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European
Integration
The single EC capital
market
Capital markets will be at least as affected as goods markets by the
EC's drive for greater economic integration. Plans for a `European
financial area' centre on the removal of capital controls by 1 July
1990, with far-reaching consequences for the EMS and for cross-border
investment. The move towards EC-wide regulation of financial services
has generated Directives on capital adequacy, solvency ratios, own
funds, investment services and banking coordination. Plans for Economic
and Monetary Union foreshadow fundamental upheavals at the heart of the
financial system, in central banking and monetary and fiscal policy.
It is hard enough to foresee how each of these measures separately, let
alone all together, will affect economic performance, financial
stability and corporate finance. The challenge to the economics
profession is considerable. During 1990/1, CEPR is conducting a major
research programme on `Financial and Monetary Integration in Europe',
directed by Francesco Giavazzi, Charles Wyplosz and Marcus Miller. On
22/24 January, the Centre collaborated with the Istituto Mobiliare
Italiano in holding a conference in Rome on `European Financial
Integration'. It was organized by Alberto Giovannini, a Research
Fellow in the Centre's International Macroeconomics programme, and Colin
Mayer, Co-Director of the Applied Microeconomics programme. CEPR is
grateful to IMI, and in particular its Director General Rainer Masera,
for its support and cooperation and to the Ford and Alfred P Sloan
Foundations for additional financing.
Structure and Regulation of Integrated Markets
After 1992, firms will increasingly issue securities on a Europe-wide
basis, but national and even regional stock exchanges are set to
continue. The desirability of preserving or integrating these markets is
determined by a trade-off: a central trading market improves the quality
of price signalling and order execution, because all the orders
available in the market can interact, while inter-market competition
should bring down execution costs and encourage innovation. In `How
(Not) to Integrate the European Capital Markets', Yakov Amihud
(New York University) and Haim Mendelson (Stanford University)
examined how market structure affects incentives to place different
orders and hence liquidity. Unlike `market orders', which are executed
immediately, `limit orders' specify a price but not the time and
likelihood of execution. `Quotes' are commitments to buy or sell
specified quantities at a specified price in some time interval.
Limit orders and quotes supply immediate liquidity, without which the
market will become volatile with individual market orders resulting in
large price swings, and they provide other investors and dealers with
valuable information with which to assess the value of assets. These
positive externalities mean markets need rules that give adequate
incentives to place limit orders, Amihud and Mendelson stressed,
especially governing the sequence in which orders are executed. Traders
will anyway enforce `price priority' because investors want to execute
their orders at the best price. Secondary priorities need to be
preserved by design. Market structure must at least enforce time
priority, ensuring two similar orders are executed in the order they
were placed, and perhaps other rules which, other things equal, give
priority to larger limit orders or to orders placed by market-makers.
The authors criticized order-routing mechanisms, such as the Intermarket
Trading System linking US equity markets, on the grounds that they
prolong execution time and disregard all secondary priority rules. And
rather than homogenizing markets, they advocated a modular system
enabling investors to choose among markets with different operating
mechanisms. Exchanges need only accept common communication and
information mechanisms to fit into such a system. Amihud and Mendelson
also proposed a new `clearing transaction' facility, similar to the
call-market method employed by some exchanges, but allowing simultaneous
calculation and execution of accumulated limit orders, which could be
conditional on any number of securities prices.
The EC Commission proposes to establish minimum standards for the
regulation of financial services, including a minimum capital
requirement of 250,000 ecu for investment businesses. In `The Design and
Implementation of Financial Regulation', Colin Mayer (City
University Business School and CEPR) and Damien Neven (Institut
Européen d'Administration des Affaires (INSEAD) and CEPR) criticized
these proposals for treating investment managers, pension funds, life
assurance firms, brokers and dealers in equities and in bonds similarly
to banks. The risks associated with banks, especially the fear of runs
on deposits spreading contagiously through the system, encourage the
authorities to impose capital requirements.
Such `systemic' risks are not in general a feature of other financial
institutions, Mayer and Neven argued. Firms that merely advise clients
on portfolio administration and do not directly manage these investments
pose few such risks, and there is evidence of a poor relation between
investment managers' performance and the amount of capital at their
disposal. For such firms, regulation should focus on investor protection
more like the regulation of professions such as accountants, doctors and
lawyers than of banks. Firms that make markets in stocks, on the other
hand, handle large amounts of money and securities, and to diminish the
risk of their default should be subject to more onerous capital
requirements than investment advisers. The authors also argued that
self-regulation is appropriate for some services, where potential
investor losses are modest and where clubs containing several firms with
large amounts of invested capital can be formed. Self-regulation is
least suitable where there is serious risk of fraud and few well
established firms.
Harmonization of EC regulation is desirable for banks and maybe for
brokers and dealers whose failure could have contagious effects, but
Mayer and Neven concluded that the Commission should not seek to impose
significant capital requirements on all investment businesses. They
advocated a hierarchy, in which international organizations were
responsible for regulation of systemic risks, national regulators for
prevention of fraud, and self-regulatory bodies for negligence and
incompetence. This would resemble the UK and US systems, where
investment advisers are not required to hold significant amounts of
capital.
Corporate Responses to Financial Integration
Integration of European financial markets will strongly affect firms
operating in those markets and firms relying on them for capital. Three
papers at the conference took up this theme. Richard Caves
(Harvard University) focused on `Corporate Mergers in International
Economic Integration'. There is a widespread expectation that the
reduction of non-tariff barriers and administrative protection
associated with 1992 will promote corporate mergers. Caves showed how,
in a game-theoretic framework, any event which would reduce costs or
boost demand for a whole industry could lead to a spate of mergers. Even
assuming no collusive gains from mergers, firms acting strategically
would initiate a sequence of mergers in order to avert the adverse
profit shifting if rivals seized those opportunities first. Other firms
would engage in imitative mergers so as to mitigate the profit-shifting
effects of the first merger. This mechanism suggested an explanation for
the association of international horizontal mergers with increasing
international trade, and a corollary predicting their bunching in time,
as has happened in pharmaceuticals, for example.
An alternative explanation focused on the facilitation of foreign direct
investment. The traditional view, Caves noted, is that international
trade and investment are substitutes, with overseas plants used to
overcome trade barriers, so that economic integration should be
associated with a decline in cross-border mergers. In the last two
decades, however, the empirical evidence has suggested that
international trade and investment are complements, explained through
exports revealing profitable investment opportunities, and vice versa.
This theory suggests that merger activity should increase when the
equilibrium stock of multinational enterprise capital in an industry is
increasing.
Caves tested these theories using data on horizontal mergers across the
US border during 1978-88. The evidence more closely fitted the
non-strategic than the strategic model. Mergers were widespread among
industries, not markedly more concentrated in some. They were strongly
related to industries' base levels of foreign investment, but not to
producer concentration in any way consistent with the strategic theory.
The analysis supported the view that integration would be preceded or
accompanied by a wave of mergers. But the lack of empirical support for
rent-seeking motivations suggests that international horizontal mergers
only pose a policy problem in a small number of industries, he
concluded, where the strategic model had more explanatory power.
In research under CEPR's auspices, Colin Mayer has highlighted
cross-country differences in patterns of external finance for firms.
German firms rely more on bank finance, with greater commitment of firms
and banks to a long-term relationship, while UK corporate finance is
more reliant on stock markets. In `Banking, Financial Intermediation and
Corporate Finance', Martin Hellwig (Universität Basel and CEPR)
examined whether the `German' model was generally superior. If so, why
do other models persist? A historical explanation focuses on differences
between the discount policies of the Reichsbank and the Bank of England
in the late 19th century, which apparently meant German banks were more
assured of short-term liquidity. A long-term relationship between a bank
and a firm may carry with it economies of scale in monitoring investment
projects. It also weakens subsequent competition from other banks.
Hellwig referred to work emphasizing the information advantage enjoyed
by a single financier in concluding further contracts. This could be
beneficial: the exclusion or weakening of ex post competition among
banks increases the profits from continued financing of a good
investment project, and in anticipation, allows better terms to be
offered on the initial project.
But discouragement of ex post competition also exposes the firm to abuse
of power by the house bank, Hellwig noted. The desire of managers to
protect themselves against such abuse may help explain the continued
prominence of internal finance, common to countries whatever the pattern
of their external finance. Excessive self-finance can create moral
hazard problems, however, if management of the firm's investments is too
free from outside control. Structural change in the economy might also
be impeded: companies in relatively stagnant sectors may build up large
internal funds, which can only be freed for profitable investment
through takeovers. In conclusion, Hellwig argued that in fact we have a
relatively good understanding of the differences between bank and market
finance. The mechanisms underlying the prominence of self-finance
provide the major puzzle for economists.
In `Banking Competition and European Integration', Xavier Vives
(Universidad Autķnoma de Barcelona and CEPR) argued that banking
competition will not increase after 1992 to anything like the degree
predicted by, for example, the Price Waterhouse study of `the costs of
non-Europe' in the financial sector. Important economic barriers to
entry, in extensive branch networks, switching costs for consumers and
the reputation of established banks, would diminish the scope for
increased competition. The removal of regulations covering interest
rates offered to depositors and borrowers would, however, increase price
competition between banks, exposing their previous tendency to
`over-compete' on aspects of service quality such as the proximity of
branches. The market may actually become more concentrated, as
over-extended branch networks are rationalized and acquisition of an
existing bank becomes the only viable route to entering a new market.
Vives also presented this paper at a
recent lunchtime meeting.
Tax Policies in an Integrated Europe
The fiscal environment in Europe will change dramatically after
1992, and free capital mobility will make it harder to collect taxes on
capital. Though generally lower than in the United States, capital
taxation within the EC varies considerably, being relatively high in
Luxemburg and the United Kingdom and lower in Germany. In `Capital
Flight and Tax Competition: A Viable Solution to Both Problems?', Alberto
Giovannini (Columbia University and CEPR) and James Hines
(Princeton University) argued that this environment distorts investment
decisions by multinational firms. To avoid taxes, they make inefficient
investments and manipulate the prices used between subsidiaries in
different countries. These distortions will worsen after 1992, because
cross-border trade will increase.
The EC had an excellent opportunity to complete its internal market for
capital by instituting a system of residence-based capital income
taxation, according to the authors. They advocated a uniform 50%
withholding tax on corporations' income. Taxes would be due to the
government of the country where the income is earned, with no
distinction between local branches of a foreign corporation and
separately incorporated entities. EC governments should then be able to
set their own tax rates on corporate income by applying rebates to
owners of corporate shares for the difference between 50% and the local
rate. The only constraints should be that the rebates be less than the
50% EC rate and based on a common definition of taxable corporate
income.
In this system host governments would be permitted to subsidize firms,
industries and particular investments, but the subsidies would be
included in the corporate tax base. Foreign income outside Europe would
be taxed at the full 50% rate, but with a credit for foreign income
taxes paid. Europe should also establish a `clearing system' to allocate
corporate income from source countries to the countries of shareholder
residence. In such a system, the authors noted, governments could no
longer retain corporate tax revenue from foreign shareholders, but they
would gain the right to tax in full their own citizens' non-domestic
corporate income. Giovannini and Hines estimated that the new system
would initially increase tax revenue in countries which were net
capital-exporters to the rest of Europe, such as Germany, the
Netherlands and the United Kingdom, and reduce revenues for France,
Italy and Spain. A transitional arrangement could be set up to persuade
the losers to accept the new system.
The Delors Report viewed fiscal policy as a constraint on monetary
policy and proposed fiscal rules to accompany EMU. Arguments for fiscal
coordination frequently relate to spillovers when government debts are
traded internationally. One country could engage in a spending spree,
the cost of which would be borne in rising interest rates and reduced
value of government bonds across the whole union. Without rules against
such behaviour, this could lead to excessive deficits in all countries.
In the first of two papers, on `Fiscal Policy, Interdependence and
Efficiency', Willem Buiter (Yale University and CEPR) and Kenneth
Kletzer (Yale University) analysed this externality using a
two-country, overlapping-generations model with a neo-classical
production function.
They showed how, with no distortions and only non-distortionary fiscal
instruments, such behaviour would not in fact lead to any loss of
economic efficiency. The world interest rate played a key role in
determining the distribution of gains from international lending and
borrowing and from increases in one country's public debt. In the
absence of a non-distortionary mechanism for international
redistribution, social welfare could be enhanced, at the expense of
efficiency, by distortionary instruments such as source- or
residence-based taxes on income from capital. If there are other
distortions, such as worldwide public goods or international
externalities in production or consumption, then non-lump-sum
instruments need not involve efficiency loss.
In `The Welfare Economics of Cooperative and Noncooperative Fiscal
Policy', Buiter and Kletzer analysed the use of intergenerational
transfers to alter the pattern of national saving and consumption and so
gain a welfare advantage for domestic residents. Fiscal coordination in
general optimized the governments' objectives, but optimization of
global objectives required international lump-sum transfers. If none are
available, a second-best involved lump-sum redistribution between
generations within each country, influencing the world rate of interest
and hence the distribution of income between debtors and creditors. The
introduction of both distortionary and lump-sum fiscal instruments and
of worldwide public goods created an efficiency case for fiscal
coordination in Buiter and Kletzer's model.
Monetary Integration
The macroeconomic effects of monetary union, with perfect capital
mobility and irrevocably fixed exchange rates, will in large part depend
on how increased currency substitution will affect money markets. Michael
Woodford (University of Chicago) investigated `Does Competition
Between Currencies Lead to Price Level and Exchange Rate Stability?',
using a multiple currency, cash-in-advance model similar to that used by
Lucas and Stokey to consider substitution between cash and credit. The
model treated transactions using different currencies as different types
of goods. The degree of substitutability between these commodities
represented substitutability between currencies. Analysis of the model
suggested that, contrary to widespread opinion, the degree of currency
substitutability had little effect on equilibrium price levels and
exchange rates except in the case of perfect substitutability. But, by
raising the likelihood of indeterminacy, increased currency substitution
could make management of fixed exchange rates more difficult.
Woodford argued that this cast considerable doubt on the wisdom of
evolutionary approaches towards fixed exchange rates such as that
advocated by the UK Treasury. Markedly increased currency substitution
would increase the scope for speculative instabilities in exchange rates
and corresponding fluctuations in price levels. If currency competition
resulted in lower rates of monetary growth, as the UK government argues,
this itself could make exchange rates and prices more unstable, owing to
greater scope for indeterminacy when monetary policy is contractionary.
Woodford concluded that, rather than allowing a natural evolution
towards fixed exchange rates, as the UK Treasury argues, too much
currency substitution would make fixed exchange rates harder and perhaps
impossible to manage. If Stage One of the Delors process leads to a
substantial increase in currency substitution, a single currency may
then become essential to preserve even the degree of monetary stability
achieved under the current EMS.
In `Problems of European Monetary Integration', Rudiger Dornbusch
(MIT and CEPR) argued that the EMS is now in limbo, frustrating
policy-makers in many countries. First, Germany has no way to avoid
importing inflation. If domestic spending were restrained, the resulting
gain in cost competitiveness would increase the external surplus,
becoming a further source of demand and inflation. Or German restraint
could lead to an offsetting expansion abroad, leaving demand for German
goods and services and hence inflation virtually unchanged. Second, high
nominal interest rates in some countries reflect the possibility of
exchange rate changes, but governments are committed against
realignments. This is the worst of all worlds, according to Dornbusch:
high nominal rates without realignments mean high realized real interest
rates, especially painful for high-debt countries. Third, unsustainably
high external deficits are a further indication of monetary problems.
A strong drive for monetary integration is therefore essential,
Dornbusch argued. With capital movements fully liberalized and margins
in financial markets reduced, monetary policy will bear an even greater
bur den, with even higher costs for public finance. Though monetary
integration is often interpreted in terms of lost independence, for most
EMS members monetary policy is already just an instrument for managing
the balance of payments. `Independent' monetary policy is also
expensive, in exchange rate uncertainty and debt service. Reform should
be designed to reduce the exchange risk premia in real interest rates
and to reduce fiscal deficits. It is because governments retain the
option of devaluation that the capital markets retain the risk premium.
To remove it, exchange rate fixity must become more credible. The more
governments put at stake, the more credible their policy.
Dornbusch advocated that the `core' countries (the present EMS members
less Spain) totally abandon exchange rate margins against the
Deutschmark. This could be achieved in a year, with no need yet for
joint institutions. France and Italy would experience incipient capital
inflows. To offset the demand expansion they should sharply tighten
their fiscal stances, providing an excellent opportunity to retire
public debt. The transition should also be used to break inflation
inertia, introducing a temporary wage freeze not to cut real wages, but
to ensure the step to fully fixed rates does not go astray at the start.
But not all EC members should be included in this process. In the United
Kingdom a real depreciation would be needed, but the response would be
wage pressure and inflation which would only be checked at the cost of
unemployment. Sterling could not fit into a European monetary
arrangement while UK wage- and price-setting differs so radically from
what is now accepted on the Continent, Dornbusch maintained. Second, the
new entrants to the EC would be better adopting a crawling peg to
achieve fixed real exchange rates. As Latin American experience shows,
fixed nominal rates are not a lasting measure against high home-made
inflation.
Conclusions
The conference ended with a public panel discussion on `Problems of
Financial Integration in Europe', chaired by Mario Sarcinelli,
Director General of the Ministero del Tesoro in Rome. A major difficulty
that will arise in a European financial area, he suggested, is that a
`level playing field' with separate national currencies will make
possible large-scale tax and regulatory arbitrage. One solution is for
the Commission to be responsible for taxing the income from services,
but this is unlikely to be politically acceptable. An alternative is to
shift responsibility for supervising intermediaries from the host to
home countries.
Luigi Spaventa (Universitā di Roma and CEPR) warned that the new
freedom to import financial services will mean that the present high
reserve requirements and taxes on deposits will penalize the Italian
financial sector. Due to a long history of political involvement, Italy
also has too many banks. A simple merger spree to create fewer, larger
banks was not the solution, according to Spaventa. More appropriate
would be cross-border alliances enabling Italian banks to continue to
exploit their comparative advantage in local knowledge, while importing
expertise.
Niels Thygesen (Kobenhavn Universitet) criticized the UK
Treasury's `competing currencies' proposal, which involved advanced
financial competition with no steps on the monetary front. This may well
be destabilizing and leaves unresolved the setting of overall EC
monetary policy. Thygesen argued that the full gains from financial
integration would only be attained with further monetary integration. A
single currency would remove the risk premium in interest rates,
eliminate transactions and information costs of exchange uncertainty,
and allow deeper specialization and superior allocation of saving and
investment.
Charles Wyplosz (INSEAD and CEPR) emphasized the distributional
consequences of integration. Though he commended Giovannini and Hines's
proposal for a tax regime that removed incentives for capital flight
within the EC, it would not prevent wholesale capital flight outside the
Community. As tax receipts on capital income fall, governments will
respond with a combination of higher taxes on less mobile factors, i.e.
labour, and reduced spending on social programmes and public
investments. Similarly, he was concerned about the overall effect of
such a huge increase in competition. The result would be to reduce
economic rents, but while capital can move elsewhere, labour is less
mobile and so will lose out. We should beware, Wyplosz concluded, the
prospect that 1992 will turn out as a capitalist paradise.
European Financial Integration edited by Colin Mayer.
Available from CEPR, 90-98 Goswell Road, London EC1V 7RR
ISBN (hardback) 0 521 402441
ISBN (paperback) 0 521 428904
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