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Commercial Paper Funding Facility: The Federal Reserve Becomes a CP Dealer

One-pager From the Fed

Here it is. That’s the Fed’s announcement of two new facilities.

The Commercial Paper Funding Facility (CPFF) will create credit, to be made available to a “Special Purpose Vehicle” (SPV), as authorized under Section 13(3) (the “unusual and exigent circumstances” section) of the Federal Reserve Act.

The SPV is authorized to purchase three-month dollar-denominated commercial paper from eligible issuers. There isn’t a lot of detail in the one-page Terms and Conditions document released by the Fed this morning, but what there is, I’ll explain to you now.


The “exigent and unusual” circumstances that the Fed is responding to relate to disorders in the capital markets where business corporations go to borrow short-term funds. This funding (“commercial paper”) is necessary to smooth out mismatches between revenues and expenses, including payrolls.

The dysfunction in the CP market is the reason why all the news media have been feeding you scare stories about your paycheck bouncing. And at the margin, these concerns are real. This isn’t something you can just ignore.

CP is normally about a $1.5 trillion market, but in recent weeks it’s shrunk precipitously as interest rates have risen, and a lot of money has become just plain unavailable for buying CP.

Where does the money come from? A lot of it comes from money-market mutual funds. And a lot of MM fund managers are very concerned that you, the public, will want to yank your money out the next time there’s a bit of panic. So they’re tending to hold cash rather than assets.

That means there’s that much less money available for companies to borrow on anything but an overnight basis.

The current state of play in credit markets, generally speaking, is that banks and other financial intermediaries have become extremely reluctant to lend money to anyone who doesn’t have risk-free Treasury securities as collateral for any period longer than overnight.

Into this breach rides the Fed. With this new CP facility, their intention is to make funding available to buy CP from qualified issuers who are having a hard time borrowing today.

CP comes in two flavors: asset-backed and unsecured. The new CPFF will be able to buy both kinds. Issuers must meet some standard credit-quality metrics, and unsecured issuers must also meet a range of security requirements, including the payment of upfront fees to the Fed.

There’s no restriction that the CPFF will only buy CP from financial companies or industrial companies. Everyone is eligible, subject to credit rating.

At what price will the Fed buy CP? They’re using a derivative of a market rate called three-month OIS. (Overnight-index swap spread rate. Don’t ask.) They haven’t decided how to set their prices, but they suggest that they will price 100 basis points above OIS on any given day.

That’s theoretically a penalty interest rate. The idea is that (as with the Fed’s discount window), the CPFF would only be used as an emergency backstop in case funds aren’t available otherwise. You’d never prefer to sell CP to the Fed if there were a private lender in the market, because theoretically the private rate would always be lower.

There are limits on how much CP any given issuer can sell to the Fed, and the whole facility is scheduled to expire on April 30, 2009.

So, there are some interesting questions around this.

First, what’s the problem it’s intended to solve? It seems to me that the CPFF will relieve the pressure on creditworthy borrowers for short-term cash, and thus forestall the potential for some really evil disruptions that can affect the Main St. economy. That’s good.

But can this facility address the basic reluctance of institutional money managers to buy CP in the first place? The answer is not necessarily yes. These fund managers may be perfectly relieved that the Fed has stepped into the vacuum they’ve left, and continue to sit on short-term cash.

If that happens, and I think it’s very likely, then we’re in a situation where the Fed will be mainlining risk-free capital into the economy, just to keep it going.

How can we ever bring that situation to an end? Well, the Fed could steadily increase the spread over OIS at which it bids for CP, and it can steadily reduce the amounts of its purchases.

That’s like taking the patient off life support. You don’t know that the patient’s heart will start beating on its own until you try it.

If you don’t find it a little hair-raising that I’m using metaphors like that to talk about the global financial system, you’re not paying attention.

To close this, I want to raise an issue that hasn’t gotten a lot of attention yet, but will become a big topic over the next several years and even decades.

This is the first major financial crisis that is being addressed primarily by way of the Bernanke Doctrine, and we have no clue yet as to the unintended consequences playing out before our eyes.

You know that Bernanke is a life-long student of the Great Depression, and has written extensively on the policy errors made by the Fed in the 1928-1933 period. He’s bound and determined not to repeat those errors.

The Bernanke Doctrine is that in times of acute financial stress, central banks must provide as much liquidity, as early as possible. A key objective is to prevent financial stresses from being transmitted to the real economy of goods and services, or from Wall Street to Main Street (assuming you’re not sick and tired of that metaphor).

And this doctrine has been applied over and over during the fourteen months since the credit crisis first ignited.

Well, one of the bizarre features of today’s world is extreme aversion to counterparty risk. People are going out of their way to avoid trading with anyone but governments or central banks.

Why? Well, maybe it’s because the Fed, the European Central Bank and others have stepped up to such a great extent. The normal process by which people evaluate counterparty risk and do business with each other, may have been circumvented because the Fed has made it possible not to bother with it.

Just a thought.

-Francis Cianfrocca

COMMENTS

  • Strelnikov

    An excellent summary of this somewhat arcane maneuver!

    Is it your opinion that we should let more institutions fail to get to the bottom more quickly, so that the next rise can begin?

    If they should fail, then fine. But it would not seem proper to let panic cause an otherwise healthy (or healthy enough) financial company to fall.

  • Charles_Beauchamp

    This is the first major financial crisis that is being addressed primarily by way of the Bernanke Doctrine, and we have no clue yet as to the unintended consequences playing out before our eyes.

    Francis,

    I think the next step is inflation. How can we possibly inject this much liquidity into the system and avoid inflation? I know this had to be done, but the size of the injections is just so large. My personal views are that we can live with a small amount of inflation above the norm, but what happens if it becomes a problem? There are only two answers to that question:

    1. Take money out of the market through buybacks. This is unlikely with the size of the commitments they have put out there.

    2. Increase interest rates. Which I think could do severe damage.

    Just interested in your thoughts.

    We need spell check on this thing.

  • MrSandman
    SUBJECT: REQUEST FOR URGENT BUSINESS RELATIONSHIP
    
    DEAR AMERICAN:
    
    I NEED TO ASK YOU TO SUPPORT AN URGENT SECRET BUSINESS RELATIONSHIP WITH A TRANSFER OF FUNDS OF GREAT MAGNITUDE.
    
    I AM MINISTRY OF THE TREASURY OF THE REPUBLIC OF AMERICA. MY COUNTRY HAS HAD CRISIS THAT HAS CAUSED THE NEED FOR LARGE TRANSFER OF FUNDS OF 800 BILLION DOLLARS US. IF YOU WOULD ASSIST ME IN THIS TRANSFER, IT WOULD BE MOST PROFITABLE TO YOU.
    
    I AM WORKING WITH MR. PHIL GRAMM, LOBBYIST FOR UBS, WHO WILL BE MY REPLACEMENT AS MINISTRY OF THE TREASURY IN JANUARY. AS A SENATOR, YOU MAY KNOW HIM AS THE LEADER OF THE AMERICAN BANKING DEREGULATION MOVEMENT IN THE 1990S. THIS TRANSACTION IS 100% SAFE.
    
    THIS IS A MATTER OF GREAT URGENCY. WE NEED A BLANK CHECK. WE NEED THE FUNDS AS QUICKLY AS POSSIBLE. WE CANNOT DIRECTLY TRANSFER THESE FUNDS IN THE NAMES OF OUR CLOSE FRIENDS BECAUSE WE ARE CONSTANTLY UNDER SURVEILLANCE. MY FAMILY LAWYER ADVISED ME THAT I SHOULD LOOK FOR A RELIABLE AND TRUSTWORTHY PERSON WHO WILL ACT AS A NEXT OF KIN SO THE FUNDS CAN BE TRANSFERRED.
    
    PLEASE REPLY WITH ALL OF YOUR BANK ACCOUNT, IRA AND COLLEGE FUND ACCOUNT NUMBERS AND THOSE OF YOUR CHILDREN AND GRANDCHILDREN TO WALLSTREETBAILOUT@TREASURY.GOV SO THAT WE MAY TRANSFER YOUR COMMISSION FOR THIS TRANSACTION. AFTER I RECEIVE THAT INFORMATION, I WILL RESPOND WITH DETAILED INFORMATION ABOUT SAFEGUARDS THAT WILL BE USED TO PROTECT THE FUNDS.
    
    YOURS FAITHFULLY MINISTER OF TREASURY PAULSON
    
    • Charles_Beauchamp

      Didn’t mean to bold that above. I am still learning a bit here with the posting engine.

      • blackhedd

        “Injecting liquidity” is generally done with repo transactions that generally expire in anywhere from one day to 28 days. Some of the emergency facilities (TAF, TSLP, etc.) go for 84 days.

        Your phrase was “taking money out through buybacks.” That’s basically what they do.

        Throughout the process, the Fed have been careful to keep the permanent money supply from expanding. I think they have more room now that the commodity bubble has abated somewhat.

        Don’t worry about inflation. Worry about deflation.

        • MrSandman

          not sure whats the deal with that post…

          sorry for the font paux…

          • Charles_Beauchamp

            Thanks, that cleared-up my inflation fears. But the deflation issue (I hadn’t really given that much consideration) is huge. I guess I can increase my Mylanta dose a bit more.

            The other issue that is still lingering (in my opinion) is that we are still getting zero leadership on all of this. All in charge (Fed/Treasury/Congress/White House) should be giving better updates of what to expect in the coming days/weeks/months and what they are still concerned about. This is, of course, without giving exact dates, which if not met would be negative for markets. Currently, the only information being delivered to the majority of Americans is from the MSM which generally have limited information but try to rachet-up the severity to help Obama.

          • blackhedd

            ;-)

            Kidding aside, there’s not a lot of information out there because there’s not a lot of knowledge. Even the experts have no idea what the next few weeks and months will bring.

            At the very bottom of the stack, no one knows how low the housing market still has to fall.

  • MrSandman

    Centralization of Credit in the Hands of the State, by Means of a National Bank with State Capital and an Exclusive Monopoly.

    Congratulations Comrades!!
    We now ARE the bank!!
    Doesn’t that make you feel better!!

  • Robert_L_Mayo

    Erick,

    Since a new Cadillac XLR is out of the question, are you sending Blackhedd a T-shirt or RedState mug or something? Lord knows we’d have been lost without him the last few weeks!

    Love,
    Bob

  • streetwise

    One idea – temporarily suspend money market funds ability to charge fees on their risk free overnight holdings.

    Nobody should be paying a fee to them for that.

  • Strelnikov

    What is the buzz on the street? Anybody hear anything about that?

    I would think some people at the top might be pulling out for Swiss Francs and gold coins.

    • blackhedd

      Both have come out in favor of more regulation and against how the financial industry does business.

      But as a rule, market participants don’t think about politics very much.

      • PaRep

        BUT I will disagree with 1 aspect of this post, They’re Deathly afraid of McCain/Palin sicing the watchdogs on them

  • ss396

    I received a happy little mailer from Fidelity the other day, discussing the current financial difficulties and how the credit lock-down had so severely hampered “business as usual” (their phrase).

    “Business as usual” means having the US taxpayer fork over, or otherwise guarantee, a couple hundred billion dollars every ten years or so to bail our financial geniuses out of yet another mess. Time and again. That truly is “business as usual”. Nothing that I have seen or read, including in that whole blessed bill, indicates that that is going to change. This credit facility that has now been created is a bail out, unless and until the Fed can sell this Commercial Paper. And who would buy it, except the folks from whom it was purchased in the first place? And why should those folks want to buy it back?

    So my lingering question is: Will this latest bail out guarantee that we will not have to bail them out again, at least until after 2015?

    If not, then we’ve just wasted a bunch of money. Again.

    • blackhedd

      Do you know what commercial paper actually is? It’s a discount note that a business sells to an investor. It’s the same as borrowing money from the investor. By definition they mature in 270 days or less, and then the borrower pays off the loan with interest.

      CP isn’t a toxic asset needing a bailout. What’s happening here is that no one is willing to lend money, even to the very best borrowers. That’s the void that the Fed is stepping into.

      If you’re concerned about the fecklessness of the policy responses we’ve seen so far, let me ask you a question:

      What would you do, by way of policy, to induce people who have money to lend it to people who need money?

      Because that’s the nut of the problem.

      • Alberta

        there was a recent article in the Financial Post about that.

        • Alberta

          and please be gentle, but isnt that what these injections of cash have been doing? That is the people with money do not know when the gov is going to stop mucking around in the market, and because of that, cant decide when to act?

          Or heres my second attempt. What you are describing is sort of, or maybe is, a liquidity trap, caused by the unwillingness of secondary parties (banks ect.) to lend the money the gov has given them to lend. So the solutions are simple right? We simple give people money. A money gift. Bypass the banks. Im getting a little sick even writing that.

          I happen to think, in all seriousness, that this problem is the bust of the boom. A boom created through government intervention. Why do we think government intervention will ease the problems? If the government put out a statement saying they would not intervene anymore in the market, no more Bear Sterns and AIGs, people would know more concretely where they stood. Then you just have to wait until the bad actors get taken out of the system by the system. Of course I acknowledge that the the core of the whole apple might be rotten, but if that is the case then nothing is going to work anyways, and trying things is just a waste of resources.

          How about paying banks to make loans (as I throw up in my mouth)? I mean, if people are not lending because they fear they wont get there money back, cant the government (puke) guarantee (puke) all the borrowers (puke)? Create incentives to loan?

          • JSobieski

            Don’t classify it as income for corporate or personal income tax purposes.

          • ss396

            What would I do? I would forebear. I see the main driver of this to be a game of chicken. If I am a financial institution with money to lend, and I want to lend it, how would I prefer to structure the risk of lending it?

            I can take on the risk myself, with appropriate pricing and guarantees to cover it. I’m going to charge extra and add a bunch of penalty clauses because, dagnabit, it’s a shaky situation that we are in. And my borrowers aren’t happy at the extra rate and the additional Ts & Cs. All around a bad business.

            Or, I can get the government to take the risk. My paper is much cleaner, and my borrowers are happier because I don’t have to price my paper so high. I might have to surrender some of my controls to the Feds, since they now have a position in me, but I’ve been running circles around these (overworked, understaffed) folks for years; I don’t see that as a major impediment.

            Mr. Cianfrocca, I have tremendous faith in the market economy, that it would not/could not remain frozen for long. I regard the market uncertainty surrounding this mostly as a question of whose money we are going to play with: the Lenders’ or the taxpayers’? If it had been clear early on that a bail out was not going to happen, the institutions would have figured out how to ‘unfreeze’ themselves. It would have been pricey, but I find that to be a better option than is this partial nationalization. We all know from long experience that the Feds do not relinquish that which they control. No power center ever does. The positions that the Feds will have with these companies will be long-standing, and our tax money will be on the hook equally as long. And this still does not address the question of why I, a taxpayer, even belong in this game?

            It was a game of chicken, and Congress blinked: we are going to bail out our financial industry yet again. And probably yet again before the year 2020, because nothing in the bill addresses the underlying problems.

            I further view the bail out as a demonstration of the lack of faith in a market economy by Mssrs. Paulson and Bernecke. These are the gentlemen who will be running the bail out and that frightens me terribly.