The U.S. Treasury Asset Relief Plan and Government
Bailouts Throughout the World
GLOBAL
The Economic Recovery Act of 2008 in the
United States had several provisions to pro-
mote recovery from the subprime financial
crisis. The most important was the Treasury
Asset Relief Plan (TARP), which authorized
the U.S. Treasury to spend US$700 billion
purchasing subprime mortgage assets from
troubled financial institutions or to inject cap-
ital into banking institutions. The hope was
that by buying subprime assets, their price
would rise above fire-sale prices, thus creat-
ing a market for them, while at the same time
increasing capital in financial institutions.
Along with injections of capital, this would
enable these institutions to start lending
again. In addition, the Act raised the federal
deposit insurance limit temporarily from
US$100 000 to US$250 000 in order to limit
withdrawals from banks and required the
U.S. Treasury, as the owner of these assets, to
encourage the servicers of the underlying
mortgages to restructure them to minimize
foreclosures. Shortly thereafter, the Federal
Deposit Insurance Corporation (FDIC) put in
place a guarantee for certain debt newly
issued by banks, and the Treasury guaran-
teed money market mutual fund shares at par
value for one year.
The spreading bank failures in Europe in
the fall of 2008 led to bailouts of financial
institutions: the Netherlands, Belgium, and
Luxembourg injected US$16 billion to prop
up Fortis, a major European bank; the
Netherlands injected US$13 billion into ING,
a banking and insurance giant; Germany
provided a US$50 billion rescue package for
Hypo Real Estate Holdings; and Iceland took
over its three largest banks after the banking
system collapsed. Ireland s government guar-
anteed all the deposits of its commercial
banks as well as interbank lending, as did
Greece. Spain implemented a bailout pack-
age similar to the United States to buy up to
50 billion euros of assets in their banks in
order to encourage them to lend. The U.K.
Treasury set up a bailout plan with a similar
price tag to that of the U.S. Treasury s plan of
400 billion pounds. It guaranteed 250 billion
pounds of bank liabilities, added 100 billion
pounds to a facility that swaps these assets
for government bonds, and allowed the U.K.
government to buy up to 50 billion pounds
of equity stakes in British banks. Bailout
plans to the tune of over US$100 billion in
South Korea, US$200 billion in Sweden,
US$400 billion in France, and US$500 billion
in Germany, all of which guaranteed debt of
their banks as well as injecting capital into
them, then followed. Both the scale of these
bailout packages and the degree of interna-
tional coordination was unprecedented.
212
PA R T I I I
Financial Institutions
Canadian banks also had their problems during the recent turbulent financial con-
ditions. Their shares fell by almost 50% and some of them experienced huge losses
in derivatives trading; for example, CIBC lost $2.1 billion in derivatives trading in
2008. However, while governments in the United States and Europe have been
working on full scale banking bailouts and rescue packages (in the trillions of dol-
lars), the Canadian government did not have to bail out any banks.
One reason that Canada s banks have fared better than banks in other coun-
tries is the structure of the Canadian mortgage market. Unlike banks in the United
States that sold the bulk of their mortgages, banks in Canada held a large propor-
tion of their mortgages on their balance sheets. This practice gave Canadian banks
an incentive to make sure that their mortgage loans were good loans. In addition,
law in Canada allows banks to go after other assets when a consumer walks away
from a mortgage, thereby making it difficult for consumers to do so.
Another reason is that Canada s big banks have been more conservative in their
lending and acquisition practices in comparison with major banks around the
world. Also, Canada s top banking regulator, the Office of the Superintendent of
Financial Institutions (OSFI), has been more conservative than banking regulators
in the United States and Europe. For example, at the beginning of the financial cri-
sis, Canada s banks had higher capital requirements than their global peers. As a
result, they had stronger reserves to cushion potential losses. Although this con-
servative regulatory regime enabled Canadian banks to withstand the financial cri-
sis better than banks in other countries, it has been argued that it makes the
Canadian banking sector less competitive because of the lower leverage and a
lower rate of return on capital than in other jurisdictions.
Moreover, the activities of Canada s banks are well diversified and are not lim-
ited to traditional retail banking. In particular, the federal government s decision in
the late 1980s to allow banks to acquire investment brokers on Bay Street and to
engage in the mutual fund and insurance businesses created a more diversified
financial services marketplace for Canada s banks. In addition, these arm s-length
institutions are subject to the same strict rules and regulations as the banks, unlike
investment dealers in the United States that had been subject to very relaxed and
minimal regulation from the Securities and Exchange Commission.
Overall, in the aftermath of the global economic meltdown, Canada s banking
system has been viewed as the soundest in the world. In fact, many countries
around the world are now considering Canadian-style reforms of their financial
markets.
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