One of the predictable though unintended consequences of Frankendodd (and its European cousins) will be to increase concentration in the banking sector. Not just predictable: predicted, including by me (notably at the JP Morgan Commodity Conference in October 2011, and here on SWP).
The logic is fairly straightforward. Frankendodd creates a huge regulatory overhead that in turn leads to scale economies. Smaller-to-medium-sized entities will not be able to afford these overhead costs, and will exit the business, and the bigger firms will get bigger. The overall level of activity is likely to go down as a result of the exit and expansion, but the biggest firms are likely to get bigger even if the market overall gets smaller. Moreover, the capital and collateral requirements in Frankendodd, including in the derivatives title, have disparate impacts on different market participants Since the smaller entities typically have higher capital costs than the bigger ones, this increase in capital needs to support trading businesses in particular will lead the smaller market participants to contract more than the bigger ones; this increase in their capital costs may also induce them to exit altogether, especially when taken in conjunction with the increase in regulatory overhead associated with trading businesses in particular
Given that Frankendodd was allegedly intended to address the too big to fail problem, it is perverse that one of its predictable consequences is to increase concentration, and likely increase the size of the biggest firms in the market.
We may be seeing the first major move in this direction, just as Frankendodd’s big boot is starting to kick in. Morgan Stanley announced deep job cuts, and rumors are flying that it will exit the fixed income trading business:
Now the storied company — whose take-no-prisoners trading desks have at times been rivaled only by firms like Goldman Sachs — is cutting even deeper, raising questions among some on Wall Street about whether it should spin off or ditch much of its trading business as its Swiss rival UBS has, a suggestion the firm eschews.
. . . .
Morgan Stanley’s board, said people briefed on the matter, has discussed closing its fixed-income department. Instead, the firm is shrinking the unit, arguing that it is important to offer its customers those trading services. By cutting jobs and costs and exiting lines like structured products and other complex financial investments and focusing on less risky, less capital-intensive businesses like the trading of interest rates, executives contended that the division can generate a healthy return.
So they’ve discussed it, but decided to keep it in a shrunken state. But it may have to revisit the more drastic measure:
In recent years, the fixed-income department has not been able to make enough money to cover the cost to Morgan Stanley of this capital, according to people briefed on the matter but not authorized to speak on the record
If it hasn’t covered its cost of capital pre-Frankendodd, lotsa luck with covering it afterwards.
Frankendodd will cause a contraction of the financial sector, which isn’t necessarily a bad thing. But the contraction will be uneven, and the fundamental nature of Frankendodd favors a relative expansion, and perhaps an absolute expansion, in the biggest-the JP Morgans and Goldmans and Deutsche Banks.
Hardly what was intended. But that’s different to say it wasn’t predictable.