Policy Brief
NUMBER PB14-4

JANUARY 2014

Monetary Policy with
Abundant Liquidity: A New
Operating Framework for
the Federal Reserve
Joseph E. Gagnon and Brian Sack
Joseph Gagnon is senior fellow at the Peterson Institute for International
Economics and Brian Sack is codirector of global economics at the D. E.
Shaw Group. They thank Kent Troutman for expert research assistance.
The authors thank Joseph Abate, Morten Bech, Seamus Brown, Chris
Burke, Seth Carpenter, Richard Clarida, Michael Cloherty, James Clouse,
Kris Dawsey, Robert Eisenbeis, Rodney Garratt, Spence Hilton, Robert
Kahn, Carl Lantz, Lorie Logan, Brian Madigan, Antoine Martin, James
McAndrews, Ellen Meade, Daniel Michalow, William Nelson, Simon
Potter, Mike Prell, Matt Raskin, Julie Remache, Matt Rutherford, David
Skeie, Edwin Truman, Angel Ubide, and Steve Weisman for helpfulcomments. All views expressed in this Policy Brief, and any errors, are thoseof the authors and do not represent the views of the Peterson Institute forInternational Economics or the D. E. Shaw Group.

© Peterson Institute for International Economics. All rights reserved.

The dramatic increase in the Federal Reserve’s balance sheet
since 2009 has attracted the attention of economists, pundits,and ordinary citizens. The amount of assets held by the Fed
recently crossed $4 trillion and will likely continue to rise to apeak of about $4.5 trillion. This run-up in asset holdings has
resulted from the Fed’s large-scale asset purchase programs,
which were intended to support economic growth. However,a side-effect of these asset purchases is the creation of unprecedented amounts of liquidity in the financial system.
This liquidity will present a challenge when the timecomes to raise short-term interest rates. Indeed, the Federal
Reserve has never tightened monetary policy, or even tried to1750 Massachusetts Avenue, NW

Washington, DC 20036

maintain short-term interest rates significantly above zero, withsuch abundant liquidity in the financial system. Fed officials
have emphasized that they have developed the tools needed todrain reserves and manage short-term interest rates in such anenvironment. However, they have not specified how those tools
would be used in practice. Moreover, there are reasons to doubtthat conducting policy along the lines of the previous operating
framework, which would involve reducing bank reserves asneeded to achieve a target level for the federal funds rate, willfunction smoothly in this environment of high liquidity.
In this Policy Brief, we propose a new operating frameworkthat will allow the Fed to conduct monetary policy while maintaining a substantially elevated balance sheet and abundantliquidity in the financial system. In particular, we believe that

The environment of high liquidity infinancial markets is likely to persist for anumber of years…. Thus, it is crucial for the
Fed to have an operating framework thatwill be effective in such an environment.
the Fed should set the interest rate at which it will offer overnight reverse repurchase agreements as its policy instrument andthat it should maintain the interest rate paid on bank reserves atthe same level. Under our proposal, all banks and many otherfinancial institutions would have an unlimited ability to invest
at the Fed at the specified interest rate. All other interest rates,
including the federal funds rate, would be determined in themarket, presumably with the risk-free interest rate set by the
Fed exerting a powerful influence on them.
The environment of high liquidity in financial markets islikely to persist for a number of years, as the Fed has indicatedits intention to reduce its asset holdings only gradually once theeconomic recovery gathers steam. Thus, it is crucial for the Fed
to have an operating framework that will be effective in suchan environment. In addition, the proposed framework would

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NUMBER PB14-4

Figure 1

JANUARY 2014

Past and projected Federal Reserve assets and bank reserves, 2005–25

percent of GDP
30

25

20

Assets15

10

Reserves

50January 2005

January 2009

January 2013

January 2017

January 2021

January 2025

Note: The increase in reverse repurchase agreements after August 2013 is added to reserves.
Sources: Blue Chip Economic Indicators; Federal Reserve Bank of New York; Federal Reserve Board; and authors‘ calculations.

provide the Fed with the flexibility to choose the optimal sizeand structure of its balance sheet after this transition period. We
believe that the Fed should not shrink its balance sheet all theway back to a size that would have been considered normal prior
to the global financial crisis but should instead leave a larger
amount of liquidity in the financial system on a permanent basis.
Overall, we see a number of advantages to our proposed
framework. Through the interest rates on reverse repurchaseagreements and bank reserves, the Fed would have sufficient
control of short-term interest rates, allowing it to influence
broader financial conditions in a manner that supports its
mandate for full employment and low inflation. And by keeping
the balance sheet more elevated than otherwise, the Fed would
be providing a greater amount of liquidity to the financial
system, allowing it to potentially operate with better efficiency
and reduced risks. In our view, this proposal would improve
the transmission of monetary policy to the overall economy
and would provide the Fed with flexibility to respond to future
crises with its balance sheet as it sees appropriate.
AN ENVIRONMENT OF ABUNDANT LIQUIDITY
The financial system is currently operating with an extreme
amount of liquidity as a result of the Federal Reserve’s programs
to purchase large amounts of Treasury and agency mortgage-2

backed securities (MBS).1 Those asset purchase programs weremeant primarily to make financial conditions more supportiveof economic growth and not to provide liquidity to the financial
system. However, as a result of these purchases, the aggregate
amount of reserves in the banking system has reached unprecedented levels, as can be seen in figure 1.2 Prior to late 2008,
bank reserves were only a trivial percentage of GDP.
Given the manner in which the Fed is likely to manage
its balance sheet going forward, this environment of abundant liquidity will persist for many years. The Federal Open
Market Committee (FOMC) has indicated that it intends tocontinue to expand the balance sheet until it sees a “substantial improvement” in the outlook for labor market conditions,and subsequently it is likely to hold the balance sheet nearits peak level for an extensive period. Once the time comesto begin to normalize policy, the FOMC is likely to shrink
the Fed’s balance sheet only gradually, by allowing holdings
1. We are using the term “liquidity” to refer to short-term assets with a relatively certain price, implying that they can be easily sold or allowed to maturein order to raise funds for making payments. Bank reserves and currency are
the most liquid assets because their value is completely certain and they can beused directly for payment.
2. When the Fed buys a security, it pays for the security by crediting thereserve balance of the bank whose customer sold the security. Thus, asset
purchases necessarily create a liability of the Federal Reserve, initially in theform of reserves.

NUMBER PB14-4

of Treasury securities and agency MBS to run off as they are
redeemed.3 The FOMC has not ruled out selling assets during
the normalization of monetary policy, but it appears that most
FOMC members do not anticipate doing so.4
Figure 1 shows projections of the Fed’s total assets and bankreserves through 2025 as a percent of GDP. Based on Chairman
Ben Bernanke’s remarks after the December 2013 FOMC
meeting, we assume that the FOMC continues to reduce thepace of its purchases by $10 billion per meeting, ending themin the fourth quarter of 2014. Thereafter, principal paymentson securities are reinvested to maintain the balance sheet at aconstant nominal size until May 2015, when the Fed begins toallow assets to run off gradually as they are redeemed.5 The difference between assets and reserves, which is mainly composed ofcurrency in circulation, is assumed to gradually return to its
pre-2008 level of 6 percent of GDP by late 2018 as interest rates
return to more normal levels.6,7 Finally, we project nominal GDP
based on the Blue Chip Economic Indicators October 2013 survey.
Under these projections, the amount of assets held by the
Fed reaches about $4.5 trillion, or roughly 25 percent of GDP
by late 2014, pushing the amount of excess reserves in thebanking system to around $3 trillion, or 16 percent of GDP.
The size of the balance sheet begins to decline in mid-2015,
3. Redemptions occur when principal is paid on an asset, either because it
matured or because all or part of it was paid off prior to maturity (prepayment
applies only to agency MBS and not Treasury securities).
4. In a set of “exit strategy principles” published in the minutes of its
June 2011 meeting, the FOMC said the first step in the process of policy
normalization would be to “cease reinvesting some or all of the payments ofprincipal” on its securities holdings. Those principles also indicated that the
FOMC might sell some of its MBS holdings. Nevertheless, at the press conference following the June 2013 FOMC meeting, Chairman Bernanke said that“a strong majority” of the FOMC does not anticipate selling assets during theprocess of normalizing monetary policy.
5. Our assumption on the timing of asset redemptions lines up with themedian response in the Fed’s Survey of Primary Dealers from October 2013.
The dealer survey projects redemptions only through 2018, at which point thebalance sheet is declining at a rate of 12 percent per year. We assume a rateof decline of 10 percent in 2019–20, 8 percent in 2021–22, and 6 percent
thereafter. The declining rate of redemptions reflects a long tail of assets with
distant maturities.
6. In January 2013, Fed staff released projections of the Fed balance sheet(Carpenter et al. 2013), which differ from our projections in three respects.
First, the Fed study assumed an upper estimate of Fed asset purchases beyond
December 2012 of $1 trillion, but market participants currently expect $1.5
trillion. Second, the Fed study assumed a rapid initial rate of redemptions of
MBS holdings, based on the observed prepayment rates in 2010–11, but these
rates fell sharply in late 2013 and market participants now expect a lower rateof redemptions. Third, the Fed study assumes that currency in circulation
will remain elevated (as a share of GDP) even after interest rates become
significantly positive.
7. Liabilities in the Fed’s new overnight reverse repurchase facility, which areassumed to account for all of the growth in reverse repurchase agreements
since August 2013, are included with bank reserves. This new facility and its
relationship with bank reserves are the central focus of our proposal.

JANUARY 2014

but the reduction is gradual, leaving the balance sheet well
above its “normal” level past 2020.
These projections highlight a critical fact about the policy
regime going forward. While the exact timing of monetary
policy tightening is unclear, it will almost surely take placein an environment of very large amounts of liquidity. Indeed,according to their own economic projections, most FOMC
members see the appropriate policy path as involving increases
in short-term interest rates beginning in 2015—at a time
when the amount of reserves will still be close to $3 trillion.
P O L I C Y TO O L S F O R M A N AG I N G S H O R T - T E R M
I N T E R E S T R AT E S
The Federal Reserve has never tried to manage short-term interest rates with such abundant liquidity in the financial system.
As noted above, bank reserves were a trivial percent of GDP
prior to late 2008, with balances typically less than $30 billion.
Over that period, the Fed did not pay interest on reserves, andovernight interest rates were much higher, which meant thatholding reserves had a meaningful opportunity cost from theperspective of the banks. In that environment, relatively smallchanges in the supply of reserves had a meaningful effect onovernight interest rates (Carpenter and Demiralp 2008).
The policy instrument of the FOMC at that time (andstill today) was the target for the federal funds rate, which is
the interest rate for uncollateralized overnight loans to depository institutions.8 The FOMC would direct the Open Market
Desk of the Federal Reserve Bank of New York to conduct
open market operations on each day to set the total amount ofreserves at a level judged to be most consistent with achieving
the target for the federal funds rate. The banking systemgenerally had a structural deficiency of reserves, which meantthat the New York Fed would typically have to inject reserves
by conducting repurchase agreements (RPs).98. Federal funds transactions include the borrowings by a depository institution from a US office of another depository institution, foreign bank, the US
government or agency thereof, a Federal Home Loan Bank, or selected otherinstitutions.
9. An RP agreement, also known as a repo agreement, is similar to a collateralized loan. The borrower sells a security to the lender and simultaneously
promises to buy back the security at a fixed price. The Fed lends funds to themarket through RP agreements in order to increase reserves. To drain reserves,
the Fed engages in RP agreements in the opposite direction, known as reverse
RPs. The New York Fed can also inject reserves on a permanent basis throughoutright purchases of Treasury securities. The structural deficiency of reservesin the banking system reflected that these purchases did not keep pace withthe average amount of reserves demanded by banking institutions, which was
an intentional outcome so that the New York Fed could then manage reservebalances through RP operations.

3

NUMBER PB14-4

Figure 2

JANUARY 2014

Short-term interest rates during the financial crisis, 2008–09

percentage points
3
Federal funds
Treasury bill
Interest on reserves
Treasury repurchase agreement210August 2008

October 2008

December 2008

February 2009

Sources: Bloomberg and Credit Suisse Locus.

The amount of reserves in the banking system surged during the
global financial crisis.10 With the increase in reserves, the Fed
would have lost its ability to keep overnight interest rates above
zero had it not gained an important new tool at this time—theauthority to pay interest on reserve balances held by depository
institutions.11
 Interest on reserves
The ability to pay interest on reserves (IOR) significantly
affected the Fed’s ability to control interest rates in the presence of abundant reserves. In particular, the federal funds rate
and other short-term interest rates were expected to remain
relatively close to the IOR rate. One reason to expect this
10. The initial surge in the fall of 2008 owed to the increased lending to thefinancial system that the Fed initiated through various liquidity facilities.
Subsequently, the increase in reserves was due to the asset purchases conductedby the Fed. This Policy Brief focuses on the consequences of those policy
actions for the Fed’s control of overnight interest rates. For a review of theefficacy of the liquidity programs and asset purchases in influencing financial
and macroeconomic conditions, see Gagnon and Hinterschweiger (2013).
11. In principle, the Fed may pay interest at a different rate on required
reserves than on excess reserves. In practice, these rates have been identical and
we do not distinguish between them. It is the rate on excess reserves that is
economically more important because only these assets are available for banks
to put to alternative uses.

4

pattern is that banks can perform an arbitrage by borrowing
in the federal funds market and holding the resulting funds
as reserves at the Fed. This transaction involves no risk forthe bank and allows it to earn any spread between the IOR
rate and the federal funds rate. 12 Banks can perform a similartransaction using other types of borrowing, for example, when
the interest rates on RPs or bank certificates of deposit (CDs)drop sufficiently below the IOR rate.13
In practice, though, bank funding rates and other overnight interest rates have traded notably below the IOR rate.
This pattern was the most extreme at the height of the financial
crisis, when the federal funds rate traded more than 50 basis
points below the IOR rate, as shown in figure 2.14 However, it
has also persisted during less stressful market conditions. For
12. Central banks in Australia, Norway, and New Zealand maintained policy
rates above 1 percent in 2009. They were able to keep overnight interbank interest rates consistently above the rates of interest paid on bank reserves despite
elevated levels of reserves (Bowman, Gagnon, and Leahy 2010).
13. CDs and RPs often have maturities greater than overnight and hence
incorporate expected changes in overnight interest rates.
14. To some extent, this large gap may reflect the novelty of IOR, which was
rushed into place before its originally scheduled introduction, as well as theunusual stresses on the financial system at that time, which made financial
institutions reluctant to lend to one another.

NUMBER PB14-4

Figure 3

JANUARY 2014

Short-term interest rates, 2009–13

percentage points
0.4
Federal funds
Treasury bill
Interest on reserves
Treasury repurchase agreement
0.3

0.2

0.1

0
April 2009

January 2010

October 2010

July 2011

April 2012

January 2013

October 2013

Sources: Bloomberg and Credit Suisse Locus.

example, over the past several years, the gap between the IOR
rate and the federal funds rate has often been 15 basis points orlarger, as can be seen in figure 3.
This pattern reflects the fact that some large lenders in
the federal funds market are not eligible to receive interest on
reserves (mainly government-sponsored enterprises, or GSEs).15
Banks are willing to borrow from these entities and hold theproceeds as reserves, performing the arbitrage noted above,
but they require a yield spread to do so because they view theassociated increases in their balance sheets as costly in termsof required regulatory capital and internal oversight.16 In addition, banks have to pay a fee to the Federal Deposit Insurance
Corporation (FDIC) related to the size of their balance sheets,
which directly reduces the return on this activity by 10 to 15
basis points on average.17
15. For estimates of the extent of activity from these participants, see Afonso,
Entz, and LeSueur (2013a).
16. Counterparties of banks may also face constraints, particularly on theamount of unsecured transactions with a single counterparty, which also limits
the ability of this arbitrage activity to put a floor on the federal funds rate.
17. The FDIC fee varies across financial institutions, with a rate ranging from
5 to 45 basis points. Foreign banks do not pay the fee because they are not

It is possible that this gap would have been larger if thefederal funds rate had not been constrained from below by thezero bound on nominal interest rates. Moreover, other types ofshort-term interest rates, such as the rate on an overnight RP
for general Treasury collateral (Treasury RP rate), also traded
well below the IOR rate over this period. As with the federal
funds rate, this pattern reflects the fact that key participants inthis market are not eligible to receive interest on reserves fromthe Fed and hence have to accept a lower return in the market.
The presence of these gaps suggests that the ability of the
Fed to control a broad range of market interest rates by setting
the IOR rate alone cannot be taken for granted. Indeed, a primary concern about the conduct of monetary policy going forward is that the gap between overnight market interest rates andthe IOR rate could widen and become less predictable as the
IOR rate moves away from the zero bound. The Fed presumably
wants to have an operational framework that provides it withconsiderable control over a broad range of short-term interest
rates, both in normal times and in periods of financial stress.
insured by the FDIC. As a result, they have become the primary borrowers offederal funds (Afonso, Entz, and LeSueur 2013b).

5

NUMBER PB14-4

JANUARY 2014

 Draining tools

The Fed has not specified how it intends to use these
two tools in the conduct of monetary policy. One possible
approach (that we argue against) is to think of these as draining
tools that could be used to remove enough reserves from thebanking system to allow the IOR rate to exhibit strong control
over other overnight interest rates. However, the amount ofreserves that would have to be drained to achieve this outcome
is unclear and could be substantial.20 If it turned out that thevast majority of reserves had to be drained, one might beconcerned that the heavy use of the TDF and term RRPs toachieve that outcome would itself cause notable distortions inmoney markets. For example, these operations could cause an
unusual steepening of the money market curve, with the Fed
having to pay rates for one-month and three-month instruments that are well above overnight interest rates.
In brief, there are risks associated with returning toelements of the previous operational framework for monetary
policy—that is, maintaining a federal funds rate target, relying
mainly on IOR to control the federal funds rate, and using
term draining operations in massive size to encourage a tighter
relationship between the funds rate and the IOR rate. Thisapproach could result in sizable and unpredictable deviations
between various money market rates—both across instruments and maturities—that would weaken the Fed’s controlof financial conditions. With that in mind, we propose using
these tools in a different manner, one that is much better
suited for the current situation in financial markets.

In order to enhance its control over short-term interest rates,
the Fed has developed and tested two new tools: a term deposit
facility (TDF) and a reverse repurchase (RRP) facility that canbe implemented for overnight or term transactions (Martin
et al. 2013). Both tools are novel. The Fed had never before
offered term deposits, since it did not have the ability to pay
interest on reserves. And while the Fed has long had the ability
to conduct RP and RRP agreements to add or drain reserves,it had never conducted RRPs in large scale.18 Operations inboth the TDF and the RRP facility can be run by either fixing
the amount of the operation and allowing an auction to determine the clearing interest rate or fixing the interest rate andallowing the market to determine the quantity (often referred
to as “full allotment” operations).

There are risks associated with returning
to elements of the previous operationalframework for monetary polic y….
The TDF is available to the same depository institutions
that receive interest on reserves. In effect, the facility allows
those institutions to “lock up” their reserves for a longer period, presumably in return for a slightly higher interest rate
than the expected path of the IOR rate over the term of thedeposit. In contrast, the RRP facility is available to a broader
set of market participants, including primary dealers, money
market funds, and GSEs. From the perspective of the financial
market participant, an overnight RRP transaction with the
Fed is similar to being paid interest on holding reserves at theFed, in that it is an overnight asset with no credit risk. Thus,
the ability to do overnight RRPs with nonbanks in effect extends IOR to a broader set of market participants.19 Similarly,
term RRPs have many of the same characteristics as TDF
transactions.

18. The manner in which the Fed will conduct RRPs is also different than in
the past. Given their greater potential scale and the practices of many of its
counterparties, the Fed decided to conduct these operations in the triparty
repo market. That market uses infrastructure provided by two clearing banks,
JPMorgan Chase and the Bank of New York Mellon, and the associatedservices that they provide to intermediate credit in this market.
19. RRPs are different in some respects, including that the Fed’s counterparty
receives collateral in some cases that can then be used for other purposes.
However, this is not uniformly true, as the New York Fed’s legal arrangementswith several types of counterparties specify that the collateral is not delivered.
That arrangement is applied primarily to counterparties that typically would
not rehypothecate the collateral in any case.

6

A N E W F R A M E W O R K F O R M O N E TA R Y P O L I C Y
We propose a new operational framework for monetary policy
in which the FOMC employs the interest rate on its overnight
RRP facility as its main policy instrument and maintains anelevated balance sheet and hence abundant reserves. The RRP
facility would be implemented as a full allotment facility,
providing any amount of overnight RRP transactions to themarket at the rate set by the FOMC. The rate at the RRP
facility (which we will simply call the RRP rate) would replace
the federal funds rate target as the primary policy instrumentof the Fed. The FOMC would ask the Federal Reserve Board
to set the IOR rate equal to the RRP rate, with the idea that

20. The federal funds rate has been below the IOR rate almost continuously
since reserves moved higher in late 2008, suggesting that the Fed might needto bring reserves down to very low levels. Of course, what matters here is thedegree to which the federal funds rate and other rates would move with the
IOR rate once it is adjusted, which is difficult to predict since the IOR rate
has held steady at 25 basis points over most of the period since the Fed began
paying interest on reserves.

NUMBER PB14-4

these two rates together would underpin the Fed’s influenceon private borrowing rates and broader financial conditions.21
The large amount of liquidity created by the Fed’s elevatedbalance sheet has to take the form of either bank reserves or
RRPs with the Fed.22 By providing overnight RRPs in a fullallotment facility, the Fed is effectively creating a financial
market instrument that is nearly as liquid as reserves and thatcan be held by a broader set of financial market participants.
In our view, it is important for the RRP and IOR rates to be

We propose a new operating framework
for monetary polic y in which the Fed sets
the interest rate on its overnight RRP
facility as its main polic y instrument
and keeps the rate of interest paid onbank reserves at the same level.
set relatively close together to avoid giving an incentive for allof the liquidity in the financial system to remain in the banks(as it would if the IOR rate far exceeded the RRP rate) or toflow out of the banks (as it would if the IOR rate were well
below the RRP rate). The Fed should instead try to achieve an“interior solution” that involves substantial volumes of bothreserves and overnight RRPs, with the market determining theallocation between reserves and RRPs according to where theliquidity is valued the most. We believe that this interior solution is best achieved with equality between the IOR and RRP
rates, as discussed below.
This framework shifts the attention away from using“draining tools” to achieve a target level of reserves andinstead focuses directly on controlling the price of overnightliquidity. Indeed, in this framework the concept of achieving
a certain amount of reserves becomes obsolete, as the Fed
will have created a close substitute for reserves in the form ofovernight RRPs. The total amount of what we could call “Fedliquidity”—that is, the sum of reserves and overnight RRPs—
21. Although we see both the RRP rate and the IOR rate as very important,
we refer to the RRP rate as the policy instrument of the FOMC. The reason isthat the RRP rate can be set by the FOMC, whereas the IOR rate is instead set
by the Federal Reserve Board. This setup creates a governance issue when thesetting of the IOR rate is an active part of implementing the monetary policy
decisions of the FOMC. Our proposal mitigates any governance problems
because the Board would be expected to adjust the IOR rate to be consistent
with the RRP rate established by the FOMC.
22. This statement assumes that other Fed liabilities, such as currency incirculation, are relatively stable and do not react to the expansion of the Fed’sbalance sheet.

JANUARY 2014

will be determined by the overall size of the Fed’s balance sheet
and hence governed by other policy decisions regarding asset
purchases or lending programs. Most importantly, the Fed
will retain complete control of the cost of this liquidity in theforms of the RRP rate and the IOR rate.
Our proposed policy framework falls into a category thatis sometimes referred to as a “floor system.” The key attributesof a floor system are a large volume of liquid central bankliabilities, including bank reserves, and control of short-term
interest rates through the rates paid by the central bank on
its liabilities.23 Several major central banks are operating floor
systems at this time, although those systems rely entirely oninterest paid on bank reserves to manage overnight interest
rates.24 Our proposal instead recognizes the importance of thenonbank sector in the creation of credit and the determinationof broader financial conditions in US markets, and it therefore
extends the floor system to a broader set of firms through the
RRP facility.
In that regard, our proposal is a straightforward application of the groundwork that has been laid by the Fed. Indeed,
it was the Fed staff that made the key innovation, in that itbriefed the FOMC in July 2013 on the possibility of implementing a full allotment overnight RRP facility. Since then,the New York Fed has been running this facility on a limited
scale in order to observe how it functions and to ensure its
operational readiness.25 This innovation by the Fed staff isintegral to the above proposal, as it allows the FOMC to
set the rate on its overnight RRPs without having to worry
about the size of those transactions. We would expect the RRP
23. The other framework that is primarily in use, a so-called corridor system,
involves setting the rates that the central bank pays on liabilities well below
market rates and maintaining only a small amount of excess reserves in thesystem. Some argue in favor of a corridor system out of concern that a floor
system increases the central bank’s role in the financial sector and reduces
short-term lending between financial institutions. However, we are unconvinced about the importance of maintaining a large interbank lending market.
For more on monetary policy in floor and corridor systems, see Goodfriend(2002), Kahn (2010), and Keister (2012).
24. New Zealand has operated a floor system for years as its regular policy
framework. Several other major economies are effectively operating floor systems at present because of the expansion of their balance sheets, including the
euro area and the United Kingdom. It is not clear whether they will continue
to operate floor systems when rates are raised above the effective lower bound.
Bill Winters (2012) and Benoit Coeure (2013) explicitly discuss whether the
Bank of England and the European Central Bank, respectively, should retain
floor systems or return to their previous frameworks.
25. The New York Fed is currently testing the overnight RRP facility byoffering daily full allotment operations at fixed rates of between 1 and 5 basis
points, for amounts up to a limit of a $3 billion per counterparty. The counterparty limit is in conflict with the principle of full allotment and is being
raised gradually. The development of the RRP facility and the experience todate with these operations were described in detail in a recent speech by Simon
Potter (2013), the current head of the New York Fed’s Open Market Desk.

7

NUMBER PB14-4

facility to operate at very high balances and see no reason to
put a limit on its size.
This proposal is appealing from a conceptual perspective.
The Fed would be setting overnight risk-free interest rates inthe economy—the IOR rate for banks and the RRP rate fora broader set of counterparties. The idea is that these riskfree interest rates would establish a firm floor on many of theovernight interest rates determined in the market, particularly if
the Fed obtains a broad enough set of counterparties for its RRP
facility. In general, market participants would not be willing toprovide funds on an overnight basis to other counterparties fora lower yield than they could obtain at the Fed’s RRP facility,
given that the latter is free of counterparty risk.

An important advantage of our frameworkis that it allows the Fed to manage its
balance sheet independently of the polic yinterest rate. We believe the Fed should
leave a large amount of liquidity in thefinancial system on a permanent basis.
All other overnight interest rates (including the federal
funds rate) would then be determined in the market, reaching
the appropriate spreads relative to the overnight risk-freerate. It is always challenging to predict the behavior of these
spreads, as we saw with the initiation of IOR in late 2008, but
we can make a few predictions.26 We expect the interest rateon Treasury bills maturing within a few days to trade at rates
modestly below the RRP rate, given that bills can be held bya broader set of market participants (such as pension funds
and individual investors); the Treasury RP rate to trade close
to or several basis points above the Fed’s RRP rate;27 the federal
funds rate and the overnight eurodollar rate to trade modestly
above the Treasury RP rate for highly rated borrowers in normal
times, with the spread reflecting the credit risk associated with
unsecured transactions;28 and three-month London interbank
26. The Fed initially set the IOR rate below the federal funds rate target, on
the assumption that the federal funds rate would generally be above the IOR
rate. But, as discussed above, this assumption proved false.
27. In addition, we strongly suspect that the moderate volatility of theTreasury RP rate in recent years (figure 3) would diminish under our proposal
given the stability of the RRP rate on a day-to-day basis.
28. A recent study by Fed staff shows that the Treasury RP rate was typically,
but not always, several basis points lower than the federal funds rate prior to2007 (Bech, Klee, and Stebunovs 2012). Stephen Lumpkin (1998) also statesthat the “federal funds rate generally exceeds the overnight RP rate.”

8

JANUARY 2014

offered rate (Libor) to price off of the expected path of the overnight federal funds/eurodollar rate at a spread that is similar tothat currently observed. Bank deposit rates and money market
mutual fund rates could be lower than the RRP rate because ofcosts of intermediation.
As noted above, this framework shifts the attention awayfrom managing the level of reserves. As such, it is not clear that
there is a meaningful role for the TDF and term RRPs in thisframework. We do not believe that they should be used in massive size to achieve some specified amount of reserves, as thatwould run counter to the nature of this operational framework.
Indeed, there is no obvious way to determine the appropriate sizeof those operations in this framework. We also see shortcomings
to running these as full allotment operations, as this would involve having to set a target for the term risk-free rate in addition
to the overnight rate, which is an unnecessary complication.29
An important advantage of the proposed framework is thatit provides the Fed with the flexibility to manage its balance
sheet in a manner that it sees as appropriate, without having
to worry about the consequences for liquidity and overnightinterest rates. The FOMC would be able to provide a directive
to the New York Fed that specified not only the RRP rate but
also how the balance sheet should be managed.
Over the course of the next several years, the directive
would likely reflect the FOMC’s intention to maintain the balance sheet at very large levels and then to shrink it only slowly.
The proposed framework would ensure that the FOMC maintains sufficient control over financial conditions in these circumstances, despite the elevated supply of liquidity to the markets.
The FOMC would be affecting financial conditions in the samemanner as it has in the past, through the actual and anticipatedpath of short-term interest rates, with the large balance sheet basically becoming inconsequential for maintaining that control.
Going forward, the framework would allow the FOMC
to respond as needed with its balance sheet to unusual circumstances in financial markets or the economy, without compromising its control of overnight interest rates. This response could
take the form of liquidity policies during periods of financial
stress. Indeed, the Fed would presumably stand ready to lend
to banks through its discount window at a fixed spread overthe RRP rate, similar to its current practice.30 The Fed would
29. Use of term instruments would reduce the daily turnover associated withovernight RP transactions and hence the operational burden on both the Fed
and its counterparties. Accordingly, there could be scope for the Fed to runsome term operations in this framework, but it should do so in a manner thatis relatively neutral and leaves the focus on the setting of overnight interest
rates.
30. The current primary credit rate on discount window transactions is 50
basis points above the upper bound of the target federal funds rate. A straightforward transition to the new operating framework would be to set the rateNUMBER PB14-4

also maintain the ability to extend credit to financial firms byresuming the term auction facility (TAF) or the myriad of otherliquidity facilities that were implemented during the financial
crisis. These policies were generally seen as proving very effective at stemming the liquidity panic at that time and helping
to restore better market functioning over time (Gagnon and
Hinterschweiger 2013).
This response could also take the form of asset purchases.
Even if it is not a part of regular monetary policy, the Fed should
retain the option to purchase long-term bonds when bond yields
rise to levels that are clearly inconsistent with likely future policies and that threaten the achievement of the Fed’s economic
objectives. The need for such a policy is most compelling when
the traditional approach of lowering the overnight interest rateis constrained, as has been the case in recent years given that thepolicy rate has reached the effective zero lower bound, but it
could prove useful in other circumstances as well.31
Lastly, the proposed framework affords the FOMC greater
flexibility to determine the optimal size and composition of its
balance sheet in steady state. Even in the absence of financial
market stress or other special economic circumstances, the
FOMC may want to retain a balance sheet that is larger thanhistorical norms. Such an approach would leave more liquidity
in the financial system, which could improve its functioning
and promote financial stability. A full assessment of the optimal
size of the Fed’s balance sheet is beyond the scope of this Policy
Brief, but one should not presume that the previous system ofleaving a trivial amount of Fed liquidity in the market is optimal.
Our best guess is that it will prove desirable for the FOMC toleave several hundred billion dollars of liquidity in the financial
system in the long run under normal market conditions.
A D VA N TAG E S O F T H E N E W F R A M E W O R K
The most important advantages of this framework were noted
above—namely, that it should provide the FOMC with effective control of financial conditions while giving it flexibility
to adjust its balance sheet in a manner that is most appropriate for its economic objectives. In this section we review anumber of considerations that further support the proposed
framework.
to 50 basis points above the RRP rate. With less worry under this framework
about the liquidity that could be injected through the discount window, it
may be worth considering whether a narrower spread is more appropriate.
31. Similarly, the Fed could sell long-term bonds when yields fall substantiallybelow levels consistent with expected future short rates in a manner thatthreatens the achievement of its economic objectives. However, the need forsuch a policy is presumably more limited than the need for asset purchases,
because there is no hard constraint on the ability of the FOMC to tighten
policy through the overnight interest rate.

JANUARY 2014

 It focuses on rates that are of greater importance than
the federal funds rate
The federal funds market has always been a relatively small
funding market, but in recent years it has shrunk further and
now involves only a limited set of market participants. Indeed,most activity today involves GSEs lending to banks that holdthe funds as reserves. Lending between banks, which had been
the traditional activity in the market, has become limited,
because the high volume of aggregate bank reserves diminishes
the need for an active market to allocate those reserves. Dataon the aggregate volume of federal funds transactions are notavailable, but a recent Fed study estimates that the outstanding
volume of federal funds transactions is around $60 billion(Afonso, Entz, and LeSueur 2013a).32 Moreover, some argue
that the interbank funding market will likely shrink further in
response to regulatory efforts.
Given the characteristics of this market, the federal
funds rate is not an obvious choice to be the policy instrument. Other short-term funding markets have much larger
volumes of activity than the federal funds market and hence
are presumably more important for determining overall financial conditions in the economy.33 The RP market is a primeexample. A study by staff at the Federal Reserve Bank of New
York attempted to estimate the size of the RP market by taking
information from various segments of the market and applying
judgment in order to scale that information appropriately andavoid double counting. Their estimate put the amount ofoutstanding RP transactions in mid-2012 at well over $2 trillion (Copeland et al. 2012).34 Much of this activity is taking
place outside of the banking sector, which reflects the factthat a large portion of credit creation in our economy is notintermediated through banks and that a broader set of market
participants is relevant for determining financial conditions.
Moreover, even for banks, it is not clear that the federal
funds rate represents the marginal cost of funds when thelevel of total reserve balances is so high. As noted above, theamount of bank reserves will be well above $2 trillion for along period. In such a regime, the opportunity cost of funds to
32. The market for unsecured bank financing in general is larger. Indeed, while
complete data are not available, it appears that the volume of activity in the
eurodollar market is larger than that in the federal funds market, and the rates
in the two markets are linked to a considerable degree.
33. The choice of the instrument was less consequential in past years because
all overnight interest rates moved together. However, in circumstances inwhich there is greater scope for differences across overnight interest rates, it
seems odd to choose the market that has the smallest volume of activity as thetarget variable.
34. Although some of those transactions involve interdealer activity that nets
down into more limited exposure, the study suggests that more than half of
the activity took place in the triparty repo market, suggesting that it comprises
nondealer firms providing funding to the dealer community.

9

NUMBER PB14-4

a bank may be better measured by the IOR rate than the rate
at which it could borrow, as a bank would presumably funda marginal loan by reducing its reserves position rather thanincreasing its borrowing in the market.
Given the size of the RP market and the overall amountof bank reserves, the rates that are set on these instruments
are likely to be far more important for influencing economic
activity than the rate that occurs on federal funds transactions. It therefore makes sense to establish a framework that is
focused on these rates. Of course, our proposal does not target
the Treasury RP rate directly.35 However, we anticipate thatan overnight RRP with the Fed will be viewed as a very close
substitute to investing in the Treasury RP market, because thelatter transaction is secured with high-quality collateral and isthus close to being risk-free and because it uses much of thesame infrastructure and involves many of the same participants as the former market.
 It enhances the integration of financial markets
As discussed above, various short-term interest rates have been
below the IOR rate in recent years. That has been the caseeven for rates that involve little or no credit risk and hence aremost comparable to an overnight transaction with the Federal
Reserve. Indeed, for much of 2011 and again in 2013, theTreasury RP rate fluctuated below 10 basis points—well below
the IOR rate of 25 basis points (figure 3).
In an integrated and efficient financial market, rates ofreturn on financial instruments with the same characteristics
will generally be equal. Having the risk-free overnight interest
rates available to different types of market participants (nonbanks versus banks) differ by such a large amount violates thiscondition. By setting the IOR and RRP rates close together,
the Fed would help to better align short-term risk-free interest
rates, making the opportunity cost of lending and investment
essentially identical for a wide range of financial institutions
that affect the credit conditions available to households andbusinesses. In addition, this outcome is arguably more fair, as
the current differences in rates could be seen as being advantageous to banks over nonbanks.

35. Elizabeth Klee and Viktors Stebunovs (2013) recommend that the Fed
adopt the overnight Treasury RP rate as its main policy target. That proposal
addresses some of the concerns about maintaining a federal funds rate target
that we raise here. However, we believe that our proposal, in which the
Fed is simply setting the interest rates on its own RRP facility and on bankreserves, is a clean and effective framework that avoids some of the operational
complications and other concerns that might emerge from adopting a Treasury
RP rate target.

10

JANUARY 2014

 It could save taxpayer money
Maintaining an IOR rate that is well above the returns on othershort-term risk-free assets might also cost the taxpayer moremoney than would be the case under our proposal. Because
the current system forces banks to hold all of the liquidity
created by the Fed, and because they face a host of regulatory
costs, the Fed ends up paying the banks a higher return thanwould be necessary if the liquidity were spread more efficiently
throughout the financial system.
The current circumstances in funding markets can beused as an example to demonstrate this point. The FOMC has
achieved a certain level of broad financial accommodation for
the economy, which presumably incorporates the entire set ofshort-term risk-free interest rates across a variety of instruments.
If the Fed were to move to our proposed framework, it could
presumably achieve the same degree of overall accommodation
at a lower IOR rate if other risk-free rates in the economy (theTreasury RP rate and Treasury bill rates) were near the IOR
rate rather than well below it. The average short-term risk-freeinterest rate in the economy could be the same, but the range
would be smaller across instruments, and the Fed would nolonger be paying only the rate at the upper end of that range.
Moreover, our proposed framework should have positive
implications for the taxpayer over the longer run by allowing
the Fed to maintain a larger balance sheet. Even though thelarger balance sheet would result in larger interest payments on
reserves and RRPs, those liabilities would be matched by assetsthat generate positive income. On average, we expect that the
Fed would earn more on its assets than it pays on its liabilities,
because of a positive risk premium on the assets held.36
 It maximizes the benefits of quantitative easing (QE)
Numerous studies show that central bank purchases of longterm bonds tend to reduce long-term interest rates througha portfolio balance channel.37 The longer the bonds are
expected to be held, the higher the potency of a given volume
of purchases. If securities purchased through QE were instead
expected to be sold in the near future, those purchases would
have little effect on long-term rates. By allowing the Fed tomaintain an elevated balance sheet indefinitely, our framework
would maximize the potency of QE purchases, especially if the
36. The income to the taxpayer would be more volatile than would be the casewith a smaller balance sheet. However, much of the variation will be driven by
the business cycle, because short-term interest rates tend to decline when theeconomy weakens. This presents potential advantages, such as increasing scope
to engage in countercyclical fiscal policies.
37. We are among the coauthors of the first widely cited study (Gagnon,
Raskin, Remache, and Sack 2011). Gagnon and Hinterschweiger (2013)provide a recent survey of subsequent studies of the effects of QE.

NUMBER PB14-4

Fed were to establish a precedent of not selling assets before
redemption. Moreover, as noted above, the framework would
allow the Fed to stand ready for future asset purchases should
they prove necessary.
 It could mitigate shortages of Treasury collateral
The Fed’s large-scale asset purchases have reduced the amountof liquid debt securities available as collateral for a variety
of financial market activities. Some argue that the resulting
scarcity of Treasury securities has hindered the efficient functioning of financial markets and the ability of the markets
to effectively create credit outside of the banking system.
Although we find these concerns to be overstated in light of
the large net issuance of Treasury securities in recent years, weare open to the idea that making the Fed’s holdings of Treasury
securities available to the market could benefit the functioningof financial markets.
By having a standing RRP facility, the Fed would bemaking its holdings of Treasury securities available to alleviate
any shortages. Indeed, if the market were finding Treasury
securities to be in short supply, the Treasury RP rate would be
expected to decline, all else equal. This would make the Fed’s
RRP facility more attractive, allowing the market in aggregate
to shift liquidity from bank reserves into Fed RRPs. Thesetransactions would, in effect, make the Fed’s Treasury holdings
available to the market, providing some relief for the collateralshortage.38
 It provides a useful reference rate for financial markets
Our financial system depends on a small set of benchmark
interest rates for determining the payments on derivatives
contracts and as a reference in a broader set of financial
contracts. Although these benchmarks have historically been
based on market-determined rates (such as Libor or the effective federal funds rate), an administered rate such as the RRP
rate could also serve as a reference rate in these contracts.
Such an approach might be appealing if the RRP rate exerts a
powerful influence on a wide set of market rates, as the reference rate would then not be affected by the idiosyncratic properties of any particular market. Moreover, the RRP rate hasan advantage over a private rate as a benchmark because there
would be no issue of errors in measurement or misreporting

38. As noted earlier, for many types of counterparties, the Fed does not allow
the counterparty to rehypothecate the collateral. Nevertheless, the transaction
would still be expected to relieve the collateral shortage by providing an alternative for those counterparties that would have otherwise removed Treasury
collateral from the system (such as doing RPs with other counterparties orbuying a Treasury bill).

JANUARY 2014of the rate. Of course, switching between benchmarks could
present a difficult transition, as discussed in the appendix.
 It improves the efficiency of liquidity management in
the financial system
The proposal makes liquid financial instruments available to arange of financial market participants, which could help themefficiently manage the liquidity of their portfolios. In addition, it may benefit the functioning of the payments system.
A recent study by Fed staff argues that the high volume ofbank reserves in recent years has reduced measures of risk inthe payments system (Bech, Martin, and McAndrews 2012).39
In particular, banks have less incentive to delay payments
until late in the day in order to economize on reserves. Bank
reserves provide a unique transaction service and yet are costless to create, so that society benefits by their abundant supply.
Our proposal could save on resources spent by the banking
system in economizing reserve balances relative to what would
take place if the Fed returned to a framework with minimal
amounts of excess reserves.
 It appropriately ignores the quantity of money
Our proposed operating framework relies on the fact that thetraditional analysis of the money multiplier based on so-called
high-powered money (central bank liabilities) is defunct whencentral bank liabilities pay interest. In our view, central banks
always achieved macroeconomic stabilization and low inflation by managing interest rates. Formerly, the path to controlling interest rates was the supply of non-interest-bearing
currency and bank reserves. Now central banks can control
interest rates directly through the rates they pay on their
liabilities. This new framework severs the link between the sizeof a central bank’s balance sheet and inflation.40
 It accords well with regulatory changes
A full review of the effects of realized and prospective changes in
the regulatory framework, and how those changes interact withthis proposal, is beyond the scope of this Policy Brief. However,in general the proposed framework should fit well with someof the regulatory changes that have been implemented or are
under consideration. Various regulatory changes emphasize theimportance of financial market participants retaining a liquid
portfolio. This is the case for banks, for example, through the
39. The Fed’s decision in 2008 to increase the availability of collateralized
daylight overdrafts in the payments system arguably provides similar benefits.
40. Marvin Goodfriend (2002) and Todd Keister, Antoine Martin, and James
McAndrews (2008) also discuss this separation in the conduct of monetary
policy.

11

NUMBER PB14-4

liquidity coverage ratio (LCR) that is part of Basel standards,
and it is also the case for nonbanks, for example, throughtougher Securities and Exchange Commission (SEC) liquidity
standards for money market funds. The creation of bank reserves
and RRPs from an expanded Fed balance sheet provides liquid
financial instruments that can be useful for meeting these standards.41 In this regard, the role of RRPs is important, as it allows
this liquidity to be held outside the banking sector.
A D D I T I O N A L CO N S I D E R AT I O N S F O R T H E
PROPOSALThe effectiveness of our proposal will depend critically on how
the RRP rate is set and on how it interacts with other market
interest rates. Here we discuss several considerations along thosedimensions.
 RRP rate relative to the IOR rate
Above we argued that it is best to achieve an “interior solution”
in which the market would maintain large amounts of bothbank reserves and RRPs, without the Fed’s framework skewingthat liquidity strongly towards one instrument or the other. Thisoutcome requires that the IOR and RRP rates be relatively close
to each other. We believe that the most appropriate choice may
be to set the IOR and RRP rates equal.42
Some considerations would seem to argue for setting the
RRP rate below the IOR rate. Specifically, the FDIC fee acts
as a tax on banks’ holdings of reserves—one that other financial institutions do not have to pay on their holdings of Fed
liquidity. However, the FDIC fee is just one of a variety of
regulatory costs for banks that could be taken into account, andbanks also receive key benefits (including deposit insurance anddiscount window access) that are not provided to other financial
institutions. Thus, it does not seem appropriate to simply adjust
for this one fee.
Moreover, other types of financial institutions face theirown sets of regulatory costs and benefits. If one accepts the argument that the RRP rate should differ from the IOR rate due to
41. The details of the regulatory changes matter for this point. For banks,
holding reserves is just as beneficial for the LCR as holding Treasury securities,
and so Fed purchases of treasuries do not affect the ability to meet the LCR
in aggregate. However, purchases of MBS and other liquidity facilities canmeaningfully increase liquidity. For money funds, the SEC rules involve thematurity of the instruments held. Thus, the availability of RRPs, even if generated by the Fed’s purchases of longer-term treasuries, can have a beneficial
effect in aggregate.
42. To further make RRPs comparable to IOR, it would be useful for the Fed
to push the RRP operations as late as possible within the day, subject to theconstraints arising from the settlement of the triparty RP market. The New
York Fed announced a step in this direction on January 13, 2014, by pushing
the time of operations from late morning to early afternoon.

12

JANUARY 2014

regulatory costs, then one might argue that the RRP rate should
differ across different types of counterparties. Our view is that it
is too difficult to measure regulatory costs and benefits to accurately adjust for these differences. In addition, from a conceptual
perspective, it is not clear that the Fed should be attempting tooffset regulatory costs by adjusting the return offered to market
participants. Ideally, differences in regulatory treatment acrossinstitutions should reflect social costs and benefits of theiractivities.
Lastly, it should be noted that bank reserves and Fed RRPs
are not perfect substitutes, in that reserves provide transactions
services that other short-term financial instruments do not. Thisconsideration provides another reason not to set the IOR rate
above the RRP rate.
Based on these arguments, we believe that the best approachis to set the two rates equal. However, this approach could be
adjusted as we learn about how markets behave in the presenceof large-scale RRPs. The Fed could stand ready to insert a smalland steady wedge between the two rates if the balance between
the levels of bank reserves and RRPs outstanding swings toostrongly in one direction or the other.
 Need to monitor short-term interest rates
We believe that the combination of IOR and the RRP facility
will exert a strong influence on other overnight interest rates.
Nevertheless, it will be important for the Fed to monitor the
behavior of key short-term interest rates as the framework is
implemented, and to make adjustments if necessary.
If other short-term rates trade significantly below the RRP
rate, the Fed could respond by expanding the list of RRP counterparties to include important investors in the assets whose rates
are lower, thereby giving them the option of earning a higher
return. By including most money market mutual funds as counterparties, the Fed has already captured the most important classof nonbank investors, and hence we believe that such expansion
will not prove necessary. However, there is little reason not tobe as expansive as possible, as broader participation should only
strengthen the floor and make the proposed framework more
effective.43
The Fed might also be concerned if short-term market rates
instead traded significantly above the RRP rate. In this case, theappropriate response will depend on the circumstances drivingthat outcome. If this pattern were to result from unusual demand
for liquidity or meaningful financial stress, the Fed mightchoose to respond by reducing the RRP and IOR rates or byusing its liquidity facilities more aggressively (such as lowering
43. We recognize that the process of adding RRP counterparties is notstraightforward, as it requires considerable due diligence and involves a number of operational and legal issues.

NUMBER PB14-4

the primary credit rate at its discount window or restarting theTAF). If the firmness of market interest rates were to occur inmore normal market circumstances, the Fed could see this asa signal that the financial system does not have an appropriate
level of liquidity and could respond by increasing the amountof assets held on its balance sheet. Alternatively, the Fed might
consider modifying our proposed framework to automaticallyinject reserves at a particular rate, as discussed next.
 A potential modification to stand ready to inject reserves
An important assumption for our proposed framework is thatthe large amounts of liquidity created by the Fed’s balance
sheet will keep other overnight interest rates relatively close to
the RRP rate (and IOR rate) established by the Fed. However,
one cannot rule out the possibility that market interest rates

We believe that the best time for the FOMC
to begin transitioning to a new framework is
now—well in advance of polic y tightening.
could be persistently above the RRP rate, particularly once theFed’s balance sheet shrinks towards its new steady state level.
Based on this consideration, the Fed could consider modifying our proposed framework to incorporate an automaticmechanism for providing reserves if market interest rates are
judged to be too far above the RRP rate or too volatile even in
normal times. In particular, within our proposed framework,
the Fed could also offer a standing RP facility with full allotment at a rate moderately higher than the RRP rate (say 10
basis points above the RRP rate).44 This facility would automatically inject reserves by lending to financial institutions whenmarket rates became firm relative to the RRP rate. The modified
framework would therefore have a symmetric approach, withstanding facilities to react to soft market rates (through RRPs)
and to firm market rates (through RPs). This two-sided ap44. The discount window available to banks has some similarities to this
proposed RP facility, in that it stands ready to inject funds against collateral
if funding rates for banks get too high. However, at most times it is used as asource of backup liquidity for individual firms rather than a broad facility for
influencing market prices. It could be modified to more effectively support the
RP facility, for example, by offering discount window credit against Treasury
collateral at the same rate as the RP facility (10 basis points above the RRPrate), while maintaining a higher rate for other types of collateral.

JANUARY 2014

proach could provide the Fed with even more effective controlof short-term interest rates.
CO N C LU S I O N
The notion of the Federal Reserve adopting a new operating
regime may sound daunting, and some observers will want tostay as close as possible to the old regime because it feels more
comfortable. But trying to maintain the existing operating
framework would be inappropriate, because the policy environment has changed dramatically. The Fed’s balance sheet is likely
to be very large for an extended period of time, and financial
markets will be awash in substantial amounts of liquidity as aresult. It is important for the Fed’s operating regime to adapt tothose circumstances to ensure that the FOMC retains controlof overnight interest rates in a manner that is efficient for thefinancial system and sufficient for the Fed to meet its economic
mandate.
In this Policy Brief, we propose an operating framework
for monetary policy that would meet these standards in a worldof high liquidity and a large Fed balance sheet. This framework
shifts the FOMC’s operating instrument to the rate at its overnight RRP facility, with the IOR rate set in lockstep with the
RRP rate. The federal funds rate would become just one of thevarious overnight interest rates determined by the market in thenormal transmission of monetary policy. Moreover, the framework would allow the Federal Reserve to manage its balance
sheet in a manner that it saw as appropriate. We anticipate
that the FOMC will shrink the balance sheet only gradually incoming years, and we suggest that, over the long run, it retain
a larger balance sheet as a share of GDP than has been the casehistorically.
In our view, this approach would improve the transmissionof monetary policy, as the Fed would be setting two overnightinterest rates that directly affect a far larger pool of institutions
and investors than does the federal funds rate. At the same time,
this framework would make the financial system more efficient,more equitable, and more robust. We believe that the best time
for the FOMC to begin transitioning to a new framework is
now—well in advance of policy tightening. If it were to instead
wait until the shortcomings of its current operating regime
become apparent, the FOMC would be seen as reacting to difficult circumstances rather than taking proactive steps to achieve
the best operating framework possible.

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NUMBER PB14-4

APPENDIXF U R T H E R CO N S I D E R AT I O N S R E L AT E D TO T H E
F E D E R A L F U N D S R AT E
This Policy Brief has argued that conducting overnight RRPs
in unlimited size and paying interest on reserves are sufficient
instruments for affecting financial conditions. In that context,
we feel that it is appropriate for the FOMC to set the RRP
rate as its policy instrument (with the IOR rate set in lockstep).
However, the FOMC has relied on the federal funds rate as its
main policy target for many years, and hence one might question whether dropping the focus on the federal funds rate is
the right approach. Here we consider the challenges that would
arise from retaining a target for the federal funds rate as well as
the challenges associated with transitioning away from it.
 Operational difficulties of maintaining a target federal
funds rate
The FOMC could decide to retain the federal funds rate as themain policy target and use the RRP facility and the IOR rateto achieve that target. Here we raise several broad concerns
about this approach.
First, it is unclear what configuration of rates would deliver
the federal funds rate target. Under the expected patterns
discussed above, the New York Fed would set the RRP rate andthe IOR rate below the federal funds rate target by whatever gap
was seen as likely to prevail at the general level of liquidity at thetime. However, if the federal funds rate remained unexpectedly
soft relative to other overnight interest rates, it is possible that
the Open Market Desk would have to set the RRP rate above
the IOR rate, thereby using the full allotment facility to remove
substantial reserves and pulling the effective federal funds rate
above the IOR rate. The New York Fed would have to adjust its
approach as it learned about these patterns.
Second, and more problematic, the gap between thefederal funds rate and the RRP rate could prove to be volatile over time, especially if the availability of the RRP facility
causes the federal funds market to continue to shrink. In thatcase, the Fed might have to frequently adjust the RRP and
IOR rates to hit the federal funds rate target. This approach
would be counterproductive, as it would introduce unpre-

14

JANUARY 2014dictable volatility in the overnight interest rate of significant
importance (applying to nearly $3 trillion of financial instruments) in order to maintain a steadier level of an interest ratethat is of more limited relevance (applying to less than $100
billion of transactions).
A third potential problem with this approach is that thepresence of a federal funds rate target, by itself, does not fully
determine how the New York Fed should operate, especially ifterm draining tools were in use. In particular, the New YorkFed could presumably achieve a given target with different
combinations of the total amount of reserves and the RRP
rate. Thus, the FOMC would have to specify either how it
wanted reserves managed or the desired spread between thefederal funds rate and the RRP rate. The first option would
seem odd, considering that the FOMC has downplayed theimportance of the quantity of reserves. And under the second
option, the FOMC would be specifying an operating objective
for the RRP rate, as is the case in our proposal.
 Transition to the new framework
One important challenge involved with changing an operationalframework is the transition. In this case, the primary issue is not
the activity in the federal funds market itself but the fact thatthe effective federal funds rate is the reference rate for an important set of interest rate swaps (overnight index swaps, or OIS)
and that OIS rates serve as a reference for a much broader setof derivatives and other financial contracts. Thus, any volatility
that is introduced into the effective federal funds rate throughthe changes described here could have unintended and undesirable consequences for the financial system.
In our view, it would be inappropriate for the Fed toconsider itself “stuck” with a federal funds rate target for thisreason. However, this consideration certainly speaks to theneed for a careful transition. Ideally, the financial system would
migrate to a set of contracts indexed to the Fed’s RRP rate(or equivalently the IOR rate), given that it becomes the key
reference point for other short-term interest rates. There may
be an advantage to indicating the change in framework wellin advance, and to managing the federal funds rate smoothly
through the transition, to limit any unexpected consequences
for existing contracts.

NUMBER PB14-4

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Gagnon, Joseph, and Marc Hinterschweiger. 2013. Responses ofCentral Banks in Advanced Economies to the Global Financial Crisis.
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