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
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