Can A Bank Run Be Stopped? Government Guarantees And

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Finance and Economics Discussion SeriesDivisions of Research & Statistics and Monetary AffairsFederal Reserve Board, Washington, D.C.Can a Bank Run Be Stopped? Government Guarantees and theRun on Continental IllinoisMark A. Carlson and Jonathan D. Rose2016-003Please cite this paper as:Carlson, Mark A., and Jonathan D. Rose (2016). “Can a Bank Run Be Stopped? Government Guarantees and the Run on Continental Illinois,” Finance and Economics Discussion Series 2016-003. Washington: Board of Governors of the Federal Reserve TE: Staff working papers in the Finance and Economics Discussion Series (FEDS) are preliminarymaterials circulated to stimulate discussion and critical comment. The analysis and conclusions set forthare those of the authors and do not indicate concurrence by other members of the research staff or theBoard of Governors. References in publications to the Finance and Economics Discussion Series (other thanacknowledgement) should be cleared with the author(s) to protect the tentative character of these papers.

Can a Bank Run Be Stopped?Government Guarantees and the Run on Continental IllinoisMark Carlson **Jonathan Rose *AbstractThis paper analyzes the run on Continental Illinois in 1984. We find that the runslowed but did not stop following an extraordinary government intervention, whichincluded the guarantee of all liabilities of the bank and a commitment to provideongoing liquidity support. Continental’s outflows were driven by a broad set of USand foreign financial institutions. These were large, sophisticated creditors withholdings far in excess of the insurance limit. During the initial run, creditors withrelatively liquid balance sheets nevertheless withdrew more than other creditors,likely reflecting low tolerance to hold illiquid assets. In addition, smaller and moredistant creditors were more likely to withdraw. In the second and more drawn outphase of the run, institutions with relative large exposures to Continental were morelikely to withdraw, reflecting a general unwillingness to have an outsized exposureto a troubled institution even in the absence of credit risk. Finally, we show thatthe concentration of holdings of Continental’s liabilities was a key dynamic in therun and was importantly linked to Continental’s systemic importance.January 21, 2016JEL Classification: G01, G21, H12Keywords: bank runs, deposit insurance, deposit guarantee, financial crisis**Board of Governors of the Federal Reserve and Bank for International Settlements. Mark.carlson@bis.orgBoard of Governors of the Federal Reserve. Jonathan.d.rose@frb.gov.We thank Ed Atkinson for valuable research assistance. We appreciate valuable comments from Pierre Cardin,Joseph Mason, Petra Moser, Larry Wall, and seminar participants at the Bank for International Settlements, StanfordUniversity, American University, and the University of California, Davis. The views presented in this paper aresolely those of the authors and do not necessarily represent those of the Board of Governors, the Bank forInternational Settlements, nor their staffs.*

1 IntroductionContinental Illinois (Continental) was a major US commercial bank that experienced amassive and widely publicized run by its short-term creditors in May 1984. 1 Out of fear thatContinental’s failure would have broad fallout in the financial system, the Federal Reserve andthe FDIC provided funding to the bank, and the FDIC put in place an exceptional guarantee of allof the bank’s creditors (FDIC 1997, 1998). About two months later the FDIC essentially tookover the bank to rehabilitate it. Eventually, Continental was recapitalized and reprivatized;previous shareholders were wiped out and the FDIC absorbed serious losses. This episode iswell known for elevating the neologism “Too Big to Fail” in public consciousness and promptinga national discussion about very large banks. 2In this paper, we study the run on Continental and the impact of the governmentresponse, particularly the FDIC’s guarantee of all bank liabilities. To do so, we use a remarkabledata set, comprising daily data on broad aggregates of Continental’s liabilities and monthly dataon funding provided by a large number of individual creditors. The daily data quickly reveal thatthe run on Continental was immense and extremely swift. In just 9 days, 30 percent of the firm’sprevious funding left and was replaced by new funds from the government and a supportcoalition of private banks. To put the speed of these withdrawals in perspective, Rose (2014)finds that during 2008 the most severe runs on traditional banks affected Washington Mutual andIndyMac. Washington Mutual lost 10 percent of its deposits and IndyMac lost about 8 percent,each in about two weeks. Thus, even in a more digital, seemingly faster moving era, these runswere less dramatic than the one on Continental, while still severe enough to lead to the seizure ofboth institutions by the FDIC.1We generally use the phrase “Continental” to refer to the entire bank holding company, Continental IllinoisCorporation (CIC). The main subsidiary of CIC was Continental Illinois National Bank, which held the great bulkof CIC’s assets. Where specificity is needed we refer specifically to the holding company or the bank subsidiary.2The connection between the bailout of Continental and the origins of the phrase “too big to fail” in the bankregulatory lexicon may have arisen during Comptroller of the Currency Conover’s testimony on September 19, 1984to the House subcommittee on Financial Institutions, Supervision, Regulation, and Insurance. In the session,Congressman St Germain asked Conover whether he could foresee letting one of the eleven international moneycenter banks fail and Conover admitted that, in the absence of a way of handling a large bank subsequent to itsfailure, he could not. Congressman McKinney promptly labeled these large banks as “too big to fail” (Conover1984, p. 300). The press had been using the phrase “too big to fail” since at least July 1984, but this is oftenconsidered the first time a government official indicated that large banks might not be allowed to fail.-1-

The daily data show that the run on Continental proved hard to arrest. The run slowedbut did not stop after the government’s announcement of support in May. Continental’s fundingdid not stabilize until the permanent support program was put in place in July, at which pointalmost half of its funding was being provided by the government. After that, the bank wasfinally able to raise more private funds, on net. These dynamics raise the question of whatincentives creditors had to run. Previous studies of runs have largely focused on the incentivesshaped by deposit insurance or on information from social networks, as those studies havegenerally examined household depositors, often at small savings banks (Brown, Guin, andMorkuetter (2013), Kelly and Ó’Gráda (2000), Ó’Gráda and White (2003), and Iyer and Puri(2012)). In contrast, Continental raised a great part of its funding from creditors who were largeand sophisticated. Many invested more than 1 million in Continental at a time when the depositinsurance limit was 100 thousand. As a result, to understand the decision to run, we focus onthe financial condition and business models of the counterparties, rather than deposit insuranceor social networks.With the monthly data we are able to characterize the types of creditors that were morelikely to run. The run was driven importantly by a broad set of US and foreign financialinstitutions. We gather additional information about the financial condition of the USdepositories in the data set in particular, and estimate a set of simple models to predict whichwere likely to withdraw large amounts. We examine whether their withdrawal patterns wereassociated with indicators related to desires for liquidity, fear of losses, or fear of contagion.Early on, in the run that occurred during May, we find little support that fear of losses droveruns, as measures of the size of direct exposures have little relation to withdrawals. Instead,creditors that held relatively greater amounts of liquid assets on their books and were lessdependent on funding from wholesale markets were more likely to withdraw large amounts,which suggests that liquidity preferences played a role. These results suggest that efforts tobolster the liquidity condition of individual institutions may improve the safety of thoseinstitutions, but it does not necessarily follow that those institutions will be more likely to be asource of stability during a stress situation. In addition, we find that more profitable and smallercreditors were more likely to withdraw.-2-

After May, the data exhibit a different pattern. Unlike during the initial run, we findsome evidence that banks with higher exposures to Continental (relative to their own assets)were more likely to mitigate those exposures by withdrawing. This finding indicates that, eventhough Continental was reportedly paying above market rates on its liabilities, many creditorsdid not feel like they were being adequately compensated for holding onto more substantialexposures to Continental. It could be that creditors were still concerned about potential losses,despite the protection offered by the FDIC, or were concerned about “headline risk” should theybe identified as having a larger exposure to the troubled bank. In addition, in both periods morephysically distant banks tended to withdraw more funds from Continental, perhaps revealinginformation about the quality of geographically proximate creditors’ relationships withContinental.The last part of this paper describes how the concentration of funding in a small numberof large accounts had important implications in this episode. While a broad set of creditorswithdrew funds from Continental, the outflows were quite concentrated among the largestcreditors. For example, Continental’s largest 25 creditors as of April 1984 withdrew about 2billion from April to August, roughly 6 percent of the bank’s total liabilities and about 30 percentof the total withdrawals. Each of these large creditors was owed tens or hundreds of millions ofdollars, far above the insurance limit. Such large short-term creditors have long played key rolesin deposit runs, and deserve special focus in planning for potential future crises.Even if the government support did not stop the funding drain on Continental, it doesappear to have been important in preventing serious spillovers to other institutions and thus incontaining the crisis. Some of the largest providers of funding for Continental were moneymarket mutual funds. It is highly likely that these institutions would have suffered losses and“broken the buck” in the event that Continental had been allowed to fail. As money marketfunds were important providers of funds to many other large financial institutions, even at thistime, problems at money market funds would likely have had systemic consequences. 3 The3While it is not clear that any difficulties would have approached the troubles that occurred in the wake of theLehman Brothers bankruptcy and the “breaking of the buck” by Reserve Fund, it is likely that there would havebeen significant dislocations.-3-

funding data also indicate that several large banking institutions had significant exposures toContinental and that these institutions may have faced significant losses.These findings have important lessons for policymakers. In response to crises, one toolgovernments can employ is to guarantee the liabilities of financial institutions; scholars havestudied such actions and found mixed evidence on their effectiveness (Ingves and Lind 1996,Estrella 2001, Shin 2009, McCabe 2010). Our results suggest that a guarantee of liabilities maynot always be effective in stabilizing the funding of troubled institutions. Relatedly, in thefuture, one method for dealing with an insolvent but systemically important depositoryinstitution could be for the FDIC to place it into a special type of receivership, using its newOrderly Liquidation Authority. This type of receivership is intended to provide for the resolutionof a firm in the long run, and the preservation of the firm’s systemically important operations inthe short run. Under such circumstances, an important question is whether the FDIC would beable to convince short-term creditors to stay. Continental’s experience suggests that obtainingsufficient financing from private sources to keep the firm operating while in receivership may bedifficult.The paper proceeds as follows. Section 2 provides an overview of the crisis atContinental. Section 3 discusses the dynamics of various deposit aggregates during the crisisand section 4 examines the composition of creditors and which creditors were more likely to run.In section 5 we discuss the responses to the FDIC guarantee along with how the responsescompared to other instances of government support. Section 6 discusses the distribution ofliabilities, and the role that concentration played in the run and in shaping Continental’s systemicimportance. Section 7 concludes.Section 2. Overview of the 1984 Crisis at Continental IllinoisContinental was the eighth largest bank in the United States in 1984, following rapidgrowth over the previous several years. Continental’s troubles began on the asset side, as thecredit quality of Continental’s loans to oil and gas companies deteriorated in the early1980s. Some of these loans had been acquired from Penn Square Bank, which failed in1982. Market participants also became concerned about Continental’s loans to entities indeveloping countries in the Americas, particularly after Mexico’s default in 1982. Because of-4-

these developments, Continental’s poor earnings release in April 1982 was taken badly bymarket participants. The release contributed to downgrades of its credit and debt ratings byrating agencies later that year, and also to downgrades by stock analysts of its earningsestimates. 4 This scrutiny created difficulties on the bank’s liability side as well. Continental hadalways been limited in its retail deposit network, since Illinois law forbade any branching. Tofund its expansion, the bank aggressively competed for wholesale deposits. After Penn Square’sfailure, Continental increasingly raised funds in the Eurodollar market rather than in the domesticcommercial paper market, and its funding costs increased. 5 This change in the mix ofContinental’s funding may have left the bank with creditors that were more likely to run later on.Table 1 shows the degree to which the bank had funded its expansion by aggressivelycompeting for wholesale deposits, rather than by the means of a retail banking business. Thetable reports a simple breakdown of Continental’s liabilities at the end of the first quarter of1984. The bank was particularly dependent on foreign deposits (typically eurodollar deposits)which accounted for more than 40 percent of the bank’s liabilities, nearly twice the amount ofdomestic deposits. (Note that both domestic and foreign creditors supplied money to Continentalthrough the eurodollar market.) Continental maintained correspondent relationships with a largenumber of domestic banks and held significant balances connected to these relationships.Continental also provided a variety of services to institutions involved with Chicago financialmarkets, and some of those institutions maintained balances with Continental in connection withthose services. Additionally, Continental funded itself with a moderate amount of fundspurchased on the federal funds and repo markets.Continental’s insurance coverage for its deposits was quite low, with only around 15percent of deposits insured by the FDIC. The low coverage was due to Continental’s reliance onforeign deposits, which are not eligible for FDIC insurance, and the fact that only about 40percent of its domestic deposits were covered by the insurance. 6 Moreover, Continental had asubstantial number of other domestic liabilities that were not covered by insurance.4Moody’s rated the firm Aaa in 1981 but only A3 in 1983 (Moody’s Investor Service 1981 and 1983).This paragraph draws on FDIC (1997, 1998) and US Congress (1984), pp. 54-57.6The most recent insurance coverage information prior to the May 1984 run is from the June 1983 FFIEC CallReport.5-5-

Table 2 compares Continental with the other banks comprising the largest 20 in thecountry, by assets, as of March 1984. The table indicates credit quality problems at Continental,with elevated delinquency rates, charge-off rates, and provisioning for future losses, as well aslower profitability. Continental’s reliance on foreign funds and on fed funds and repos were alsoelevated compared to its peers. The average interest rates it paid for its funds is about in linewith this set of peers, though.Starting about May 7, 1984, rumors circulated that the bank could fail or be forced toseek a merger. 7 On Tuesday May 8, 1984, this rumor, along with a denial by Continental,appeared in Dow Jones Capital Markets Reports. These articles reportedly made financialmarket participants even more concerned about the financial health of Continental andprecipitated a sudden and rapid run on the bank. 8 Consequently, Continental’s funding situationdeteriorated as investors either refused to roll over eurodollar deposits or demanded significantlyhigher rates for renewal. Continental also had difficulty placing large CDs, and investorsholding outstanding CDs reportedly tried to dump them in the secondary market (Bailey andZaslow 1984). To address its funding problems, Continental turned increasingly to the discountwindow (FDIC 1997, Kilborn 1984, Rowe 1984).In response, the banking industry rallied to support Continental. On Monday, May 14,Continental announced that 16 of the nation’s largest commercial banks had agreed to providethe firm with 4.5 billion in short-term credit (Bailey, Carrington, and Hertzberg 1984). 9 Thisaction was reportedly taken in part to shore up the confidence of financial market participants,especially overseas investors, and prevent the crisis from spreading. There were someindications that the provision of this facility eased general conditions; interest rates retreatedsomewhat and the Wall Street Journal reported that markets for managed deposits were calmer(Bailey, Helyar, and Hertzberg 1984). However, other reports indicated that the run on7Prior to this, the most recent piece of news came in late April 1984, when Continental’s announcement of anincrease in nonperforming loans may have increased investor concerns.8For example, The Wall Street Journal reported that “at one point word was spreading at the Chicago Board ofTrade that Continental’s traders had been abruptly called off the floor at the same time Continental’s traders were inprominent view on the other side of the bond trading pit” (Bailey and Zaslow 1984).9Reports from the time widely noted that the Federal Reserve had a tacit role in the formation of this coalition, byproviding private assurances to the coalition members that Continental would be able to borrow up to 17 billionfrom the discount window based on collateral already on deposit with the Chicago FRB. See Rowe (1984b) andBennett (1984). The Federal Reserve’s first public statement regarding Continental came on May 17.-6-

Continental continued as foreign depositors refused to renew CDs and Continental’s sources foreurodollar funding were being withdrawn (FDIC 1997; Sprague 1986, p.154).On Thursday May 17, continuing pressures on Continental led the FDIC, FederalReserve, and the Office of the Comptroller of the Currency to create a temporary assistance plan,announced in a joint news release. This program was a combined effort by these regulatoryagencies and commercial banks. Most importantly, the FDIC announced that it would guaranteeall deposits and general creditors of Continental. 10 The press release stated the FDIC’s guaranteeclearly, but briefly and with few details:In view of all the circumstances surrounding Continental Illinois Bank, the F.D.I.C.provides assurance that, in any arrangements that may be necessary to achieve apermanent solution, all depositors and other general creditors of the bank will be fullyprotected and service to the bank's customers will not be interrupted.This guarantee was particularly important given Continental’s low level of insurance coverage;the FDIC (1998) reported that at this point, Continental had about 3 billion of insured liabilitiesand 30 billion of uninsured liabilities. The guarantee covered all the creditors, including theuninsured liabilities. Liabilities of the bank holding company excluding the bank were notcovered, although these were generally small. 11In the same press release, the FDIC also announced an injection of 2 billion into thebank in the form of subordinated notes provided by itself and a group of commercial banks. TheFederal Reserve stated that it would meet extraordinary liquidity needs, without many furtherdetails. Finally, the 4.5 billion short-term credit facility from 16 commercial banks, which hadbeen initiated on May 14, was replaced by a 5.3 billion line of credit to Continental from aconsortium of 24 banks. The bank support coalition eventually expanded to 28.The regulators stated that the assistance package and guarantee were needed to maintainconfidence and prevent the run on Continental from spreading to other large banks (Conover10Before Continental, we know of one instance in which the FDIC gave an explicit general guarantee of all creditorsto a depository institution: Greenwich Savings Bank in 1982 (see p. 223 of the FDIC (1997), chapter 6).Nevertheless, Continental’s guarantee was of much greater significance given Continental’s size and systemicimportance. In other instances prior to Continental and Greenwich the FDIC had provided open bank assistance totroubled institutions. This assistance involves capital injections, therefore providing protection to the generalcreditors of the institutions being assisted, but not explicit guarantees.11Moody’s reports that at the end of 1983, liabilities of the consolidated company were 40.3 billion of whichnonbank subsidiaries accounted for 1.2 billion.-7-

1984, and Volcker 1984). Of particular concern was that the run on Continental would causefunding problems at other large institutions. The chair of the FDIC argued that “the fundingproblem at Continental was beginning to affect financial markets generally. Something needed tobe done quickly to stabilize the situation” (Isaac 1984, p. 459). FDIC Board Member IrvineSprague reported that regulators believed the collapse of Continental would cause fundingdifficulties at other large banks which in turn would likely bring down two large (unnamed)institutions (Sprague 1986, p. 155). These concerns were reportedly reflected in market data;Bailey and Zaslow (1984) reported a widening of spreads between rates on Treasury Bills andbank CDs for banks other than Continental. 12 Further, Continental had numerous correspondentbanks and the FDIC maintained that the deposits of these smaller banks needed to be guaranteedto keep these institutions from failing (Conover 1984, FDIC 1997). Isaac (1984, pp. 470-474)noted that even if some of the smaller banks might not have failed had Continental closed, theymight have experienced liquidity problems and decreased profitability while Continental wasbeing liquidated.The initial response by regulators and other commercial banks was meant to assureinvestors that there would be sufficient capital, liquidity, and time to arrange an orderlyresolution. It did appear to calm markets for a time, as we will document in the next section.However, starting in late June, concerns gradually re-emerged about the viability of Continentaland the bank experienced renewed outflows of deposits. On July 26, federal regulatorsannounced a permanent assistance plan (FDIC 1998). Under this plan, the FDIC acquired 1billion in preferred stock in Continental’s holding company (an 80 percent stake), with the abilityto convert these shares into common stock at a later date. The FDIC also assumed Continental’sliabilities to the discount window, which had been hovering between 2 billion and 4 billion,and in return received an equal amount of loans held by Continental in its asset portfolio, alongwith an option to buy stock in Continental at a rate that depended on the recovery rate on theloans. The Federal Reserve also agreed to continue to provide liquidity assistance (and thecommercial banks continued to extend a line of credit). The permanent assistance plan was put12Similarly, Goldsmith-Pinkham and Yorulmazer (2010) find that when the British bank Northern Rockexperienced a run that other banks paid more for their money market and interbank liabilities, especially those moredepending on money market funding.-8-

into place in September, and was successful in preventing Continental from being closed.Discount window borrowings by the bank edged up briefly following the July announcement, butthen declined steadily as the firm was able to use market sources to a greater extent. Financialmarkets remained orderly. However, the assistance plan was one of the most expensive everarranged by financial regulators at the time: the FDIC estimated its cost for the bailout at 1.1billion and Continental’s shareholders were essentially wiped out. 13Section 3. The run by type of liabilityDaily data on Continentals’ liabilities from May 8 to August 29, 1984, presented inFigure 1, show the timing of the outflows on an aggregate basis. 14 Between the end of 1983 andMay 8, there had been only a slight decline in Continental’s liabilities. Once the run started,though, private sector funding dropped quickly: between May 8 and May 17, private sector fundsdeclined by about 10 billion, or about 30 percent of Continental’s liabilities. Private sectorfunds were largely replaced with funds from the government—either the FDIC or the FederalReserve—and from the support collation of large banks. 15 Altogether, this support quicklytotaled almost 9 billion (in addition to funds that the banks in the support coalition had alreadybeen supplying Continental).These data show that the announcement of the interim support package arrested the steeprun-off in deposits, as non-support liabilities were roughly stable for a while. However in lateJune and early July there was a renewed decline. Between May 17 and July 26, when thepermanent assistance program was announced, non-support liabilities declined by another 7billion. Support by the government and bank coalition increased only 3.6 billion, so that totalliabilities contracted. Even after the announcement of permanent support, non-support liabilitiescontinued to decline, but more modestly. At the end of August, the amount of non-support andsupport liabilities were nearly equal. Altogether, between May 17 and August 29, non-support13If its losses exceeded 800 million, the FDIC’s call option allowed it to purchase all 40.3 million of the holdingcompany’s outstanding stock shares at a price of 0.00001 per share, or about 400. The FDIC ended up exercisingthis option.14This information was presumably provided to the Federal Reserve as part of the monitoring of the firm.15The members of the support coalition identified themselves publicly. The 28-member coalition ultimatelycomprised the largest 20 commercial banks outside of Continental, and 8 additional banks.-9-

liabilities declined 9 billion, almost as much as during the initial run. Thus, while the FDICguarantee clearly slowed the withdrawal of funds, it also clearly did not completely convincecreditors to remain.Figure 2 shows more detail regarding the composition of the decline in private, noncoalition liabilities. All types of liabilities declined during the run on Continental. The steepestdrop occurred in federal funds purchased and reverse repurchase (repo) transactions, whichcontracted 77 percent. 16 Offshore and domestic deposits also both declined during the initial run.Following the interim support announcement, the fed funds and repo liabilities rebounded andthen stabilized somewhat. Deposits continued to decline after the interim support announcement,especially offshore deposits, though at a slower pace than during the initial run. 17 After theannouncement of the permanent assistance package, domestic deposits, fed funds, and repoliabilities stabilized, but offshore deposits declined a bit more.Section 4. Composition of creditors and runnersTo analyze the composition of creditors, and gain insights into which ones were mostlikely to run, we also have data on the individual liability holdings of nearly 600 institutions at amonth-average frequency during 1984. 18 The list was compiled by Continental’s TreasuryServices Division. (For brevity, we refer to these as the CTS reports.) It is not a complete list ofall creditors, and the selection process is unknown to us, but the list evidently comprises a groupthat Continental’s Treasury department deemed important enough to track with a monthly report.Most likely, this is a list of the institutions who provided Continental with largest amounts offunding in 1984 or in recent years. We view our data as most representative of large depositorsthat are least likely to be insured and most likely to run, and which are the types of depositors ofmost interest to us in this investigation.16Many Eurodollar deposits had 3-month maturities, which could affect the rate at which this type of fundingdropped. However, a House of Representatives Staff Report (House of Representatives 1984) found that in somecases Continental was forced to prepay such deposits.17Domestic deposits includes items such as demand deposits, retail savings, commercial certifi

Jan 21, 2016 · We generally use the phrase “Continental” to refer to theentire bank holding company, Continental Illinois Corporation (CIC). The main subsidiary of CIC was Continental Illinois National Bank, which held the great bulk of CIC’s assets. Where specificity is needed we refer spec

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