"At the crudest level, banks borrow money from people who want to earn a safe return (e.g., mum and pop savers and corporations that need to park cash) and lend that money back out at higher rates of interest to people that want to borrow to build or buy stuff (e.g., home owners and businesses). A bank sits in the middle and takes the “spread” between the rate of interest it pays to savers, who are actually lenders to the bank, and the return it gets from people that borrow from it.
In this way, the bank is the ultimate “middle man”, inducing people to save and borrow while clipping tickets along the way. Don't get me wrong: we need them, as the conversion of savings into loans is the lifeblood of any economy.
The fundamental problem with banks is that there is typically an enormous mismatch between the respective terms (or maturity dates) of their “sources” and “uses” of funding. When we put our money into a bank account we like to have the flexibility to withdraw that cash at any time. But the wrinkle here is that the bank then uses that money to make 30-year home loans. Blind Freddy can see that if everyone demands their cash back at the same time the bank is going to be in strife...
...The objective of the latest batch of banking rule changes is, unsurprisingly, to try and more closely match the terms associated with the banks’ different sources of funding. That is, to better align the life of a bank’s assets with the life of its liabilities. More simply stated, the regulators are saying to banks: we want you to reduce your reliance on short-term borrowings if you are going to continue to make long-term loans.
While, ironically, the shortest term of all funding sources is an “at-call” retail deposit, regulators take the view that this money can be dependable if: (1) the customer has an established transactional relationship with the bank; (2) the customer is relatively small and unsophisticated (more sophisticated investors are more likely to run during a crisis); and (3) if there is some form of government insurance or guarantee protecting depositors. That is, of course, a simplified summary.
Under the new rules, banks have to show they have enough immediately accessible, or “liquid”, cash available to cover a “bank run” over a 30-day period. So if a bunch of people demand their money back from the bank, the bank can actually pay them out.
Take our biggest bank, CBA. It gets about 60% of its funding from depositors, who are lenders to it. CBA will now have to show the bank regulator in Australia that if a significant share of its short-term funding flees because of some unforeseen financial mess-up, it has enough cash on hand to meet these repayments.
In boffin-speak this test is formally known as the “Liquidity Coverage Ratio” (or LCR). To meet the LCR, banks in overseas countries will be forced to hold – rather ironically – a certain sum of government debt securities.
The target LCR is 100%: that is, banks have to demonstrate that they can sell their liquid assets and meet 100% of the redemptions projected during a 30-day crisis. (Expect to see banks offer products with 30-day notice periods for withdrawals to cutely circumvent this rule.)
Since Australia does not have much government debt, our banks will be treated differently. Specifically, they will be able to borrow from taxpayers via the RBA in order to pay their creditors. We will, of course, charge them a fee for this service.
A second major test will require banks to show that they have a minimum amount of “stable” funding to match the longer-term loans they make using that money. Roughly speaking, these two variables will have to (sensibly) match each other one-for-one.
Once again, if a retail depositor is small, unsophisticated, and has a long-term transactional relationship with the bank, it may be regarded as a stable source of funding under the new regulations.
By understanding these new rules, you can start to work out what kinds of product changes the banks will want to make. For instance, we will likely see banks trying to attract lots of small retail depositors whom they can convert into long-term transactional clients. They will also be seeking to subtly lock customers into lending money to the bank for longer periods of time, even if these lock-ups are non-obvious.
There are already a few practical examples emerging in the market. One is the “teaser” rates that you increasingly see the likes of ING Direct, UBank, and Rabo Direct advertise. These are the opposite of the “honeymoon” rates some lenders attach to their home loans.
Teasers are all about cheaply acquiring low-tech customers who will be incented to stay in transactional accounts for at least four months. Such folks have a good chance of eventually falling into the bank’s all-important “stable” funding basket.
Along these lines, ING Direct promotes a “6.35% per annum” savings account. To be clear, you can never earn a 6.35% interest rate over any 12-month period with this product (taking as given no change to the RBA’s rate). This is because you only get the high 6.35% rate for the first four months, after which it drops down to a much lower 5% rate.
Accordingly, if you hold the account for a year, you are actually getting a circa 5.45% per annum rate, which is substantially less than ING Direct’s one-year term deposit rate of 5.7%. You are also restricted to investing a maximum of $250,000.
Rabo Direct offers a similar product. You can only invest $200,000 and get a high “bonus” interest rate for the first four months, following which it reverts to the lower standard rate.
UBank runs a slightly different “special” that gives you an extra 0.5% per annum over its basic variable rate as long as you keep adding $200 to the account every month (thereby demonstrating your long-term “commitment” to it), and on the proviso that you invest no more than $200,000.
Perhaps the most subtle product catches I have seen come with term deposits (TDs). I only discovered these traps by reading the very fine print in the terms and conditions. You see, I and most other people presume that with a TD you can take your money out at any time subject to an interest rate penalty. That is, you don’t get the higher TD rate if you pull out.
As it happens, this assumption is incorrect. In the two TDs I checked – one offered by a major bank and another supplied by a smaller one – the bank, and only the bank, has exclusive “discretion” as to whether it “allows you” to take your money out of the TD before maturity.
I had a sneaking suspicion there would be a catch like this because the banks need to show that TDs are long-term sources of funding, and that depositors cannot simply exit en masse.
In the major bank’s fine print, it says, “you may apply to the bank…to request the withdrawal or all or part of your funds prior to the maturity date. The Bank may, in its discretion, approve a request for early withdrawal”, in which case you are also charged a prepayment penalty and a fee.
This is carefully worded legalese that means the bank can, in its sole judgment, reject your application to withdraw your money (it is just not stated that way).
How big are the penalties the banks charge you if they “allow you” to withdraw your money from a TD? With this major bank, if you wanted to take out your money 20% of the way into the TD’s term, you would lose 90% of all your interest. If you withdraw 40% into the term, you lose 80%, and so on. These are very big penalties, and have a termination fee added on top.
An example of similar language is found in the terms and conditions of a TD offered by a smaller bank. They say, “We may, at your request, allow you to break your Term Deposit before maturity… You must pay a termination fee if we allow you to terminate your Term Deposit prior to its maturity.”
If this bank “allows you” to break the TD, it is then permitted to charge potentially substantial “break costs” much like the early repayment fees associated with a fixed-rate home loan. Specifically, it says:
“Break costs reflect future cash flow losses incurred by us as a result of interest rate differentials that exist between wholesale market rates applicable to the existing term deposit and current wholesale market rates applicable for the remaining period of the term deposit, adjusted to reflect a net present value. Break costs increase in line with increases in the following: interest rates, the amount withdrawn and the market margin.”
The sleight-of-hand extends to the marketing strategies used to promote TDs. Take this “screen shot” from Rabo Direct’s webpage (see below). Now what number leaps out at you? Why, a stunning 6.4% per annum interest rate? Notice that there is no asterisk next to this rate, but just the lightly shaded words in the top left-hand corner of the bold blue box. Yes, the words that attach the caveat “Up to”. Hard to see, isn’t it?
As it turns out, this super-duper 6.4% per annum interest rate only applies to Rabo’s five-year term deposit. So what is the much more popular one year TD rate? A substantially lower 5.5% per annum.
The bottom line is that banks are having to evolve their businesses. The policy objective is to make them safer and less prone to failure. This is a good thing. Just be aware that your money may be part of the solution. And all investments, event term deposits, carry risks. Accordingly, do your homework before you enter into one."
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