What's Wrong With the Dodd Proposal to Restructure the Fed

Last Updated Nov 20, 2009 9:29 AM EST

A proposal from Senate Banking Committee Chairman Christopher Dodd changes the selection process for key positions within the Federal Reserve system. Unfortunately, this proposal makes the selection process worse, not better. If this proposal is passed into law, it would further concentrate power within the Federal Reserve system, and it would politicize the selection process, both of which are the opposite of where reform should take the system.

The Current Structure of the Federal Reserve System
The Federal Reserve System consists of a Central Bank in Washington and twelve Federal Reserve District (or regional) Banks. The Central Bank's authority resides with the seven member Board of Governors, one of which serves as chair (currently Ben Bernanke). Each of the District Banks has a nine member Board of Directors along with a bank President. It is the selection of the Board of Directors that is at issue.

Currently, the nine member Board of Directors at each of the District Banks consist of three Class A directors, three Class B directors, and three Class C directors. Class A directors are elected by member banks within the district and are professional bankers. Class B directors are also elected by member banks in the district, but these are business leaders, not bankers. Finally, Class C directors are appointed by the Board of Governors and are intended to represent the public interest.

Class B and Class C directors cannot be officers, directors, or employees of any bank, and Class C directors may not be stockholders of any bank. One Class C director is selected by the Board of Governors to serve as Chair of the Board of Directors. The Board of Directors selects the President of each District Bank, but the President must be approved by the Central Bank's Board of Governors.

What is the reasoning behind this structure? When the Fed was created in 1913, there was a concerted attempt to distribute power across geographic regions; between the public and private sectors; and across business, banking, and the public interests. The geographic distinctions were important because it's not unusual for economic conditions to differ regionally -- conditions can be booming in some places and depressed in others -- and the regions would favor different monetary policies. Thus, it's important to bring these different preferences to the table when policy is being determined so that the best overall strategy can be implemented.
Changes in the Distribution of Power over Time
In the early days of the Fed, power over monetary policy -- which at that time was mainly discount rate policy within each Federal Reserve District -- was shared between Washington and the District Banks, so the intent of the system was largely realized.

However, the shared power arrangement within the Federal Reserve system changed after the Great Depression. The Fed did not perform well during the great Depression and one of the problems, it seemed, was that the deliberative, democratic nature of the institution prevented it from taking quick, decisive action when it was most needed. Furthermore, the Fed did not have the tools it needed to deal with system-wide disturbances rather than problems with individual banks (the discount window is well-suited to help individual banks, but it's not an effective tool to combat system wide disruptions; on the other hand, open-market operations -- a policy tool the Fed obtained after the Great Depression -- can inject reserves system-wide and are much more useful to deal with system-wide problems).

The result was that after the Great Depression, power was concentrated in the Central Bank's Board of Governors in Washington D.C., and increasingly over time, in the hands of one person -- the Chair of the Federal Reserve. Thus, over time the Fed has evolved from a democratic, shared power arrangement at its inception to a system that functions, for all intents an purposes, as a single bank in Washington, D.C,. with twelve branches spread across the U.S.

The Dodd Proposal
How would the Dodd proposal change this? Under the proposal, the Board of Directors for each District Bank would be chosen by the Central Bank's Board of Governors (who are themselves chosen by the President with the advice and consent of the Senate). The chair of the Board of Directors at each District Bank would be chosen by the President and confirmed by the Senate.

This means that the key figures within each District Bank would be chosen by Washington, and unlike the present system, there is no attempt at all to represent geographic, business, banking, and public interests explicitly in this arrangement. In addition, it no longer has the explicit safeguards contained in the current rules to prevent bankers from dominating the directorships (e.g. under the new rules the Chair of the Board of Directors could be a banker, currently that can't happen). Given that the appointments are coming from Washington (as opposed to a vote of banks within the District for six of the nine positions on the Board like we have now), there is no guarantee that the District bank Boards won't be stacked with one special interest or another. Thus one of the main reasons given by Dodd for the change in the selection process -- to remove the influence of bankers -- is actually undermined by his proposal because it removes the safeguards against the Board being dominated by banking interests.

I believe that the current structure of the Fed already gives too much power to Washington and not enough to the District Banks, and this has helped to feed the perception that the Fed does not represent the interests of the typical person. Unfortunately, the Dodd proposal further concentrates power in Washington and adds more political elements to the selection process thereby making these problems even worse.

Thus, I agree with this:

Bullard, 48, the St. Louis Fed's president since April 2008, said ... the Fed is ultimately controlled by political appointees as it stands... "We don't want to put all the power into Washington and New York," Bullard said. "That's just the opposite of what this crisis is teaching us. So you want the input from around the country, and I think it's really important for informing monetary policy."

Richmond Fed President Jeffrey Lacker said ... "I wouldn't want to see the reserve bank governance mechanism politicized in any way,"... Asked if Dodd's plan would politicize the process, Lacker said: "I think it could."


Finally, while the proposal claims to insulate the Fed's monetary policy decision from political pressure, this quote from the same article illustrates the dangers of political interference. The quote is in response to another part of the Dodd proposal that would take away some of the power the District Bank Presidents have in setting monetary policy (which is already much less than the power of the Board of Governors):
"I doubt very much that by a year from now Fed presidents are going to have as big a role as they now have," Financial Services Committee Chairman Barney Frank told reporters... He has said the presidents too often vote in favor of higher interest rates.
That last sentence means he believes the Fed has favored low inflation over low unemployment as it has set interest rate policy. That may or may not be true, but do we really want members of the House setting interest rate policy or changing the structure of the Fed whenever they disagree? I don't.

I fully agree that the selection process for the Directors and the District Bank Presidents could and should be changed (that includes redrawing geographic districts). It's not clear that the present system does the best possible job of representing the array of interests that have a stake in the outcome of policy decisions. But concentrating power in Washington is not the way to solve this problem. Instead we need to redistribute power over a wider range of interests, including geographic interests, and make sure the selection process for key positions within the Federal Reserve system brings those interests to the table when policy is determined.

[Update: See also Alan Blinder's "Threatening the Fed's Independence".]

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