and en-                  resolution. This relationship is supported
the corporation has been able to dispose       hance the value of troubled assets on                  by a recent study from current and former
of a mere 31 percent of the initial            its books. Another expert warns, "The                  Office of Thrift Supervision (OTS) econ-
receivership assets of resolved thrifts,       problem assets in insolvent S&Ls are                   omists, which finds that the most signifi-
with the rest being held in its portfolio      highly perishable commodities, particu-                cant determinant of the total cost of
(see figure 1).                                larly in the hands of inept or indifferent             resolving failed thrifts is the number of
                                               custodians."                                           months the institutions were insolvent.'g
The majority of the sales have included
the most-marketable assets, such as cash       Second, when the RTC holds assets in                   The cost of delay in closing insolvent
and securities. Furthermore, some $13          lieu of returning them to the private sec-             and unprofitable thrifts can also be seen
billion of the reprivatized assets were        tor, it incurs carrying costs—the costs                by looking at the earnings performance
sold with an option that allows buyers         associated with financing and managing                 of the thrift industry itself. In 1990,
to return the assets to the RTC for a full     assets. These carrying costs can be a                  OTS-supervised thrifts (including those
refund within 90 days of the sale. The         substantial part of the total resolution               under RTC control) lost $13.2 billion.
remaining assets held by the RTC, pri-         costs. Irvine Sprague, former Federal                  Although roughly 60 percent of all OTS
marily real estate and junk bonds, are of      Deposit Insurance Corporation chair-                   thrifts were profitable, one report shows
lower quality and marketability. As seen       man, argues that the costs of financing,               that the industry loss was driven by the
in table 2, real estate and delinquent         staff time, legal fees, appraisals, and ad-            remaining 40 percent of these thrifts,
loans represent about 32 percent of the        vertising are substantial and can "...eat              which lost $17.1 billion. Last year
marked the fourth straight year that aggre-                         TABLE 2         RTC RECEIVERSHIP INSTITUTIONS
gate industry losses were driven by losses
at a minority of thrift institutions.
                                                                                                             Amount                     Percent of
                                                                                                            ($ Billions)               Gross Assets
• Obstacles to Efficient
                                                Cash and investment securities3                                 3.1                         4.8
 Asset Disposition                              Mortgage-backed securities                                      1.4                         2.2
Critics of the RTC's performance to date
                                                Total performing loans                                         32.4                       50.6
point out that the corporation's operating
                                                   1- to 4-family mortgages                                    14.4                       22.5
policies have slowed the speed of thrift
                                                   Construction and land                                        3.1                        4.8
resolutions and have resulted in ineffi-
                                                   Other mortgages                                              9.9                       15.5
cient asset disposition procedures relative
                                                   Other loans                                                  4.9                        7.7
to a private salvage operation. In a recent
                                                Total delinquent loans                                         12.4                       19.3
study, Professor Edward J. Kane con-               1- to 4-family mortgages                                     2.3                        3.7
trasts the RTC's salvage operation with            Construction and land                                        2.9                        4.6
that of a private salvager. He contends            Other mortgages                                              4.5                        7.1
that while the goal of a private-sector sal-       Other loans                                                  2.6                        4.0
vager is to maximize recoveries on its as-      Real estate owned                                               8.2                       12.8
sets, a public-sector salvager carries the      Subsidiaries                                                    2.7                        4.3
additional burden of balancing often con-       Other assets                                                                             _M
flicting political objectives.10 As a result,   Gross assets                                                   64.0                      100.0
the RTC faces a number of restrictions
on its ability to dispose of assets. In         a. Excludes $5.1 billion in cash and cash equivalents accumulated from receivership collections.
general, these constraints fall into four       NOTE: All data are based on preliminary information as of February 28, 1991. Number of institutions: 366.
                                                SOURCE: Resolution Trust Corporation, RTC Review, vol. 2, no. 2, February 1991.
categories: political and legal, adminis-
trative, information, and funding.

The magnitude of the current thrift
problem, in terms of both the number
                                                the RTC to recognize losses quickly                       investments that must be evaluated by
of failed institutions and total losses,
                                                and dispose of assets promptly, to                        the RTC and potential acquirers. The
has increased the extent to which politi-
                                                prevent the total cost of the bailout                     RTC employs more than 1,500 people,
cal concerns can influence asset dispo-
                                                from escalating.                                          but critics contend that its pool of bank
sition by the RTC. With taxpayers foot-
ing a substantial part of the estimated                                                                   examiners and disposition experts is
$200 billion in thrift-related losses, the      Administrative constraints on the sal-                    too small and inexperienced to keep
operation of the RTC is subject to ex-          vage operation arise from two sources.                    pace with the problem.
tensive scrutiny by Congress, the ad-           The first is the additional layer of bu-
ministration, and the public. One can           reaucracy that FIRREA imposed with                       Another obstacle in the evaluation proc-
argue, however, that the increased pub-         the establishment of the RTC Oversight                   ess is the lack of any secondary market
lic scrutiny should encourage RTC               Board, which was instituted to ensure                    in which to trade or to determine a mar-
managers to conduct the salvage opera-          that the corporation conducts its opera-                 ket value for a substantial portion of the
tion in a manner that is consistent with        tions in a manner consistent with the                    seized thrifts' assets. Further complicat-
broader political and social goals.             public interest. However, RTC Chair-                     ing the valuation process is the fact that
                                                man L. William Seidman has stated in                     credit risk, rather than interest-rate risk,
                                                Congressional testimony that this board                  is currently the underlying cause of
Unfortunately, legislators, agency offi-
                                                has reduced the RTC's operational flex-                  losses on thrift balance sheets. Assessing
cials, and analysts do not always agree
                                                ibility and innovation and has conse-                    the credit risk of each borrower is more
on just how the RTC should resolve
                                                quently hindered the speed and efficien-                 complex and time-consuming than ad-
troubled thrifts to serve the public inter-
                                                cy with which the corporation can                        justing assets to account for unrealized
est in the best way. Individuals with a
                                                dispose of assets.                                       gains and losses due to interest-rate fluc-
short-term outlook want to minimize
                                                                                                         tuations in a national credit market.
the near-term costs associated with
taking losses. In their opinion, the RTC        A second source of administrative con-
should spread out the recognition of            straint is the sheer magnitude of the                    Uncertainty about conditions in the var-
losses over time by warehousing assets          thrift crisis relative to the staff resources            ious regional markets also reduces the
and financing them with working capi-           available to the RTC. The 556 thrifts                    RTC's ability to value the assets in its
tal. Individuals with a long-term out-          that have experienced government in-                     control. Coupled with the low market
look are concerned primarily with total         tervention as of March 1 represent mil-                  value of many of the receivership assets,
taxpayer liability and therefore want           lions of individual loan contracts and                   this uncertainty creates incentives for the
RTC to warehouse its assets. Selling                              FIGURE 1 RTC RESOLUTIONS:
these difficult-to-value assets leaves the                                 INCEPTION THROUGH MONTH-END
RTC open to second-guessing by the
press, taxpayers, and politicians, who                           As a percentage of total assets
may accuse the corporation of selling                            50
the assets too cheaply. Unfortunately,
warehousing assets does not increase the
efficiency of markets, but instead may in-                      40
crease the uncertainty concerning the
true value of assets, such as real estate,
when the market is depressed.
                                                                30
The lack of adequate funding may also
delay thrift resolutions by the RTC.
The initial $68 billion committed by
                                                                20
FIRREA has fallen well short of what
is needed to cover the losses of insol-
vent thrifts. The inability of the RTC to                       10
cover losses has limited the number of
thrifts it has been able to resolve, and
the corporation has already drained off
$34.3 billion of its $50 billion of initial                                 Aug., Sept. Oct. Nov. Dec. Jan. Feb.
funding. In fact, without an additional                                                 1990             1991
                                                                                Percentage of assets returned to private sector
$ 18 billion in funding (by way of legis-
lative error), the RTC salvage operation      SOURCE: Resolution Trust Corporation, RTC Review, vol. 2, no. 2, February 1991.
would have ground to a halt last fall. 14

Funding constraints have also reduced
the working capital needed to finance         • Removing Some of the Obstacles                       vent thrifts. First, the corporation will
the temporary holding of assets. A            Congress has recently passed legislation               increase the markdown to 40 percent
shortage of this capital reduces the          to address some of the funding prob-                   for real estate assets on the market
speed at which the RTC can intervene          lems that have threatened to paralyze                  longer than six months, and to 50 per-
and resolve thrift insolvencies, since it     the thrift salvaging operation. The new                cent for those held longer than 18
must eventually generate working capi-        RTC recapitalization bill allocates $30                months.16 In addition, the RTC also in-
tal through the liquidation of assets.        billion of taxpayer funds to absorb                    tends to offer mortgage-backed securi-
                                              thrift losses and permits the RTC to                   ties at the rate of $1 billion per month
Much of the RTC's working capital to          borrow an additional $48 billion to use                once registration is completed with the
date has come from its short-term bor-        as working capital. RTC Chairman                       Securities and Exchange Commission.
rowings from the Federal Financing            Seidman recently announced that with
Bank. Of the total $75.3 billion in           the newly acquired spending authority,                 Some analysts have argued that de-
working capital that the RTC has dis-         the RTC plans to sell another 215 failed               pressed real estate markets have made
tributed through March 1, 1991, ap-           thrifts by the end of September 1991.                  it more expensive for the government
proximately one-fourth has come from                                                                 to hold on to some real estate than to
Congressional appropriation, while the        Although increased funding will                        merely give it away. Consequently, the
remainder has come from short-term            finance the RTC through this period, it                RTC expects to give away between
loans. These loans are to be repaid with      is unclear whether it will enable the cor-             2,000 and 3,000 of the single-family
the revenue generated from asset sales;       poration to resolve all insolvent thrifts.             units that it fails to auction to nonprofit
however, the sluggish pace of these           Recent statements by the U.S. General                  groups for use as low-income housing.
sales has reduced the amount of funds         Accounting Office suggest that the
available for covering losses and pro-        RTC's additional needs to cover losses                 One other initiative aimed at accelerat-
viding the working capital for addition-      could exceed the entire $78 billion of                 ing asset sales is instituting a new bid
al resolutions. At the end of February        recently appropriated funding. 15                      option, whereby the RTC will include
 1991, only $8.2 billion of cash was                                                                 an estimate of the value of assets in its
available from the RTC's initial Con-         Seidman has also reported that the RTC                 bid packages. The estimate is the price
gressional appropriation and from its         will relax some rules in order to speed                that the RTC will pay for these assets at
Federal Financing Bank borrowing              the sale of $65 billion in assets (partic-             closing and will apply to all institutions
authority to fund additional resolutions.     ularly real estate) from those 215 insol-              in RTC conservatorship.
 •   Conclusion                                    3. See James B. Thomson and Walker F.            11. This follows Kane's analysis of the con-
 Cleaning up the thrift mess, the goal of          Todd, "Rethinking and Living with the            straints on the ability of the Federal Deposit
 the RTC, is a complex and monumental              Limits of Bank Regulation," The Cam Jour-        Insurance Corporation to resolve bank insol-
                                                   nal, vol. 9, no. 3 (Winter 1990), pp. 579-600.   vencies. See Edward J. Kane, "Appearance
 undertaking. The RTC's performance to
                                                   4. FIRREA transferred the chartering             and Reality in Deposit Insurance: The Case
 date suggests that it has not met its
                                                   authority and supervision responsibilities of    for Reform," Journal of Banking and
 stated objective of resolving thrift insol-                                                        Finance, vol. 10, no. 2 (June 1986), pp.
                                                   the former Federal Home Loan Bank Board
 vencies quickly and at the lowest cost to                                                          175-88.
                                                   to the newly created Office of Thrift Super-
 taxpayers. The corporation has resolved
                                                   vision. This act also transferred the respon-    12. See L. William Seidman, "Statement on
 less than half of the thrifts that will ulti-     sibility of thrift deposit insurance from the    Predictions and Policy Statements of the
 mately be closed, and in those resolu-            now-defunct FSLIC to the Federal Deposit         Resolution Trust Corporation," in Oversight
 tions has failed to return nearly 70 per-         Insurance Corporation's Savings Association      Hearings on the Resolution Trust Corpora-
 cent of the assets to the private sector.         Insurance Fund (SAIF).                           tion, Hearings before the Committee on
                                                   5. See Edward J. Kane, "Principal-Agent          Banking, Finance, and Urban Affairs of the
                                                   Problems in S&L Salvage," Journal of             House of Representatives, 101 Cong. 2
 The pace at which the RTC has resolved
                                                   Finance, vol. 45, no. 3 (July 1990), pp.         Sess., January 23-25, 1990 (Government
 insolvent thrifts reflects the sheer magni-
                                                   755-64.                                          Printing Office, 1990), pp. 87-93.
 tude and nature of this unprecedented
                                                   6. See Bert Ely, "Statement on Oversight         13. See Paul M. Horvitz, "Statement on the
 problem, as well as constraints that reduce
                                                   Board's Strategic Plan to Make FIRREA and        Strategic Plan for the RTC," in Oversight
 the speed, flexibility, and efficiency of                                                          Hearings on the Resolution Trust Corpora-
                                                   RTC Succeed," in Status and Activities of the
 the salvage operation. Unfortunately,                                                              tion, January 23-25, 1990, pp. 1165-81; and
                                                   RTC and the Oversight Board, Hearings.
 the resulting delay continues to add to           October4, 19, and November 6, 13, 1989,          Irvine Sprague, "Statement on Disposition of
 the ultimate resolution costs. Although           pp. 92-94.                                       Assets by the Resolution Trust Corporation,"
 the recently announced procedures are                                                              Hearings, May 4, 1990, pp. 18-19.
                                                    7. See Irvine Sprague, "Statement on Dis-
 a step toward streamlining operations              position of Assets by the Resolution Trust      14. See "Resolution Trust Corporation Fund-
 and speeding resolutions, it is clear that         Corporation," Hearings before the Subcom-       ing Act of 1990," Congressional Record—
. the RTC must further modify its cur-            • mittee on Financial Institutions Supervision,   Senate, October 27, 1990, pp. S17722-25. •
 rent asset disposition policies in order           Regulation, and Insurance and the Resolu-       15. See John R. Cranford, "RTC Gets
 to resolve the thrift crisis with mini-            tion Trust Corporation Task Force of the        'Incomplete' Grade, Urged to Improve
                                                    Committee on Banking, Finance, and Urban        Records," Congressional Quarterly Weekly
 mum taxpayer loss.
                                                    Affairs of the House of Representatives, 101    Report, vol. 49, no. 8 (February 23, 1991),
                                                    Cong. 2 Sess., May 4, 1990 (Government          p. 457.
 • Footnotes                                        Printing Office, 1990), pp. 18-19.              16. Under current rules, the RTC marks
 1. See David C. Cooke, "Status of the Reso-
                                                   8. See James R. Barth, Philip F. Bartholo-       down property by 5 to 10 percent initially, by
 lution Trust Corporation: Testimony before
                                                   mew, and Michael G. Bradley, "Determi-           15 percent after six months, and by 20 per-
 the RTC Oversight Task Force," in Status
                                                   nants of Thrift Institution Resolution Costs."   cent after nine months.
 and Activities of the RTC and the Oversight
                                                   Journal of Finance, vol. 45, no. 3 (July
 Board, Hearings before the Subcommittee on
                                                   1990), pp. 731-54.
 Financial Institutions Supenision. Regula-
 tion, and Insurance and the Resolution Trust      9. The S&L Quarterly Performance: Ratings
                                                                                                    Christopher J. Pike is a senior research assis-
 Corporation Task Force of the Committee on        and Analysis, Austin, Texas: Sheshunoff In-
                                                                                                    tant and James B. Thomson is an assistant
 Banking, Finance, and Urban Affairs of the        formation Services, 1991.
                                                                                                    vice president and economist at the Federal
 House of Representatives, 101 Cong. 1             10. Kane states that"... unlike a private sal-   Resen'e Bank of Cleveland.
 Sess., October 4, 19, and November 6, 13,         vor, the RTC is saddled with the additional
 1989 (Government Printing Office, 1989),          objective of slowing down official recogni-        The views staled herein are those of the
 pp. 290-326.                                      tion of the full size of FSLIC's losses." See    authors and not necessarily those of the
                                                   Kane, "Principal-Agent Problems."                Federal Resen'e Bank of Cleveland or of the
2. At the end of February 1991, 190 thrifts
                                                                                                    Board of Governors of the Federal Reserve
were operating in RTC conservatorship, and                                                          System.
another 320 thrifts supervised by the Office of
Thrift Supervision were considered marginal.
We define a thrift as marginal if it is not in
RTC conservatorship (as of February 28,
1991) and has a total net worth of less than 3
percent of assets on December 31,1990.
Annual Report 1990 Now Available

Essay Examines How Banks
Are Weakened by Overprotection
According to the essay in the Federal        "Unfortunately," explains the essay,          Regulations could be gradually elimi-
Reserve Bank of Cleveland's Annual           "the common view of bank failures,            nated, suggests the essay, so that banks
Report 1990, regulation—rather than          which is rooted in the financial collapse     are subject to the same market forces
market forces—has guided the devel-          of the 1930s, is misleading. It over-         as are unregulated, unprotected finan-
opment of the U.S. banking system and        emphasizes the likelihood and effects         cial firms. "The result," says the essay,
has ultimately reduced its efficiency,       of financial fragility and has been used      "would be a more efficient, competi-
stability, and competitiveness. "Since       to justify restrictions, regulations, and a   tive, and stable financial system that
all industries exist in a constantly         safety net to protect the banking indus-      will not need to rely on taxpayer subsi-
changing environment," states the            try and the public. A closer look at the      dies to compete, or even survive, in the
essay, "this 'protection' actually creates   forces that led to the Great Depression       financial marketplace."
vulnerability and increases the costs of     and other, earlier panics seems to indi-
bank failures."                              cate that poor monetary policy decisions      Annual Report 1990 is available from
                                             and a lack of timely, reliable informa-       the Public Affairs and Bank Relations
The essay, entitled "The Banking In-         tion caused the crises, not an inherent       Department of the Federal Reserve
dustry: Withering Under the Umbrella         weakness of banks."                           Bank of Cleveland at 216/579-3079.
of Protection," indicates that U.S. bank-
ing regulations and guarantees "have         The essay documents the decline in the
been shaped by a belief that banking is      relative importance of banks in the
'special.' This belief is based on the       financial services market. Other firms,
fear that the economy is especially vul-     such as finance companies, insurance
nerable to banking failures, panics, and     companies, and brokerage houses, now
other malfunctions in banking markets.       provide the same services as banks—
                                             without special regulations and guaran-
                                             tees. Consequently, treating banks as
                                             separate, unique firms is unnecessary.




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