Federal Reserve Bank Services Private Sector Adjustment Factor, 29512-29526 [05-10168]
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29512
Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
BURDEN ESTIMATE, COMBINED DEPOSIT BROKERS AND INDIVIDUALS—Continued
[Frequency of response: occasional]
Form No.
Form title
7200/15 .......
Declaration for Plan and Trust .......................................................................
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650
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Request for Comment
Comments are invited on: (a) Whether
the collection of information is
necessary for the proper performance of
the FDIC’s functions, including whether
the information has practical utility; (b)
the accuracy of the estimates of the
burden of the information collection,
including the validity of the
methodology and assumptions used; (c)
ways to enhance the quality, utility, and
clarity of the information to be
collected; and (d) ways to minimize the
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of automated collection techniques or
other forms of information technology.
All comments will become a matter of
public record.
Dated at Washington, DC, this 18th day of
May, 2005.
Federal Deposit Insurance Corporation.
Robert E. Feldman,
Executive Secretary.
[FR Doc. 05–10220 Filed 5–20–05; 8:45 am]
BILLING CODE 6714–01–P
FEDERAL RESERVE SYSTEM
Formations of, Acquisitions by, and
Mergers of Bank Holding Companies
The companies listed in this notice
have applied to the Board for approval,
pursuant to the Bank Holding Company
Act of 1956 (12 U.S.C. 1841 et seq.)
(BHC Act), Regulation Y (12 CFR Part
225), and all other applicable statutes
and regulations to become a bank
holding company and/or to acquire the
assets or the ownership of, control of, or
the power to vote shares of a bank or
bank holding company and all of the
banks and nonbanking companies
owned by the bank holding company,
including the companies listed below.
The applications listed below, as well
as other related filings required by the
Board, are available for immediate
inspection at the Federal Reserve Bank
indicated. The application also will be
available for inspection at the offices of
the Board of Governors. Interested
persons may express their views in
writing on the standards enumerated in
the BHC Act (12 U.S.C. 1842(c)). If the
proposal also involves the acquisition of
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Hours
a nonbanking company, the review also
includes whether the acquisition of the
nonbanking company complies with the
standards in section 4 of the BHC Act
(12 U.S.C. 1843). Unless otherwise
noted, nonbanking activities will be
conducted throughout the United States.
Additional information on all bank
holding companies may be obtained
from the National Information Center
website at www.ffiec.gov/nic/.
Unless otherwise noted, comments
regarding each of these applications
must be received at the Reserve Bank
indicated or the offices of the Board of
Governors not later than June 17, 2005.
A. Federal Reserve Bank of St. Louis
(Glenda Wilson, Community Affairs
Officer) 411 Locust Street, St. Louis,
Missouri 63166-2034:
1. First Horizon National Corporation,
Memphis, Tennessee; to acquire 100
percent of the voting shares of United
Bank and Trust Company, Saint
Petersburg, Florida.
B. Federal Reserve Bank of Kansas
City (Donna J. Ward, Assistant Vice
President) 925 Grand Avenue, Kansas
City, Missouri 64198-0001:
1. Centennial Bank Holdings, Inc.,
Fort Collins, Colorado; to acquire 100
percent of the voting shares of First
MainStreet Financial, Ltd., Longmont,
Colorado, and thereby indirectly acquire
voting shares of First MainStreet Bank,
N.A., Longmont, Colorado.
Board of Governors of the Federal Reserve
System, May 18, 2005.
Robert deV. Frierson,
Deputy Secretary of the Board.
[FR Doc. 05–10278 Filed 5–20–05; 8:45 am]
BILLING CODE 6210–01–S
FEDERAL RESERVE SYSTEM
[Docket No. OP–1229]
Federal Reserve Bank Services Private
Sector Adjustment Factor
Board of Governors of the
Federal Reserve System.
ACTION: Notice with request for
comments.
AGENCY:
SUMMARY: The Board requests comment
on potential modifications to the
method for calculating the target return
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Respondents
Burden hours
on equity (ROE) in the private-sector
adjustment factor (PSAF). The PSAF
imputes the costs that would have been
incurred and profits that would have
been earned had the Federal Reserve
Banks’ priced services been provided by
a private firm. The Monetary Control
Act of 1980 (MCA) requires that the
Federal Reserve set fees for its services
to recover, over the long run, its actual
costs of providing the services, as well
as the imputed costs and profits. The
Board reviews its method for calculating
the PSAF periodically to assess whether
it is still appropriate in light of the
changing business and regulatory
environment, industry practices, and
accounting standards.
Specifically, the Board requests
comment on possible changes to the
current method to compute a target rate
of return on equity capital, including
changes to the analytical models and
peer group institutions used. The
Board’s method for setting its overall
level of equity capital would continue to
be based on the Federal Deposit
Insurance Corporation (FDIC) guidelines
for a well-capitalized institution for
insurance premium purposes.
DATES: Comments must be submitted on
or before July 22, 2005.
ADDRESSES: You may submit comments,
identified by Docket No. OP–1229, by
any of the following methods:
• Agency Web Site: https://
www.federalreserve.gov. Follow the
instructions for submitting comments at
https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
• Federal eRulemaking Portal: https://
www.regulations.gov. Follow the
instructions for submitting comments.
• E-mail:
regs.comments@federalreserve.gov
• FAX: 202/452–3819 or 202/452–
3102.
• Mail: Jennifer J. Johnson, Secretary,
Board of Governors of the Federal
Reserve System, 20th Street and
Constitution Avenue, NW., Washington,
DC 20551.
All public comments are available
from the Board’s Web site at https://
www.federalreserve.gov/generalinfo/
foia/ProposedRegs.cfm as submitted,
except as necessary for technical
reasons. Accordingly, your comments
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Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
will not be edited to remove any
identifying or contact information.
Public comments may also be viewed
electronically or on paper in Room MP–
500 of the Board’s Martin Building (20th
and C Streets, NW) between 9 a.m. and
5 p.m. on weekdays.
FOR FUTHER INFORMATION CONTACT:
Gregory L. Evans, Assistant Director
(202/452–3945), Brenda L. Richards,
Financial Project Leader (202/452–
2753), or Jonathan Mueller, Financial
Analyst (202/530–6291); Division of
Reserve Bank Operations and Payment
Systems. Telecommunications Device
for the Deaf (TDD) users may contact
202/263–4869.
SUPPLEMENTARY INFORMATION:
I. Background
The MCA requires that the Board
establish fees for ‘‘priced services’’
provided to depository institutions at a
level necessary to recover all direct and
indirect costs actually incurred and
imputed costs. Imputed costs include
financing costs, return on equity capital
(profit), taxes, and certain other
expenses that would be incurred if a
private business firm provided the
services. The imputed costs and
imputed profit are collectively referred
to as the private sector adjustment factor
(PSAF). In establishing fees, the Board
considers the objectives of fostering
competition, improving the efficiency of
the payments mechanism, and
providing an adequate level of services
nationwide.
The methodology underlying the
PSAF is reviewed periodically to ensure
that it is appropriate and relevant in
light of changes that may have occurred
in Reserve Bank priced-services
activities, accounting standards, finance
theory, and regulatory and business
practices.1 The Board considers four
principles when reviewing the PSAF
methodology: (1) Providing a
conceptually sound basis for efficient
pricing in the market for payments
services, (2) maintaining consistency
with actual Reserve Bank financial
information and practice, (3)
maintaining consistency with privatesector practice, and (4) using data in the
public domain in order to make the
PSAF replicable. In addition, the Board
seeks to balance the cost, complexity,
and accuracy of the PSAF methodology
1 During the development of this proposal, the
Federal Reserve worked with a consulting firm
specializing in capital allocation and risk
management and four finance professors from U.S.
academic institutions to obtain information about
current private-sector practices.
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in implementing theoretically sound
approaches.2
The Board seeks to establish fees for
priced services to recover projected
costs and the PSAF over the long run.
Because the Board does not believe that
price volatility increases efficiency in
payment systems, it has been wary of
cost-recovery models that produce
volatile results from year to year. For
this reason, fees for each year are not set
to offset any previous or subsequent
years’ overrecovery or underrecovery.
Moreover, other providers of payment
services do not typically establish prices
in order to eliminate surpluses or
shortfalls incurred in previous years. A
highly volatile PSAF applied
mechanically to the fee-setting process
could also result in unnecessarily
volatile prices, which, in turn, could
adversely affect the efficient operations
of the Reserve Banks and other payment
service providers. As a result, the Board
has preferred, when appropriate, to
adopt PSAF methods that provide for
stable rather than volatile returns.
II. Private Sector Adjustment Factor
The current method for calculating
the PSAF includes determining the book
value of Federal Reserve assets and
liabilities to be used in providing priced
services during the coming year, and the
rates used to impute financing costs.
The Board’s method involves
developing an estimated Federal
Reserve priced-services pro forma
balance sheet using actual pricedservices assets and liabilities. The
remaining elements on the balance
sheet, such as equity, are imputed as if
these services were provided by a
private-sector firm. To satisfy the FDIC
requirement for a well-capitalized
institution, equity is imputed at 5
percent of total assets.3 In 2005, assets
are projected to total $16.2 billion,
resulting in imputed equity capital of
$808 million.
A target ROE is estimated and applied
to the equity capital on the pro forma
2 The previous review of the PSAF was completed
in 2001 (65 FR 82360, October 10, 2001) and
changes were implemented for the 2002 PSAF.
3 Equity is imputed based on the FDIC definition
of a ‘‘well-capitalized’’ institution for insurance
premium purposes. The FDIC requirements for a
well-capitalized financial institution are (1) a ratio
of total capital to risk-weighted assets of 10 percent
or greater; and (2) a ratio of Tier 1 capital to riskweighted assets of 6 percent or greater; and (3) a
leverage ratio of Tier 1 capital to total assets of 5
percent or greater. The Federal Reserve pricedservices balance sheet total capital has no
components of Tier 1 or total capital other than
equity; therefore, requirements 1 and 2 are
essentially the same measurement. Because riskweighted assets are considerably below actual
assets, only requirement 3 is binding for the Federal
Reserve priced services.
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balance sheet to determine the pricedservices cost of equity.4 Currently, the
ROE is calculated by averaging the
results of three analytical models: The
comparable accounting earnings (CAE)
model, the discounted cash flow (DCF)
model, and the capital asset pricing
model (CAPM). The top fifty bank
holding companies (BHCs) based on
deposit balance serve as the peer group
for Federal Reserve priced services and
the peer group’s financial data is used
to estimate the target ROE. Selecting the
BHCs based on deposit balances was
intended to maintain the focus on the
largest banking entities because they
process transactions and perform
settlement services comparable to those
provided by the Reserve Banks.
The CAE model uses historical BHC
accounting information to estimate ROE.
The ROE for an individual BHC in the
peer group is calculated as the ratio of
the firm’s net income before taxes to its
book value of equity and is averaged
with other BHCs to determine the peer
group ROE. The DCF model takes a
forward-looking approach to estimating
ROE. It assumes that a firm’s stock price
is equal to the discounted present value
of all expected future dividends. The
CAPM captures the risk—return
relationship that rational investors
require in efficient markets. The
underlying theory of the model assumes
that investors demand a premium for
bearing risk; that is, the higher the risk
of the security, the higher its expected
return must be to attract investors to buy
it. The basic principle of CAPM is that
the required rate of return on a firm’s
equity is equal to the return on a riskfree asset plus a risk premium.
The PSAF also includes imputed
taxes, which are captured using a pretax
ROE. A pretax ROE assumes that a 100
percent recovery of expenses, including
the targeted ROE, is achieved. The PSAF
tax rate is the median of the rates paid
by the fifty BHCs in the peer group over
the past five years. Finally, the PSAF
includes the estimated share of the
Board of Governors’ expenses that
supports priced services, imputed sales
tax, and an imputed assessment for
FDIC insurance.
III. Discussion
A. Overview
The Board is considering changes to
the methodology used to estimate the
target ROE for priced services. The table
below summarizes the current
methodology and the changes
4 For the 2005 PSAF, the target ROE of 18.1
percent is multiplied by the equity capital of $808
million to get the priced services cost of equity of
$146 million.
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Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
more depth in subsequent sections of
the notice.
B. Imputed Return on Equity
information. The annual ratios of net
income before taxes to equity of the
individual BHCs are averaged to
determine the peer group ROE. The
arithmetic average of the last five years’
individual ROEs is the CAE ROE.
This model is appealing because it is
directly related to the published
financial statements of BHCs. Because
the priced-services ROE is applied to
the book value of equity, the CAE is also
the only model that is consistent with
the pro forma presentation that is used
to measure cost recovery and
compliance with the MCA. The CAE
model’s primary shortcomings are that it
relies exclusively on historical data
reported on a book value basis to project
an expected market rate of return and
does not incorporate future earnings
expectations. The ROE results for any
point are substantially anchored in past
accounting book values, and book
values can be less relevant to investors
The target ROE for Reserve Bank
priced-services activities is established
at the entity level rather than by
developing an ROE for each service.
Conceptually, the ROE is developed
with a shareholder’s perspective in
mind and considers whether
shareholders are adequately
compensated in the form of average
equity returns given the overall risk of
the business activities.
Current Three-Model Approach. As
discussed earlier, the Board targets an
ROE using the average of the results of
the CAE, DCF, and CAPM models. The
three economic models use different
inputs and provide different outlooks
when determining a unique target ROE.
1. Comparable Accounting Earnings
Model
The CAE model’s sole source of data
is peer group historical accounting
5 Consensus earnings forecasts and long-term
growth rates (as published by the Institutional
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than market-based measures of a firm’s
financial condition. The CAE results can
be particularly unrealistic during
periods when there are large
fluctuations in business cycles. These
shortcomings were identified when the
three-model approach was adopted in
2001; however, the Board believed the
CAE results complemented the marketdriven results of the DCF and CAPM
models when the results of all three
models were averaged.
2. Discounted Cash Flow Model
The DCF approach requires as inputs
the BHC peer group stock prices as well
as forecasts of future dividends and
long-term dividend growth rates.5 The
implied discount rate of a firm can be
calculated and considered the firm’s
estimated ROE in the DCF model if the
stock price and expected future
dividends are known. The ROEs for
individual BHCs are combined using a
Brokers Estimate System) are translated into future
dividend cash flows.
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considered, which are discussed in
Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
29515
weighted average based on each BHC’s
equity market capitalization. The
formula for the DCF model is
equity market capitalization. The
formula for the DCF model is
The DCF model was adopted for the
ROE calculation because it incorporates
projections of future shareholder market
returns, which are not reflected in the
CAE or CAPM models. The DCF model
can be a powerful valuation tool;
however, meaningful results depend on
analysts’ ability to project cash flow and
dividend growth rates accurately.
Financial market history has shown the
inherent difficulty faced by analysts in
developing accurate financial
projections given the rapid shifts in
business activities as a result of
increased competition, changes in the
regulatory environment, technological
obsolescence, and other forces.
3. Capital Asset Pricing Model
The CAPM requires judgment in
determining
• The risk-free interest rate or the rate
of return on an investment with no or
low risk, typically measured using a
Treasury rate.
• The method, data, and period used
for estimating the beta. The beta
measures the market risk of a particular
company relative to the risk of the
overall market. A beta of 1.0 signifies
that a firm’s returns will be perfectly
correlated with the market and move up
or down with the market’s return
(dividends and capital gains and losses).
A beta of less than 1.0 indicates that a
firm’s returns fluctuate less than the
market (less risky); while a beta greater
than 1.0 indicates that a firm’s returns
tend to vary more than the market (more
risky).
• The market risk premium, which
estimates the additional return investors
require to forgo the safety of investing
in no or low-risk assets to bear the
higher risk of common stock.
The CAPM provides a framework to
determine the risk-return relationship
required by investors. Because CAPM
measures the relevant market risk of a
firm’s stock and the contribution of the
firm’s stock to the market risk of a welldiversified portfolio, CAPM can be
applied to many business decisions. For
example, investors, who are concerned
with market risk when holding
diversified portfolios, can use CAPM to
make portfolio management decisions
and balance the risk-return tradeoff.
Business managers, who are concerned
with maximizing the return to
shareholders, can also use CAPM to
make financing decisions because
CAPM produces the required rate of
return expected by the market. As a
practical matter, not all financial
models, including CAPM, will
necessarily produce accurate estimates
unless the decisionmaker exercises
some judgment to adjust for risks that
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CAPM’s basic principle is that the
required rate of return on a firm’s equity
is equal to the return on a risk-free asset
plus a risk premium. The risk premium
is a measurement of the expected excess
return on a market portfolio of equities
(the expected market risk premium) and
the correlation of the firm’s returns to
the market returns (beta).
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Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
one-year Treasury bill as the risk-free
rate. The monthly stock returns over a
rolling ten-year period are used in a
linear regression technique to estimate
the peer group beta.6 To capture each
BHC’s involvement in similar service
activities, the returns of each BHC in the
peer group are weighted by market
capitalization. The market risk premium
is estimated using the monthly excess
return of the market over the risk-free
rate since 1927, which is standard
finance practice.7
The following table shows Reserve
Bank priced services pretax and after-
tax ROE targets from 2001 to 2005 using
each of the three models. Table 2
highlights the CAPM’s sensitivity to
interest rates, which has made it much
more variable from year to year than the
other two models. As rates fell from
2001 to 2005, the CAPM produced an
ROE that is much lower than the ROEs
produced by the CAE or DCF models.
Conversely, during periods of higher
interest rates such as the 1980s, the
CAPM produced higher ROE results
than the CAE or DCF. Over the eighteenyear period of 1983–2000, the average
ROE of the CAPM was the highest of all
three models at 15.1 percent, followed
by the CAE at 11.4 percent and the DCF
at 13.0 percent.
The three models for calculating the
target ROE are based on different
assumptions, analytical approaches, and
data sources. Because each of the three
models brings a different perspective to
a firm’s cost of equity capital, the Board
concluded that a simple average of the
three was a better measure of the peer
group’s ROE than any single model by
itself. Support for this approach was
found in academic studies that
demonstrated that the use of multiple
models can improve estimation
techniques when each model provides
new information. Taking the average of
the three models was seen as a way to
minimize the effect of unusual data and
provide a less-volatile ROE over time. In
recent years, however, academic,
market, and financial services industry
practices have evolved, and the
weaknesses of the CAE and DCF have
become more widely recognized. As a
result, reliance on the CAE and DCF for
targeting a firm’s ROE has declined.
The Board requests comment on
alternative methods to calculate the
target ROE. Are there models, other than
the three in use, that the Board should
consider? What is considered to be a
reasonable target ROE for institutions
that provide services similar to those
provided by the Reserve Banks?
Possible change to the imputed ROE
methodology. To implement the
principle of maintaining consistency
with private-sector practice, the Board
reviewed current finance theory and
practice to determine whether the
current PSAF methodology, and in
particular the three-model approach, is
the most appropriate method for
6 Linear regression uses variables, such as the
BHCs’ equity returns and the market’s return, and
estimates a relationship between them in the form
of a straight-line.
7 The market risk premium data are found on the
Kenneth R. French website (https://
mba.tuck.dartmouth.edu/pages/faculty/ken.french).
Stock return data are obtained from the Center for
Research in Security Prices.
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4. Results of the Current Three-Model
Approach
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the models do not measure. In addition,
CAPM can produce varying results that
may not accurately predict future
performance, depending on the formula
inputs. Nevertheless, CAPM is a useful
conceptual tool because it represents the
way rational people would behave when
managing risk and making financing
decisions.
Because the results of the CAPM are
sensitive to the inputs, they are critical
to the model’s usefulness. The risk-free
rate is a significant factor because it
both is used to determine the market
risk premium and also is added to the
risk premium of the peer group in the
CAPM calculation. Currently, the Board
uses the constant maturity yield on the
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computing the ROE. When the Board
adopted the current three-model
approach, there was evidence that
multiple models were being used by
academics and professionals to estimate
ROE.8 Current information suggests,
however, that CAPM has continued to
evolve and is used more in practice than
the CAE and DCF methods.9
Specifically, the CAE method, while not
widely used at the time of the last study,
has continued to wane in use. Similarly,
the effectiveness of the DCF as a tool for
estimating ROE has also been
questioned based on recent research
findings that analysts’ dividend
projections can be upwardly or
downwardly biased.10 Although some
public utilities still use the results of the
DCF model together with CAPM for
developing ROE targets, it is not used by
many larger financial institutions.11
With information suggesting that two of
the three models that are used in the
current ROE method might not be in
line with common practice, the Board is
considering discontinuing using the
average of the results of three models
and use CAPM only to calculate the
target ROE. While CAPM has the virtue
of being a forward-looking, marketbased measure of ROE that incorporates
the fundamental risk’return
relationships required by rational
investors and is the most widely
accepted and used model for calculating
ROE, it also continues to be the most
volatile of the methods, as shown in
table 2. The volatility comes from the
8 For example, when the current method was
adopted, the New York State Public Service
Commission was considering using an average of
different ROE measures to determine the cost of
equity capital for utilities it regulates.
9 R.F. Bruner, K.M. Eades, R.S. Harris, and R.C.
Higgins, 1998 ‘‘Best Practices in Estimating Cost of
Capital: Survey and Synthesis,’’ Financial Practice
and Education, and J.R. Graham, and C.R. Harvey,
2001 ‘‘The Theory and Practice of Corporate
Finance: Evidence from the Field,’’ Journal of
Financial Economics, find that CAPM is the
dominant model for estimating cost of equity. In
addition, most textbook treatments of equity cost of
capital calculations are based on the CAPM model
(for example see www.Damodaran.com).
10 Louis K.C. Chan, Jason Karceski, and Josef
Lakonishok, ‘‘Analysts’’ Conflict of Interest and
Biases in Earnings Forecasts’ March 2003, NBER
Working Paper 9544, find evidence that analysts
manipulate forecasts downward so that firms are
positioned for positive earnings surprises at
announcement dates. Patricia M. Deschow, Amy
Hutton, and Richard Sloan, ‘‘The Relation between
Analysts’’ Forecasts of Long-term Earnings Growth
and Stock Price Performance Following Equity
Offerings’ Contemporary Accounting Research,
Spring 2000, find that analysts’ projections may be
overly optimistic because fees paid to analyst’s
firms are correlated to optimistic projections.
11 J.H. Vander Weide, 2004. Prepared Testimony
for the Pacific Gas and Electric Company Cost of
Capital 2004 and 2005 Submission to the California
Public Utilities Commission.
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estimates and assumptions required to
calculate the ROE.
The Board requests comment on
whether the CAPM methodology is
appropriate to rely on to estimate a
target ROE. What important elements of
the ROE calculation might be excluded
if the Board adopts the CAPM-only
method? Are there considerations that
do not support the use of CAPM to
impute the Reserve Banks’ target ROE?
Is the DCF model used to estimate a
target ROE? What earnings estimates are
the most useful? Are recent published
accounting earnings relevant when
estimating a target ROE? Is the volatility
of the CAPM-only method acceptable?
Should CAPM-only be viewed as a
method to develop an ROE that may be
modified; if so, why and how would one
modify the model?
C. Possible CAPM Methodology
Modifications
Regardless of whether a CAPM-only
method for ROE is adopted, the Board
is considering whether the current
CAPM methodology should be modified
to better reflect comparably positioned
service providers, the aims of the MCA,
and current academic and professional
practice.12 As previously noted, CAPM
requires judgment to determine the
inputs that should be used for each
aspect of model. The Board is
considering modifying the risk-free
investment horizon and the beta
assumptions, including the peer group
used to estimate beta, the beta
estimation period, and the weighting of
the peer group betas in CAPM.
Risk-free investment horizon. The
CAPM risk-free parameter in the Board’s
current method for calculating the target
ROE is based on a one-year Treasury bill
rate. The Treasury security is
considered to be risk-free, and this
short-term rate was chosen to match the
time horizon of the target ROE.13 There
are competing views about whether a
12 As part of the current review, the Board
examined whether economic factors other than the
overall market return significantly affect the stock
returns of the BHC peer group. In the analysis,
alternative multifactor CAPMs that included BHC
payments-related revenue shares and
macroeconomic interest rate spreads were analyzed.
The analysis suggests that the current standard
CAPM and equity betas used to estimate ROE are
reasonable. See ‘‘Alternative Measures of the Cost
of Equity Capital for the Federal Reserve Banks’’
Payments Services: Technical Supplement to the
2004 PSAF Review’’ by Barnes and Lopez (https://
www.federalreserve.gov/boarddocs/press/other/
2005/20050518/supplement.pdf).
13 Although the priced-services ROE is
recomputed each year, the Board considered the
difference between a one-year rate based on the
average of monthly, three-month, or one-year
Treasury bill rate insignificant because Treasury
securities do not have significant pricing anomalies
across short-term maturities.
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short-term or long-term risk-free rate is
more appropriate in the CAPM. One
point of view is that a short-term riskfree rate is consistent with an
underlying tenet of CAPM that suggests
that the market for a security is liquid
and matches the time horizon of a shortterm investor. This approach is
consistent with the yearly price-setting
for Federal Reserve services. Another
point of view advocates using a longterm risk-free rate, such as the ten-year
Treasury bond rate, because it more
closely matches the duration of
investments, the duration of stock
market indexes used to estimate a beta,
and the investment horizon of a longterm investor. It may also be considered
to be more in line with the MCA’s
requirement for the Federal Reserve to
recover all costs of providing its services
over the long run. In this approach, a
target ROE should represent return that
the firm hopes to achieve on average
over the fluctuations of the business
cycle. When considering what risk-free
rate term to use, generally the time
horizon of the investor is matched with
term of the risk-free security. If
investment in the Reserve Banks’
activities is assumed to be long term,
this approach would support using the
yield on a longer-term Treasury
instrument as the risk-free rate in the
CAPM to calculate the Reserve Banks’
priced-services target ROE.
Rates on short-term Treasury bills are
subject to more volatility than longerterm Treasury securities because they
are more sensitive to economic
conditions. Historically, the yields on
short- and long-term Treasury securities
generally move in the same direction,
with long-term securities offering higher
yields, on average, than the yields
provided by short-term securities.
Volatility of the short-term Treasury rate
could produce widely-varying CAPM
ROE estimates and adversely affect the
pricing of the Federal Reserve’s services.
To the extent that the Reserve Banks
adjust prices each year to recover a
fluctuating ROE, a more-stable ROE may
lead to more-stable prices, which is
consistent with the Federal Reserve’s
objective to promote efficient payments
operations.
As mentioned earlier in this notice,
the expected market risk premium
(E(Rm¥Rf)) data are gathered from a
third-party source. This is a widely
accepted and easily accessible source,
and the data are calculated with shortterm risk-free rates, which is standard
practice because investors can buy or
sell securities in the short term. Because
the risk-free rate is used in two parts of
the CAPM equation, however,
inconsistency is introduced in the
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have higher yields. This term premium,
estimated using the historical difference
between short- and long-term Treasury
securities, would be used to adjust a
long-term rate in order to reflect an
average expected short-term risk-free
rate over a ten-year horizon.14 15
Table 3 compares the ROEs that result
from using the one-year versus the tenyear risk free rate in the CAPM
calculation. For illustrative purposes,
the beta is assumed to equal 1.0 to
isolate the effect of using a short- and
longer-term rate on the current
methodology. For 2005, there is a
different of 1.6 percentage points
between the after-tax ROE calculated
when using a short-term risk-free rate
and a long-term free rate adjusted by the
term premium.
The Board requests comment on the
time horizon for estimating a target
ROE. Should the Federal Reserve’s
priced-services target ROE for the
upcoming year be based on a short-term
rate, which might reflect what the
market expects its peers to deliver in the
upcoming year, or should the target ROE
be calculated using a long-term rate,
which might better reflect the return
that the market expects its peers to
deliver, on average, over time? The
Board also requests comment on the
reasonableness of incorporating a tenyear Treasury bond less a term premium
to reflect an expected average short-term
risk-free rate over a ten-year horizon.
What are other factors that could be
used to incorporate a long-term time
horizon?
Beta assumptions. A beta measures
the sensitivity of the peer group returns
to the overall market’s returns. In order
to calculate a beta representative of the
Federal Reserve priced-services
activities, a comparable peer group is
needed. When the peer group is
identified, the most relevant and
appropriate methods to use for the beta
calculation can be determined.
1. Peer Group
priced services, the Board is considering
a peer group that meets all of the
following criteria.
1. The BHCs among the top fifty
publicly traded BHCs based on deposit
balances.
2. The BHCs among the top fifty
publicly traded BHCs based on their
level of due-to balances. By using
deposit and due-to balances, the peer
group would represent publicly traded
entities that provide correspondent
banking services and have several years
of financial data available in the public
domain.17 This selection criteria may
result in a peer group of BHCs that hold
both retail and correspondent deposits
and are more involved in transaction
processing and settlement services.
3. To more closely relate the peer
group members’ capital structure and
risk-weighted asset ratios to the Federal
Reserve’s priced-services imputed
capital structure, the Board is
considering further refining the
selection process by choosing BHCs that
have a ratio of Tier 1 capital to riskweighted assets similar to Reserve Bank
14 As reported in the H.15 Historical Releases
report published by the Board of Governors. The
H.15 provides the constant maturity yield
(annualized) for various term Treasury securities on
a monthly basis.
15 The term premium is estimated at 1.34 percent,
which is the arithmetic average of the difference
between the ten-year Treasury bond yield and the
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Although BHCs’ activities are not a
perfect proxy for Reserve Bank pricedservices activity, they provide similar
services through their correspondent
banking activities, including payment
and settlement services. They also hold
respondent (‘‘due-to’’) balances, which
are similar to depository institution
balances held by Reserve Banks, and
have publicly available information;
therefore, they are the most reasonable
alternative.16 One drawback to using
BHCs as the proxy is that they offer
diverse services with different risk
profiles that reach well beyond the
payment services that are provided by
the Reserve Banks, such as consumer
and corporate lending and investment
services. To reduce the effect on the
ROE of these noncomparable services in
which BHCs are involved, the Board is
also considering looking at the level of
a BHC’s involvement in correspondent
banking activity, its capital structure,
and its solvency ratings in refining the
BHC peer group to better match the
Federal Reserve priced-services
activities.
To choose peers whose activities are
more comparable to the Federal Reserve
one-month Treasury bill yield from 1959–2003
based on data from the Federal Reserve Board H.15
statistical release and Ibbotson Associates.
16 BHC due-to balances are bank deposits
reported on the books of the individual institutions
that make up the BHC, which originate from other
banks and represent respondent balances held to
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provide transaction processing and settlement
services.
17 Choosing BHCs that have been traded for five
years allows the Federal Reserve to use BHC market
returns in the other models used to determine a
target ROE. The number of years in the selection
criteria would change if more or fewer market data
observations were needed.
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EN23MY05.004
equation when a long-term investment
horizon is combined with the short-term
expected market risk premium from the
third-party source. To maintain
consistency, the constant maturity yield
on the ten-year Treasury bond, less a
term premium, could be used as an
estimate of the risk-free rate (Rf).
Empirical analyses show that, on
average, longer-term Treasury securities
Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
peer group is narrowed to seventeen of
the twenty institutions that resulted
from the cross-matching of deposit and
due-to balances.21
Although the cross-matched peer
group is smaller than the top fifty BHC
peer group by deposit balance, the
majority of the top fifty BHCs by deposit
and due-to balances is accounted for in
the cross-matched peer group. For
example, the cross-matched peer group
consists of 67 percent of the deposits of
the top fifty BHCs by deposit and 59
percent of the due-to balances of the top
fifty BHCs by due-to balance.
The Board requests comment on this
modified approach to selecting a peer
group, and in particular on the
following questions. What factors
should be considered when determining
the Federal Reserve’s priced-services
peer group? Is selecting a peer group
based on deposit balances, due-to
balances, or a combination of both an
appropriate peer group selection
criterion? Is there other criteria the
Board should consider? Do the Tier 1
capital-to-risk-weighted assets ratio and
solvency rating filters improve the
selection method?
18 The Tier 1 capital to risk-weighted assets ratio
for the 2005 PSAF was 10.8 percent. Choosing a
BHC within +/¥20 percent of the capital to riskweighted asset ratio (8.6 percent to 13.0 percent for
the 2005 PSAF) would capture a reasonable number
of BHCs with similar capital structures and riskweighted assets.
19 The PSAF calculation uses data from audited
financial statements of the peer group. The data
used for the 2005 PSAF calculation is based on
year-end 2003 data because this is the most recent
publicly available information at the time of the
calculation.
20 Due-to balance data are available only at the
bank level and must be aggregated to get to the BHC
level.
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2. Beta Estimation Period
In the current method, the beta is
estimated from a rolling ten-year period
of monthly stock returns for each BHC
in the peer group. Different sample
periods result in different betas, with a
longer period producing a beta that is
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less sensitive to unusual market
variations and a shorter period having
an opposite effect. The rolling ten-year
period was adopted because it provides
a sufficient number of market
observations to mitigate the effect of
market variations on the calculation.
The Board is considering calculating
the beta using monthly returns from the
market over a rolling five-year period
rather than a rolling ten-year period.
Some financial sources suggest that
using more years of historical data to
calculate the beta may be less relevant
to the firm’s future returns than fewer
years would be, because the nature of
business risks undertaken by firms may
have changed significantly over tenyears. The shorter period is less likely
to distort ROE results because it
excludes some past structural changes
in the banking industry and in the
financial markets that no longer reflect
current BHC peer group risk profiles. In
addition, a five-year data period could
provide a reasonable number of
observations to estimate the peer group
beta. Table 4 compares the 2005 CAPM
ROEs of the current peer group to the
CAPM ROEs of the cross-matched peer
group using a long-term risk-free rate
less a term premium.22 Using the fiveyear rolling period results in a lower
ROE for both peer groups because the
peer group BHCs’ returns compared to
the market’s returns have been less
volatile over the five-year period than
over the ten-year period.
21 Of the top twenty-five institutions based on
due-to balances, three are not publicly traded and
five do not have a Tier 1 capital to risk-weighted
asset ratios similar to Reserve Bank priced services.
22 For ease in illustration, only the cross-matched
peer group of due-to/deposit balances will be
compared to the current peer group throughout the
remainder of this notice.
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EN23MY05.005
priced-services activities (plus or minus
20 percent).18
4. To create a peer group that has a
solvency rating similar to that of the
Federal Reserve’s priced-services
activities if the Federal Reserve were a
private firm, the peer group could be
further narrowed by including only the
BHCs that have an investment-grade
solvency rating.
Attachment I shows the resulting peer
group (cross-matched peer group) of
twenty BHCs that results from these
selection criteria using publicly
available data as of December 2003.19 To
minimize the complexity involved in
capturing the due-to balances for the
peer group, the Board is considering
assuming that the largest three hundred
BHCs by deposit balance includes the
top fifty BHCs by due-to balance.20
An alternative the Board is also
considering could eliminate deposit
balances as a selection criterion and use
the three remaining criteria to select a
peer group, while limiting to twentyfive the number of institutions to which
it would be applied. Choosing the peer
group by the largest due-to balances and
not considering their level of deposit
balance may result in a peer group that
is more focused only on correspondent
banking activities. When the peer group
is composed of the top twenty-five
institutions based on their level of dueto balances that also meet the Tier 1
capital to risk-weighted assets ratio and
solvency rating filtering criteria, the
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3. Weighting of the Peer Group Betas
In the current method to determine
the priced-services beta in CAPM, the
returns of each BHC in the peer group
are market-value weighted and are
compared with the overall market
returns. In effect, value weighting
assumes that a firm’s payments business
is proportional to its market
capitalization level. As BHCs become
The Board requests comment on what
weighting method is appropriate to best
capture the business risk of a peer
group. Is equal-weighting or valueweighting the returns of each BHC in
the peer group preferable when
estimating beta? Should an alternative
weighting process, such as by deposit or
due-to balances, be used? What are the
strengths and weaknesses of each
weighting method?
4. Beta of 1.0
Historical betas use past returns of a
firm and the market to estimate the
firm’s beta for the future. Historical
betas, however, may not be a good
predictor of the future risk for a firm
because it may be facing different risks
than it did in the past. Finance literature
suggests that betas, as an empirical rule,
move towards 1.0 over time. Assigning
a beta of 1.0 for a firm assumes that the
firm will achieve the same returns as the
market over time, and therefore carries
23 A minor modification to calculate beta
produces slightly different ROE results when
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more involved in nonpayment-related
businesses, however, the extent to
which market capitalization is
representative of a BHC’s payments
activities and its usefulness to weight
the betas is uncertain. Value weighting,
therefore, may not produce an
appropriate beta to serve as the proxy
for the Reserve Banks’ priced-services
activities.
The Board is considering calculating
the priced-services beta using the equalweighted returns of each BHC in the
peer group rather than value-weighted
returns as a better approximation of the
appropriate peer group. Equal-weighted
and value-weighted averages of betas
from 2001 to 2005 for each BHC in the
cross-matched peer group are shown in
attachment II. The difference between
the betas, using equal-weighting or
value-weighting, with the cross-matched
peer group of twenty BHCs, varies. For
2001 and 2005, equal-weighting are .12
and .20 lower than value-weighting,
respectively.
Table 5 compares the ROEs that result
from applying the two different
weighting schemes with the returns for
each peer group using a long-term riskfree rate less a term premium. For the
2005 CAPM after-tax ROE using the
cross-matched peer group, the
difference between equal-weighting and
value-weighting is 2.0 percent.
the same risk as the market in the long
run.
To simplify the beta estimation
process, the Board is considering
assigning the Federal Reserve’s priced
services a beta of 1.0. When using a beta
of 1.0, a peer group is no longer needed
to estimate the target CAPM ROE.
An alternative way to incorporate the
concept that all firm betas will revert to
1.0 is to weight the historical beta and
the beta of 1.0 to determine the firm’s
adjusted beta. For example, financial
literature suggests and financial firm
practice support applying a two-thirds
weight on the historical beta and a onethird weight on the beta of 1.0. The
adjusted beta will reduce volatility and
be a truer measure of risk over the long
run while moving the beta estimate
closer to 1.0.
The Board requests comment on
incorporating the concept that all firm
betas will be 1.0 over time in the pricedservices beta calculation. Is a beta equal
to 1.0 for Federal Reserve priced
services a reasonable simplifying
assumption when computing CAPM?
Are important elements that should be
factored into the CAPM equation
eliminated with this assumption? If an
adjusted beta should be considered,
what is the best method for
implementing it?
In addition, the Board requests
comment on the overall CAPM
methodology changes it is considering.
Are the after-tax and pretax ROE results
of the CAPM-only method reasonable?
In what ways, if any, does this
methodology oversimplify the
calculation? In what ways, if any, is the
methodology overly complex?
comparing the current CAPM calculation, shown in
The Board requests comment on the
beta estimation period. Does a rolling
five-year period or a rolling ten-year
period better capture elements that are
relevant to calculating a meaningful beta
for estimating the Reserve Bank pricedservices ROE?
the first row, with the current 2005 CAPM
calculation shown in table 2.
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D. Effect of Different PSAF
Methodologies
Table 6 shows the effect on the beta
of changes to the CAPM factors being
considered.
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29521
substantially higher betas than the other
BHCs in the peer group, with five-year
averages of 1.5 and 1.2. With the
exception of two midsize-to-small
BHCs, the remaining BHCs in the peer
group all have a five-year average betas
of less than 1.0.24 The two largest BHCs
account for more than 60 percent of the
sample group’s historical beta under
value-weighting, while they make up
just 24 percent of beta under equalweighting.
Combining the peer group historical
betas from table 6 above with the
appropriate interest rate and market
data, the pretax return on equity and the
cost of equity25 for Reserve Bank priced
services in 2005 are shown in table 7:26
24 The five-year average betas less than 1.0 range
from .48–.85.
25 A minor modification to calculate beta
produces slightly different ROE results when
comparing the current CAPM calculation, shown in
the first row, with the current 2005 CAPM
calculation shown in table 2.
26 The estimated ROE is applied to the priced
services 2005 book value equity balance of $808
million to derive the cost of equity shown in the
table.
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beta of 1.0 cause the adjusted beta to be
closer to 1.0.
The change in historical beta between
rows two and three reflects the change
in the rolling beta estimation period
from ten to five years. This change
produces a notable drop in the historical
beta. The reduction in the beta from .98
to .82 demonstrates that the crossmatched peer group has been less
volatile than the market over the last
five years than over the last ten years.
Lines three and four show that the
historical beta for the cross-matched
peer group declines significantly when
moving from value-weighting to equalweighting. The two largest BHCs based
on market capitalization have
EN23MY05.007
As shown in rows one and two, the
reduction in the peer group size from
fifty to twenty BHCs, which results
when applying the filters described in
the peer group section of the notice,
causes the historical beta for the sample
group to rise slightly. The rise in
historical beta is attributable to the
increased weight of the larger BHCs in
the cross-matched peer group because
the smaller BHCs in the current peer
group of fifty dropped out. In general,
the smaller BHCs have lower betas,
which may result, in part, from a greater
reliance on more-traditional and lessrisky core banking activities. The
weighting of the historical beta and the
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Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
In 2005, a 100 basis point change in
the pretax ROE increases or decreases
the imputed costs to priced services by
about $8.1 million. This is
approximately 1.1 percent of pricedservices expenses.27
IV. Broader Issues in the
Implementation of Target ROE
As noted earlier in this notice, the
Board seeks to fully recover the costs of
its priced-services operations, including
the PSAF, over the long run. To limit
unnecessary and potentially disruptive
volatility in its pricing, the Board does
not require priced services to offset
previous years’ overrecoveries or
underrecoveries. Accordingly, a target
ROE for priced services is calculated
each year by the method described in
this notice, and that target is factored
directly into product pricing decisions
for the upcoming budget year.
The Board notes that among some
companies the current practice is to
establish a multiyear ROE target, to be
achieved over a strategic planning
horizon. Budget models may focus on
specific project and business line targets
or on maximizing profit from year to
year. Strategic ROEs could take a longerterm view and consider changes in the
marketplace and technology and how
the firm would respond to them, along
with planned capital investment.
Companies may intentionally set prices
in a way that would result in actual ROE
performance deviating from the target
year to year; however, they expect to
achieve the target on average over the
planning horizon.
The Board would consider adopting a
longer-term view if a case could be
made that it would significantly
improve the efficiency of the payments
systems. Implementing a less
mechanical approach would require the
Board to devise a transparent and
replicable method to adjust the annual
ROE targets built into the Reserve Bank
priced-services’ budget so as to achieve
the long-term objective. The Board seeks
comment on the following questions.
Do firms target a different ROE for
near-term budgeting purposes than for
multiyear, longer-term, strategic
planning? What advantages or
disadvantages are there to the Federal
Reserve setting a PSAF, including the
priced-services ROE, more or less
frequently than annually? What, if any,
are the implications if a longer-term
approach to setting the ROE is adopted?
Under the MCA, the fees the Reserve
Banks charge for priced services are to
be set to fully recover the costs that a
27 System 2005 budgeted priced services expenses
less shipping are $724.8 million.
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private-sector provider would incur in
providing them over the long run. As
the payments system evolves from
paper-based transactions to electronic
forms, the Board will be setting a target
ROE for the Reserve Banks pricedservices activities in the context of
declining volumes for its check service
line. The Board seeks comment on the
following questions.
What are the advantages and
disadvantages to the Board changing its
current practice of setting the target ROE
for priced services at an entity level and
begin developing target ROEs for each
service line? In what way should the
Board adjust the target ROE to consider
the decline in use of paper-based check
products, given that the check service
represents a majority of priced-services
activities?
V. Looking Ahead
While the Board considers the
changes to the current PSAF
methodology discussed above, it
recognizes that the changes under way
in the payments industry and regulatory
practices will, in all likelihood, lead to
the consideration of more changes to the
PSAF model in the longer term.
Historically, the Board considered BHCs
a proxy for the Reserve Bank pricedservices peer group because
correspondent banks are the Reserve
Banks’ primary competitors in
providing check services, which
comprises more than 80 percent of the
cost of Reserve Bank priced-services
activities. Competitors in the electronic
payment services, however, have
typically been market utilities. Market
utilities, such as the Clearing House
Interbank Payment System (CHIPS),
which is the primary competitor for
Fedwire funds transfer services, and the
Electronic Payments Network (EPN),
which is the only private-sector
automated clearinghouse (ACH)
operator, are both member-owned
clearinghouses. As paper check volume
continues to decline and as the check
service increasingly becomes electronic,
market utilities may replace
correspondent banks as the Reserve
Banks’ primary priced-services
competitor.
Similarly, proposals developed by the
Basel Committee on Banking
Supervision (Basel II), once adopted, to
improve capital regulations
internationally, make regulatory capital
more risk sensitive, include an explicit
operational risk capital charge, and
promote enhanced risk-management
practices among large, internationally
active banking organizations may affect
the capital structure of the Reserve
Banks’ priced-services peer group and
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warrant consideration in developing the
PSAF equity costs.
The Board would welcome any
comments on the possible implications
of these and other environmental
changes for the appropriate approach to
calculate the PSAF.
VI. Competitive Impact Analysis
All operational and legal changes
considered by the Board that have a
substantial effect on payments system
participants are subject to the
competitive impact analysis described
in the March 1990 policy statement
‘‘The Federal Reserve in the Payments
System.’’ 28 Under this policy, the Board
assesses whether the change would have
a direct and material adverse effect on
the ability of other service providers to
compete effectively with the Federal
Reserve in providing similar services
because of differing legal powers or
constraints or because of a dominant
market position of the Federal Reserve
deriving from such legal differences. If
the fees or fee structures create such an
effect, the Board must further evaluate
the changes to assess whether their
benefits—such as contributions to
payment system efficiency, payment
system integrity, or other Board
objectives—can be retained while
reducing the hindrances to competition.
Because the PSAF includes costs that
must be recovered through fees for
priced services, changes made to the
method may have an effect on fees. The
Board is considering changes that may
refine the PSAF peer group and ROE
methodology to resemble that of other
service providers as required by the
MCA. Consequently, the fees adopted by
the Reserve Banks should be based on
the cost and profit targets that are
comparable with those of other
providers of services similar to Reserve
Bank priced services. Accordingly, the
Board believes that if it determines to
adopt some or all of these changes, the
changes will not have a direct and
material adverse effect on the ability of
other service providers to compete
effectively, due to legal differences, with
the Federal Reserve in providing similar
services.
VII. Paperwork Reduction Act
In accordance with the Paperwork
Reduction Act of 1995 (44 U.S.C. ch.
3506; 5 CFR Part 1320 Appendix A.1),
the Board has reviewed the proposal
under the authority delegated to the
Board by the Office of Management and
Budget. No collections of information
pursuant to the Paperwork Reduction
Act are contained in the proposal.
28 FRRS
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VIII. Summary of Comments Requested
A. Imputed ROE
The Board requests comment on
alternative methods to calculate the
target ROE.
1. Are there models, other than the
three in use, that the Board should
consider?
2. What is considered to be a
reasonable target ROE for institutions
that provide services similar to those
provided by the Reserve Banks?
The Board requests comments on
whether the CAPM methodology is
appropriate to rely on to estimate a
target ROE.
3. What important elements of the
ROE calculation might be excluded if
the Board adopts the CAPM-only
method?
4. Are there considerations that do not
support the use of CAPM to impute the
Reserve Banks’ target ROE?
5. Is the DCF model used to estimate
a target ROE? What earnings estimates
are the most useful?
6. Are recent published accounting
earnings relevant when estimating a
target ROE?
7. Is the volatility of the CAPM-only
method acceptable?
8. Should CAPM-only be viewed as a
method to develop an ROE that may be
modified; if so, why and how would one
modify the model?
B. CAPM Methodology
Risk-Free Investment Horizon
The Board requests comment on the
time horizon for estimating a target
ROE.
1. Should the Federal Reserve’s
priced-services target ROE for the
upcoming year be based on a short-term
rate, which might reflect what the
market expects its peers to deliver in the
upcoming year, or should the target ROE
be calculated using a long-term rate,
which might better reflect the return
that the market expects its peers to
deliver, on average, over time?
2. Is it reasonable for the Board to
incorporate a ten-year Treasury bond
less a term premium to reflect an
expected average short-term risk-free
rate over a ten-year horizon?
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3. What are other factors that could be
used to incorporate a long-term time
horizon?
Peer Group
The Board requests comment on the
modified approach to selecting a peer
group, and in particular on the
following questions.
4. What factors should be considered
when determining the Federal Reserve’s
priced-services peer group?
5. Is selecting a peer group based on
deposit balances, due-to balances, or a
combination of both an appropriate peer
group selection criterion?
6. Is there other criteria the Board
should consider?
7. Do the Tier 1 capital-to-riskweighted assets ratio and solvency
ratings filters improve the selection
method?
29523
equation eliminated with this
assumption?
14. If an adjusted beta should be
considered, what is the best method for
implementing it?
In addition, the Board requests
comment on the overall CAPM
methodology changes it is considering.
15. Are the after-tax and pretax ROE
results of the CAPM-only method
reasonable?
16. In what ways, if any, does this
methodology oversimplify the
calculation?
17. In what ways, if any, is the
methodology overly complex?
C. Broader Issues in the Implementation
of the Target ROE
The Board requests comment on what
weighting method is appropriate to best
capture the business risk of a peer
group.
9. Is equal-weighting or valueweighting the returns of each BHC in
the peer group preferable when
estimating beta?
10. Should an alternative weighting
process, such as by deposit or due-to
balances, be used?
11. What are the strengths and
weaknesses of each weighting method?
The Board seeks comment on the
following questions.
1. Do firms target a different ROE for
near-term budgeting purposes than for
multiyear, longer-term, strategic
planning?
2. What advantages or disadvantages
are there to the Federal Reserve setting
a PSAF, including the priced-services
ROE, more or less frequently than
annually?
3. What, if any, are the implications
if a longer-term approach to setting the
ROE is adopted?
4. What are the advantages and
disadvantages to the Board changing its
current practice of setting the target ROE
for priced services at an entity level and
begin developing target ROEs for each
service line?
5. In what way should the Board
adjust the target ROE to consider the
decline in use of paper-based check
products, given that the check service
represents a majority of priced-services
activities?
Beta of 1.0
D. Looking Ahead
The Board requests comment on
incorporating the concept that all firm
betas will be 1.0 over time in the pricedservices beta calculation.
12. Is a beta equal to 1.0 for Federal
Reserve priced services a reasonable
simplifying assumption when
computing CAPM?
13. Are important elements that
should be factored into the CAPM
The Board requests comment on the
possible implications that payment
industry and regulatory changes may
have on the approach to calculate PSAF.
Beta Estimation Period
The Board requests comment on the
beta estimation period.
8. Does a rolling five-year period or a
rolling ten-year period better capture
elements that are relevant to calculating
a meaningful beta for estimating the
Reserve Bank priced-services ROE?
Weighting of the Peer Group Betas
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By order of the Board of Governors of the
Federal Reserve System, May 17, 2005.
Jennifer J. Johnson,
Secretary of the Board.
BILLING CODE 6210–01–P
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29524
29 Differences in calculation timing result in
slightly different value- and equal-weighted betas
than shown in Attachment III.
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Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
29526
Federal Register / Vol. 70, No. 98 / Monday, May 23, 2005 / Notices
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
BILLING CODE 6210–01–C
30 A minor modification to claculate beta
produces slightly different ROE results when
comparing the current CAPM calculation, shown in
the first row, with the current 2005 CAPM
calculation shown in table 2.
VerDate jul<14>2003
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Meeting of the Presidential Advisory
Council on HIV/AIDS
Department of Health and
Human Services, Office of the Secretary.
AGENCY:
PO 00000
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ACTION:
Notice.
SUMMARY: As stipulated by the Federal
Advisory Committee Act, the
Department of Health and Human
Services (DHHS) is hereby giving notice
that the Presidential Advisory Council
on HIV/AIDS (PACHA) will hold a
E:\FR\FM\23MYN1.SGM
23MYN1
EN23MY05.011
[FR Doc. 05–10168 Filed 5–20–05; 8:45 am]
Agencies
[Federal Register Volume 70, Number 98 (Monday, May 23, 2005)]
[Notices]
[Pages 29512-29526]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 05-10168]
-----------------------------------------------------------------------
FEDERAL RESERVE SYSTEM
[Docket No. OP-1229]
Federal Reserve Bank Services Private Sector Adjustment Factor
AGENCY: Board of Governors of the Federal Reserve System.
ACTION: Notice with request for comments.
-----------------------------------------------------------------------
SUMMARY: The Board requests comment on potential modifications to the
method for calculating the target return on equity (ROE) in the
private-sector adjustment factor (PSAF). The PSAF imputes the costs
that would have been incurred and profits that would have been earned
had the Federal Reserve Banks' priced services been provided by a
private firm. The Monetary Control Act of 1980 (MCA) requires that the
Federal Reserve set fees for its services to recover, over the long
run, its actual costs of providing the services, as well as the imputed
costs and profits. The Board reviews its method for calculating the
PSAF periodically to assess whether it is still appropriate in light of
the changing business and regulatory environment, industry practices,
and accounting standards.
Specifically, the Board requests comment on possible changes to the
current method to compute a target rate of return on equity capital,
including changes to the analytical models and peer group institutions
used. The Board's method for setting its overall level of equity
capital would continue to be based on the Federal Deposit Insurance
Corporation (FDIC) guidelines for a well-capitalized institution for
insurance premium purposes.
DATES: Comments must be submitted on or before July 22, 2005.
ADDRESSES: You may submit comments, identified by Docket No. OP-1229,
by any of the following methods:
Agency Web Site: https://www.federalreserve.gov. Follow the
instructions for submitting comments at https://www.federalreserve.gov/
generalinfo/foia/ProposedRegs.cfm.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments.
E-mail: regs.comments@federalreserve.gov
FAX: 202/452-3819 or 202/452-3102.
Mail: Jennifer J. Johnson, Secretary, Board of Governors
of the Federal Reserve System, 20th Street and Constitution Avenue,
NW., Washington, DC 20551.
All public comments are available from the Board's Web site at
https://www.federalreserve.gov/generalinfo/foia/ProposedRegs.cfm as
submitted, except as necessary for technical reasons. Accordingly, your
comments
[[Page 29513]]
will not be edited to remove any identifying or contact information.
Public comments may also be viewed electronically or on paper in Room
MP-500 of the Board's Martin Building (20th and C Streets, NW) between
9 a.m. and 5 p.m. on weekdays.
FOR FUTHER INFORMATION CONTACT: Gregory L. Evans, Assistant Director
(202/452-3945), Brenda L. Richards, Financial Project Leader (202/452-
2753), or Jonathan Mueller, Financial Analyst (202/530-6291); Division
of Reserve Bank Operations and Payment Systems. Telecommunications
Device for the Deaf (TDD) users may contact 202/263-4869.
SUPPLEMENTARY INFORMATION:
I. Background
The MCA requires that the Board establish fees for ``priced
services'' provided to depository institutions at a level necessary to
recover all direct and indirect costs actually incurred and imputed
costs. Imputed costs include financing costs, return on equity capital
(profit), taxes, and certain other expenses that would be incurred if a
private business firm provided the services. The imputed costs and
imputed profit are collectively referred to as the private sector
adjustment factor (PSAF). In establishing fees, the Board considers the
objectives of fostering competition, improving the efficiency of the
payments mechanism, and providing an adequate level of services
nationwide.
The methodology underlying the PSAF is reviewed periodically to
ensure that it is appropriate and relevant in light of changes that may
have occurred in Reserve Bank priced-services activities, accounting
standards, finance theory, and regulatory and business practices.\1\
The Board considers four principles when reviewing the PSAF
methodology: (1) Providing a conceptually sound basis for efficient
pricing in the market for payments services, (2) maintaining
consistency with actual Reserve Bank financial information and
practice, (3) maintaining consistency with private-sector practice, and
(4) using data in the public domain in order to make the PSAF
replicable. In addition, the Board seeks to balance the cost,
complexity, and accuracy of the PSAF methodology in implementing
theoretically sound approaches.\2\
---------------------------------------------------------------------------
\1\ During the development of this proposal, the Federal Reserve
worked with a consulting firm specializing in capital allocation and
risk management and four finance professors from U.S. academic
institutions to obtain information about current private-sector
practices.
\2\ The previous review of the PSAF was completed in 2001 (65 FR
82360, October 10, 2001) and changes were implemented for the 2002
PSAF.
---------------------------------------------------------------------------
The Board seeks to establish fees for priced services to recover
projected costs and the PSAF over the long run. Because the Board does
not believe that price volatility increases efficiency in payment
systems, it has been wary of cost-recovery models that produce volatile
results from year to year. For this reason, fees for each year are not
set to offset any previous or subsequent years' overrecovery or
underrecovery. Moreover, other providers of payment services do not
typically establish prices in order to eliminate surpluses or
shortfalls incurred in previous years. A highly volatile PSAF applied
mechanically to the fee-setting process could also result in
unnecessarily volatile prices, which, in turn, could adversely affect
the efficient operations of the Reserve Banks and other payment service
providers. As a result, the Board has preferred, when appropriate, to
adopt PSAF methods that provide for stable rather than volatile
returns.
II. Private Sector Adjustment Factor
The current method for calculating the PSAF includes determining
the book value of Federal Reserve assets and liabilities to be used in
providing priced services during the coming year, and the rates used to
impute financing costs. The Board's method involves developing an
estimated Federal Reserve priced-services pro forma balance sheet using
actual priced-services assets and liabilities. The remaining elements
on the balance sheet, such as equity, are imputed as if these services
were provided by a private-sector firm. To satisfy the FDIC requirement
for a well-capitalized institution, equity is imputed at 5 percent of
total assets.\3\ In 2005, assets are projected to total $16.2 billion,
resulting in imputed equity capital of $808 million.
---------------------------------------------------------------------------
\3\ Equity is imputed based on the FDIC definition of a ``well-
capitalized'' institution for insurance premium purposes. The FDIC
requirements for a well-capitalized financial institution are (1) a
ratio of total capital to risk-weighted assets of 10 percent or
greater; and (2) a ratio of Tier 1 capital to risk-weighted assets
of 6 percent or greater; and (3) a leverage ratio of Tier 1 capital
to total assets of 5 percent or greater. The Federal Reserve priced-
services balance sheet total capital has no components of Tier 1 or
total capital other than equity; therefore, requirements 1 and 2 are
essentially the same measurement. Because risk-weighted assets are
considerably below actual assets, only requirement 3 is binding for
the Federal Reserve priced services.
---------------------------------------------------------------------------
A target ROE is estimated and applied to the equity capital on the
pro forma balance sheet to determine the priced-services cost of
equity.\4\ Currently, the ROE is calculated by averaging the results of
three analytical models: The comparable accounting earnings (CAE)
model, the discounted cash flow (DCF) model, and the capital asset
pricing model (CAPM). The top fifty bank holding companies (BHCs) based
on deposit balance serve as the peer group for Federal Reserve priced
services and the peer group's financial data is used to estimate the
target ROE. Selecting the BHCs based on deposit balances was intended
to maintain the focus on the largest banking entities because they
process transactions and perform settlement services comparable to
those provided by the Reserve Banks.
---------------------------------------------------------------------------
\4\ For the 2005 PSAF, the target ROE of 18.1 percent is
multiplied by the equity capital of $808 million to get the priced
services cost of equity of $146 million.
---------------------------------------------------------------------------
The CAE model uses historical BHC accounting information to
estimate ROE. The ROE for an individual BHC in the peer group is
calculated as the ratio of the firm's net income before taxes to its
book value of equity and is averaged with other BHCs to determine the
peer group ROE. The DCF model takes a forward-looking approach to
estimating ROE. It assumes that a firm's stock price is equal to the
discounted present value of all expected future dividends. The CAPM
captures the risk--return relationship that rational investors require
in efficient markets. The underlying theory of the model assumes that
investors demand a premium for bearing risk; that is, the higher the
risk of the security, the higher its expected return must be to attract
investors to buy it. The basic principle of CAPM is that the required
rate of return on a firm's equity is equal to the return on a risk-free
asset plus a risk premium.
The PSAF also includes imputed taxes, which are captured using a
pretax ROE. A pretax ROE assumes that a 100 percent recovery of
expenses, including the targeted ROE, is achieved. The PSAF tax rate is
the median of the rates paid by the fifty BHCs in the peer group over
the past five years. Finally, the PSAF includes the estimated share of
the Board of Governors' expenses that supports priced services, imputed
sales tax, and an imputed assessment for FDIC insurance.
III. Discussion
A. Overview
The Board is considering changes to the methodology used to
estimate the target ROE for priced services. The table below summarizes
the current methodology and the changes
[[Page 29514]]
considered, which are discussed in more depth in subsequent sections of
the notice.
[GRAPHIC] [TIFF OMITTED] TN23MY05.000
B. Imputed Return on Equity
The target ROE for Reserve Bank priced-services activities is
established at the entity level rather than by developing an ROE for
each service. Conceptually, the ROE is developed with a shareholder's
perspective in mind and considers whether shareholders are adequately
compensated in the form of average equity returns given the overall
risk of the business activities.
Current Three-Model Approach. As discussed earlier, the Board
targets an ROE using the average of the results of the CAE, DCF, and
CAPM models. The three economic models use different inputs and provide
different outlooks when determining a unique target ROE.
1. Comparable Accounting Earnings Model
The CAE model's sole source of data is peer group historical
accounting information. The annual ratios of net income before taxes to
equity of the individual BHCs are averaged to determine the peer group
ROE. The arithmetic average of the last five years' individual ROEs is
the CAE ROE.
This model is appealing because it is directly related to the
published financial statements of BHCs. Because the priced-services ROE
is applied to the book value of equity, the CAE is also the only model
that is consistent with the pro forma presentation that is used to
measure cost recovery and compliance with the MCA. The CAE model's
primary shortcomings are that it relies exclusively on historical data
reported on a book value basis to project an expected market rate of
return and does not incorporate future earnings expectations. The ROE
results for any point are substantially anchored in past accounting
book values, and book values can be less relevant to investors than
market-based measures of a firm's financial condition. The CAE results
can be particularly unrealistic during periods when there are large
fluctuations in business cycles. These shortcomings were identified
when the three-model approach was adopted in 2001; however, the Board
believed the CAE results complemented the market-driven results of the
DCF and CAPM models when the results of all three models were averaged.
2. Discounted Cash Flow Model
The DCF approach requires as inputs the BHC peer group stock prices
as well as forecasts of future dividends and long-term dividend growth
rates.\5\ The implied discount rate of a firm can be calculated and
considered the firm's estimated ROE in the DCF model if the stock price
and expected future dividends are known. The ROEs for individual BHCs
are combined using a
[[Page 29515]]
weighted average based on each BHC's equity market capitalization. The
formula for the DCF model is
---------------------------------------------------------------------------
\5\ Consensus earnings forecasts and long-term growth rates (as
published by the Institutional Brokers Estimate System) are
translated into future dividend cash flows.
[GRAPHIC] [TIFF OMITTED] TN23MY05.001
The DCF model was adopted for the ROE calculation because it
incorporates projections of future shareholder market returns, which
are not reflected in the CAE or CAPM models. The DCF model can be a
powerful valuation tool; however, meaningful results depend on
analysts' ability to project cash flow and dividend growth rates
accurately. Financial market history has shown the inherent difficulty
faced by analysts in developing accurate financial projections given
the rapid shifts in business activities as a result of increased
competition, changes in the regulatory environment, technological
obsolescence, and other forces.
3. Capital Asset Pricing Model
CAPM's basic principle is that the required rate of return on a
firm's equity is equal to the return on a risk-free asset plus a risk
premium. The risk premium is a measurement of the expected excess
return on a market portfolio of equities (the expected market risk
premium) and the correlation of the firm's returns to the market
returns (beta).
[GRAPHIC] [TIFF OMITTED] TN23MY05.002
The CAPM requires judgment in determining
The risk-free interest rate or the rate of return on an
investment with no or low risk, typically measured using a Treasury
rate.
The method, data, and period used for estimating the beta.
The beta measures the market risk of a particular company relative to
the risk of the overall market. A beta of 1.0 signifies that a firm's
returns will be perfectly correlated with the market and move up or
down with the market's return (dividends and capital gains and losses).
A beta of less than 1.0 indicates that a firm's returns fluctuate less
than the market (less risky); while a beta greater than 1.0 indicates
that a firm's returns tend to vary more than the market (more risky).
The market risk premium, which estimates the additional
return investors require to forgo the safety of investing in no or low-
risk assets to bear the higher risk of common stock.
The CAPM provides a framework to determine the risk-return
relationship required by investors. Because CAPM measures the relevant
market risk of a firm's stock and the contribution of the firm's stock
to the market risk of a well-diversified portfolio, CAPM can be applied
to many business decisions. For example, investors, who are concerned
with market risk when holding diversified portfolios, can use CAPM to
make portfolio management decisions and balance the risk-return
tradeoff. Business managers, who are concerned with maximizing the
return to shareholders, can also use CAPM to make financing decisions
because CAPM produces the required rate of return expected by the
market. As a practical matter, not all financial models, including
CAPM, will necessarily produce accurate estimates unless the
decisionmaker exercises some judgment to adjust for risks that
[[Page 29516]]
the models do not measure. In addition, CAPM can produce varying
results that may not accurately predict future performance, depending
on the formula inputs. Nevertheless, CAPM is a useful conceptual tool
because it represents the way rational people would behave when
managing risk and making financing decisions.
Because the results of the CAPM are sensitive to the inputs, they
are critical to the model's usefulness. The risk-free rate is a
significant factor because it both is used to determine the market risk
premium and also is added to the risk premium of the peer group in the
CAPM calculation. Currently, the Board uses the constant maturity yield
on the one-year Treasury bill as the risk-free rate. The monthly stock
returns over a rolling ten-year period are used in a linear regression
technique to estimate the peer group beta.\6\ To capture each BHC's
involvement in similar service activities, the returns of each BHC in
the peer group are weighted by market capitalization. The market risk
premium is estimated using the monthly excess return of the market over
the risk-free rate since 1927, which is standard finance practice.\7\
---------------------------------------------------------------------------
\6\ Linear regression uses variables, such as the BHCs' equity
returns and the market's return, and estimates a relationship
between them in the form of a straight-line.
\7\ The market risk premium data are found on the Kenneth R.
French website (https://mba.tuck.dartmouth.edu/pages/faculty/
ken.french). Stock return data are obtained from the Center for
Research in Security Prices.
---------------------------------------------------------------------------
4. Results of the Current Three-Model Approach
The following table shows Reserve Bank priced services pretax and
after-tax ROE targets from 2001 to 2005 using each of the three models.
Table 2 highlights the CAPM's sensitivity to interest rates, which has
made it much more variable from year to year than the other two models.
As rates fell from 2001 to 2005, the CAPM produced an ROE that is much
lower than the ROEs produced by the CAE or DCF models. Conversely,
during periods of higher interest rates such as the 1980s, the CAPM
produced higher ROE results than the CAE or DCF. Over the eighteen-year
period of 1983-2000, the average ROE of the CAPM was the highest of all
three models at 15.1 percent, followed by the CAE at 11.4 percent and
the DCF at 13.0 percent.
[GRAPHIC] [TIFF OMITTED] TN23MY05.003
The three models for calculating the target ROE are based on
different assumptions, analytical approaches, and data sources. Because
each of the three models brings a different perspective to a firm's
cost of equity capital, the Board concluded that a simple average of
the three was a better measure of the peer group's ROE than any single
model by itself. Support for this approach was found in academic
studies that demonstrated that the use of multiple models can improve
estimation techniques when each model provides new information. Taking
the average of the three models was seen as a way to minimize the
effect of unusual data and provide a less-volatile ROE over time. In
recent years, however, academic, market, and financial services
industry practices have evolved, and the weaknesses of the CAE and DCF
have become more widely recognized. As a result, reliance on the CAE
and DCF for targeting a firm's ROE has declined.
The Board requests comment on alternative methods to calculate the
target ROE. Are there models, other than the three in use, that the
Board should consider? What is considered to be a reasonable target ROE
for institutions that provide services similar to those provided by the
Reserve Banks?
Possible change to the imputed ROE methodology. To implement the
principle of maintaining consistency with private-sector practice, the
Board reviewed current finance theory and practice to determine whether
the current PSAF methodology, and in particular the three-model
approach, is the most appropriate method for
[[Page 29517]]
computing the ROE. When the Board adopted the current three-model
approach, there was evidence that multiple models were being used by
academics and professionals to estimate ROE.\8\ Current information
suggests, however, that CAPM has continued to evolve and is used more
in practice than the CAE and DCF methods.\9\ Specifically, the CAE
method, while not widely used at the time of the last study, has
continued to wane in use. Similarly, the effectiveness of the DCF as a
tool for estimating ROE has also been questioned based on recent
research findings that analysts' dividend projections can be upwardly
or downwardly biased.\10\ Although some public utilities still use the
results of the DCF model together with CAPM for developing ROE targets,
it is not used by many larger financial institutions.\11\ With
information suggesting that two of the three models that are used in
the current ROE method might not be in line with common practice, the
Board is considering discontinuing using the average of the results of
three models and use CAPM only to calculate the target ROE. While CAPM
has the virtue of being a forward-looking, market-based measure of ROE
that incorporates the fundamental risk'return relationships required by
rational investors and is the most widely accepted and used model for
calculating ROE, it also continues to be the most volatile of the
methods, as shown in table 2. The volatility comes from the estimates
and assumptions required to calculate the ROE.
---------------------------------------------------------------------------
\8\ For example, when the current method was adopted, the New
York State Public Service Commission was considering using an
average of different ROE measures to determine the cost of equity
capital for utilities it regulates.
\9\ R.F. Bruner, K.M. Eades, R.S. Harris, and R.C. Higgins, 1998
``Best Practices in Estimating Cost of Capital: Survey and
Synthesis,'' Financial Practice and Education, and J.R. Graham, and
C.R. Harvey, 2001 ``The Theory and Practice of Corporate Finance:
Evidence from the Field,'' Journal of Financial Economics, find that
CAPM is the dominant model for estimating cost of equity. In
addition, most textbook treatments of equity cost of capital
calculations are based on the CAPM model (for example see
www.Damodaran.com).
\10\ Louis K.C. Chan, Jason Karceski, and Josef Lakonishok,
``Analysts'' Conflict of Interest and Biases in Earnings Forecasts'
March 2003, NBER Working Paper 9544, find evidence that analysts
manipulate forecasts downward so that firms are positioned for
positive earnings surprises at announcement dates. Patricia M.
Deschow, Amy Hutton, and Richard Sloan, ``The Relation between
Analysts'' Forecasts of Long-term Earnings Growth and Stock Price
Performance Following Equity Offerings' Contemporary Accounting
Research, Spring 2000, find that analysts' projections may be overly
optimistic because fees paid to analyst's firms are correlated to
optimistic projections.
\11\ J.H. Vander Weide, 2004. Prepared Testimony for the Pacific
Gas and Electric Company Cost of Capital 2004 and 2005 Submission to
the California Public Utilities Commission.
---------------------------------------------------------------------------
The Board requests comment on whether the CAPM methodology is
appropriate to rely on to estimate a target ROE. What important
elements of the ROE calculation might be excluded if the Board adopts
the CAPM-only method? Are there considerations that do not support the
use of CAPM to impute the Reserve Banks' target ROE? Is the DCF model
used to estimate a target ROE? What earnings estimates are the most
useful? Are recent published accounting earnings relevant when
estimating a target ROE? Is the volatility of the CAPM-only method
acceptable? Should CAPM-only be viewed as a method to develop an ROE
that may be modified; if so, why and how would one modify the model?
C. Possible CAPM Methodology Modifications
Regardless of whether a CAPM-only method for ROE is adopted, the
Board is considering whether the current CAPM methodology should be
modified to better reflect comparably positioned service providers, the
aims of the MCA, and current academic and professional practice.\12\ As
previously noted, CAPM requires judgment to determine the inputs that
should be used for each aspect of model. The Board is considering
modifying the risk-free investment horizon and the beta assumptions,
including the peer group used to estimate beta, the beta estimation
period, and the weighting of the peer group betas in CAPM.
---------------------------------------------------------------------------
\12\ As part of the current review, the Board examined whether
economic factors other than the overall market return significantly
affect the stock returns of the BHC peer group. In the analysis,
alternative multifactor CAPMs that included BHC payments-related
revenue shares and macroeconomic interest rate spreads were
analyzed. The analysis suggests that the current standard CAPM and
equity betas used to estimate ROE are reasonable. See ``Alternative
Measures of the Cost of Equity Capital for the Federal Reserve
Banks'' Payments Services: Technical Supplement to the 2004 PSAF
Review'' by Barnes and Lopez (https://www.federalreserve.gov/
boarddocs/press/other/2005/20050518/supplement.pdf).
---------------------------------------------------------------------------
Risk-free investment horizon. The CAPM risk-free parameter in the
Board's current method for calculating the target ROE is based on a
one-year Treasury bill rate. The Treasury security is considered to be
risk-free, and this short-term rate was chosen to match the time
horizon of the target ROE.\13\ There are competing views about whether
a short-term or long-term risk-free rate is more appropriate in the
CAPM. One point of view is that a short-term risk-free rate is
consistent with an underlying tenet of CAPM that suggests that the
market for a security is liquid and matches the time horizon of a
short-term investor. This approach is consistent with the yearly price-
setting for Federal Reserve services. Another point of view advocates
using a long-term risk-free rate, such as the ten-year Treasury bond
rate, because it more closely matches the duration of investments, the
duration of stock market indexes used to estimate a beta, and the
investment horizon of a long-term investor. It may also be considered
to be more in line with the MCA's requirement for the Federal Reserve
to recover all costs of providing its services over the long run. In
this approach, a target ROE should represent return that the firm hopes
to achieve on average over the fluctuations of the business cycle. When
considering what risk-free rate term to use, generally the time horizon
of the investor is matched with term of the risk-free security. If
investment in the Reserve Banks' activities is assumed to be long term,
this approach would support using the yield on a longer-term Treasury
instrument as the risk-free rate in the CAPM to calculate the Reserve
Banks' priced-services target ROE.
---------------------------------------------------------------------------
\13\ Although the priced-services ROE is recomputed each year,
the Board considered the difference between a one-year rate based on
the average of monthly, three-month, or one-year Treasury bill rate
insignificant because Treasury securities do not have significant
pricing anomalies across short-term maturities.
---------------------------------------------------------------------------
Rates on short-term Treasury bills are subject to more volatility
than longer-term Treasury securities because they are more sensitive to
economic conditions. Historically, the yields on short- and long-term
Treasury securities generally move in the same direction, with long-
term securities offering higher yields, on average, than the yields
provided by short-term securities. Volatility of the short-term
Treasury rate could produce widely-varying CAPM ROE estimates and
adversely affect the pricing of the Federal Reserve's services. To the
extent that the Reserve Banks adjust prices each year to recover a
fluctuating ROE, a more-stable ROE may lead to more-stable prices,
which is consistent with the Federal Reserve's objective to promote
efficient payments operations.
As mentioned earlier in this notice, the expected market risk
premium (E(Rm-Rf)) data are gathered from a third-party source. This is
a widely accepted and easily accessible source, and the data are
calculated with short-term risk-free rates, which is standard practice
because investors can buy or sell securities in the short term. Because
the risk-free rate is used in two parts of the CAPM equation, however,
inconsistency is introduced in the
[[Page 29518]]
equation when a long-term investment horizon is combined with the
short-term expected market risk premium from the third-party source. To
maintain consistency, the constant maturity yield on the ten-year
Treasury bond, less a term premium, could be used as an estimate of the
risk-free rate (Rf). Empirical analyses show that, on average, longer-
term Treasury securities have higher yields. This term premium,
estimated using the historical difference between short- and long-term
Treasury securities, would be used to adjust a long-term rate in order
to reflect an average expected short-term risk-free rate over a ten-
year horizon.\14\ \15\
---------------------------------------------------------------------------
\14\ As reported in the H.15 Historical Releases report
published by the Board of Governors. The H.15 provides the constant
maturity yield (annualized) for various term Treasury securities on
a monthly basis.
\15\ The term premium is estimated at 1.34 percent, which is the
arithmetic average of the difference between the ten-year Treasury
bond yield and the one-month Treasury bill yield from 1959-2003
based on data from the Federal Reserve Board H.15 statistical
release and Ibbotson Associates.
---------------------------------------------------------------------------
Table 3 compares the ROEs that result from using the one-year
versus the ten-year risk free rate in the CAPM calculation. For
illustrative purposes, the beta is assumed to equal 1.0 to isolate the
effect of using a short- and longer-term rate on the current
methodology. For 2005, there is a different of 1.6 percentage points
between the after-tax ROE calculated when using a short-term risk-free
rate and a long-term free rate adjusted by the term premium.
[GRAPHIC] [TIFF OMITTED] TN23MY05.004
The Board requests comment on the time horizon for estimating a
target ROE. Should the Federal Reserve's priced-services target ROE for
the upcoming year be based on a short-term rate, which might reflect
what the market expects its peers to deliver in the upcoming year, or
should the target ROE be calculated using a long-term rate, which might
better reflect the return that the market expects its peers to deliver,
on average, over time? The Board also requests comment on the
reasonableness of incorporating a ten-year Treasury bond less a term
premium to reflect an expected average short-term risk-free rate over a
ten-year horizon. What are other factors that could be used to
incorporate a long-term time horizon?
Beta assumptions. A beta measures the sensitivity of the peer group
returns to the overall market's returns. In order to calculate a beta
representative of the Federal Reserve priced-services activities, a
comparable peer group is needed. When the peer group is identified, the
most relevant and appropriate methods to use for the beta calculation
can be determined.
1. Peer Group
Although BHCs' activities are not a perfect proxy for Reserve Bank
priced-services activity, they provide similar services through their
correspondent banking activities, including payment and settlement
services. They also hold respondent (``due-to'') balances, which are
similar to depository institution balances held by Reserve Banks, and
have publicly available information; therefore, they are the most
reasonable alternative.\16\ One drawback to using BHCs as the proxy is
that they offer diverse services with different risk profiles that
reach well beyond the payment services that are provided by the Reserve
Banks, such as consumer and corporate lending and investment services.
To reduce the effect on the ROE of these noncomparable services in
which BHCs are involved, the Board is also considering looking at the
level of a BHC's involvement in correspondent banking activity, its
capital structure, and its solvency ratings in refining the BHC peer
group to better match the Federal Reserve priced-services activities.
---------------------------------------------------------------------------
\16\ BHC due-to balances are bank deposits reported on the books
of the individual institutions that make up the BHC, which originate
from other banks and represent respondent balances held to provide
transaction processing and settlement services.
---------------------------------------------------------------------------
To choose peers whose activities are more comparable to the Federal
Reserve priced services, the Board is considering a peer group that
meets all of the following criteria.
1. The BHCs among the top fifty publicly traded BHCs based on
deposit balances.
2. The BHCs among the top fifty publicly traded BHCs based on their
level of due-to balances. By using deposit and due-to balances, the
peer group would represent publicly traded entities that provide
correspondent banking services and have several years of financial data
available in the public domain.\17\ This selection criteria may result
in a peer group of BHCs that hold both retail and correspondent
deposits and are more involved in transaction processing and settlement
services.
---------------------------------------------------------------------------
\17\ Choosing BHCs that have been traded for five years allows
the Federal Reserve to use BHC market returns in the other models
used to determine a target ROE. The number of years in the selection
criteria would change if more or fewer market data observations were
needed.
---------------------------------------------------------------------------
3. To more closely relate the peer group members' capital structure
and risk-weighted asset ratios to the Federal Reserve's priced-services
imputed capital structure, the Board is considering further refining
the selection process by choosing BHCs that have a ratio of Tier 1
capital to risk-weighted assets similar to Reserve Bank
[[Page 29519]]
priced-services activities (plus or minus 20 percent).\18\
---------------------------------------------------------------------------
\18\ The Tier 1 capital to risk-weighted assets ratio for the
2005 PSAF was 10.8 percent. Choosing a BHC within +/-20 percent of
the capital to risk-weighted asset ratio (8.6 percent to 13.0
percent for the 2005 PSAF) would capture a reasonable number of BHCs
with similar capital structures and risk-weighted assets.
---------------------------------------------------------------------------
4. To create a peer group that has a solvency rating similar to
that of the Federal Reserve's priced-services activities if the Federal
Reserve were a private firm, the peer group could be further narrowed
by including only the BHCs that have an investment-grade solvency
rating.
Attachment I shows the resulting peer group (cross-matched peer
group) of twenty BHCs that results from these selection criteria using
publicly available data as of December 2003.\19\ To minimize the
complexity involved in capturing the due-to balances for the peer
group, the Board is considering assuming that the largest three hundred
BHCs by deposit balance includes the top fifty BHCs by due-to
balance.\20\
---------------------------------------------------------------------------
\19\ The PSAF calculation uses data from audited financial
statements of the peer group. The data used for the 2005 PSAF
calculation is based on year-end 2003 data because this is the most
recent publicly available information at the time of the
calculation.
\20\ Due-to balance data are available only at the bank level
and must be aggregated to get to the BHC level.
---------------------------------------------------------------------------
An alternative the Board is also considering could eliminate
deposit balances as a selection criterion and use the three remaining
criteria to select a peer group, while limiting to twenty-five the
number of institutions to which it would be applied. Choosing the peer
group by the largest due-to balances and not considering their level of
deposit balance may result in a peer group that is more focused only on
correspondent banking activities. When the peer group is composed of
the top twenty-five institutions based on their level of due-to
balances that also meet the Tier 1 capital to risk-weighted assets
ratio and solvency rating filtering criteria, the peer group is
narrowed to seventeen of the twenty institutions that resulted from the
cross-matching of deposit and due-to balances.\21\
---------------------------------------------------------------------------
\21\ Of the top twenty-five institutions based on due-to
balances, three are not publicly traded and five do not have a Tier
1 capital to risk-weighted asset ratios similar to Reserve Bank
priced services.
---------------------------------------------------------------------------
Although the cross-matched peer group is smaller than the top fifty
BHC peer group by deposit balance, the majority of the top fifty BHCs
by deposit and due-to balances is accounted for in the cross-matched
peer group. For example, the cross-matched peer group consists of 67
percent of the deposits of the top fifty BHCs by deposit and 59 percent
of the due-to balances of the top fifty BHCs by due-to balance.
The Board requests comment on this modified approach to selecting a
peer group, and in particular on the following questions. What factors
should be considered when determining the Federal Reserve's priced-
services peer group? Is selecting a peer group based on deposit
balances, due-to balances, or a combination of both an appropriate peer
group selection criterion? Is there other criteria the Board should
consider? Do the Tier 1 capital-to-risk-weighted assets ratio and
solvency rating filters improve the selection method?
2. Beta Estimation Period
In the current method, the beta is estimated from a rolling ten-
year period of monthly stock returns for each BHC in the peer group.
Different sample periods result in different betas, with a longer
period producing a beta that is less sensitive to unusual market
variations and a shorter period having an opposite effect. The rolling
ten-year period was adopted because it provides a sufficient number of
market observations to mitigate the effect of market variations on the
calculation.
The Board is considering calculating the beta using monthly returns
from the market over a rolling five-year period rather than a rolling
ten-year period. Some financial sources suggest that using more years
of historical data to calculate the beta may be less relevant to the
firm's future returns than fewer years would be, because the nature of
business risks undertaken by firms may have changed significantly over
ten-years. The shorter period is less likely to distort ROE results
because it excludes some past structural changes in the banking
industry and in the financial markets that no longer reflect current
BHC peer group risk profiles. In addition, a five-year data period
could provide a reasonable number of observations to estimate the peer
group beta. Table 4 compares the 2005 CAPM ROEs of the current peer
group to the CAPM ROEs of the cross-matched peer group using a long-
term risk-free rate less a term premium.\22\ Using the five-year
rolling period results in a lower ROE for both peer groups because the
peer group BHCs' returns compared to the market's returns have been
less volatile over the five-year period than over the ten-year period.
---------------------------------------------------------------------------
\22\ For ease in illustration, only the cross-matched peer group
of due-to/deposit balances will be compared to the current peer
group throughout the remainder of this notice.
[GRAPHIC] [TIFF OMITTED] TN23MY05.005
[[Page 29520]]
The Board requests comment on the beta estimation period. Does a
rolling five-year period or a rolling ten-year period better capture
elements that are relevant to calculating a meaningful beta for
estimating the Reserve Bank priced-services ROE?
---------------------------------------------------------------------------
\23\ A minor modification to calculate beta produces slightly
different ROE results when comparing the current CAPM calculation,
shown in the first row, with the current 2005 CAPM calculation shown
in table 2.
---------------------------------------------------------------------------
3. Weighting of the Peer Group Betas
In the current method to determine the priced-services beta in
CAPM, the returns of each BHC in the peer group are market-value
weighted and are compared with the overall market returns. In effect,
value weighting assumes that a firm's payments business is proportional
to its market capitalization level. As BHCs become more involved in
nonpayment-related businesses, however, the extent to which market
capitalization is representative of a BHC's payments activities and its
usefulness to weight the betas is uncertain. Value weighting,
therefore, may not produce an appropriate beta to serve as the proxy
for the Reserve Banks' priced-services activities.
The Board is considering calculating the priced-services beta using
the equal-weighted returns of each BHC in the peer group rather than
value-weighted returns as a better approximation of the appropriate
peer group. Equal-weighted and value-weighted averages of betas from
2001 to 2005 for each BHC in the cross-matched peer group are shown in
attachment II. The difference between the betas, using equal-weighting
or value-weighting, with the cross-matched peer group of twenty BHCs,
varies. For 2001 and 2005, equal-weighting are .12 and .20 lower than
value-weighting, respectively.
Table 5 compares the ROEs that result from applying the two
different weighting schemes with the returns for each peer group using
a long-term risk-free rate less a term premium. For the 2005 CAPM
after-tax ROE using the cross-matched peer group, the difference
between equal-weighting and value-weighting is 2.0 percent.
[GRAPHIC] [TIFF OMITTED] TN23MY05.006
The Board requests comment on what weighting method is appropriate
to best capture the business risk of a peer group. Is equal-weighting
or value-weighting the returns of each BHC in the peer group preferable
when estimating beta? Should an alternative weighting process, such as
by deposit or due-to balances, be used? What are the strengths and
weaknesses of each weighting method?
4. Beta of 1.0
Historical betas use past returns of a firm and the market to
estimate the firm's beta for the future. Historical betas, however, may
not be a good predictor of the future risk for a firm because it may be
facing different risks than it did in the past. Finance literature
suggests that betas, as an empirical rule, move towards 1.0 over time.
Assigning a beta of 1.0 for a firm assumes that the firm will achieve
the same returns as the market over time, and therefore carries the
same risk as the market in the long run.
To simplify the beta estimation process, the Board is considering
assigning the Federal Reserve's priced services a beta of 1.0. When
using a beta of 1.0, a peer group is no longer needed to estimate the
target CAPM ROE.
An alternative way to incorporate the concept that all firm betas
will revert to 1.0 is to weight the historical beta and the beta of 1.0
to determine the firm's adjusted beta. For example, financial
literature suggests and financial firm practice support applying a two-
thirds weight on the historical beta and a one-third weight on the beta
of 1.0. The adjusted beta will reduce volatility and be a truer measure
of risk over the long run while moving the beta estimate closer to 1.0.
The Board requests comment on incorporating the concept that all
firm betas will be 1.0 over time in the priced-services beta
calculation. Is a beta equal to 1.0 for Federal Reserve priced services
a reasonable simplifying assumption when computing CAPM? Are important
elements that should be factored into the CAPM equation eliminated with
this assumption? If an adjusted beta should be considered, what is the
best method for implementing it?
In addition, the Board requests comment on the overall CAPM
methodology changes it is considering. Are the after-tax and pretax ROE
results of the CAPM-only method reasonable? In what ways, if any, does
this methodology oversimplify the calculation? In what ways, if any, is
the methodology overly complex?
D. Effect of Different PSAF Methodologies
Table 6 shows the effect on the beta of changes to the CAPM factors
being considered.
[[Page 29521]]
[GRAPHIC] [TIFF OMITTED] TN23MY05.007
As shown in rows one and two, the reduction in the peer group size
from fifty to twenty BHCs, which results when applying the filters
described in the peer group section of the notice, causes the
historical beta for the sample group to rise slightly. The rise in
historical beta is attributable to the increased weight of the larger
BHCs in the cross-matched peer group because the smaller BHCs in the
current peer group of fifty dropped out. In general, the smaller BHCs
have lower betas, which may result, in part, from a greater reliance on
more-traditional and less-risky core banking activities. The weighting
of the historical beta and the beta of 1.0 cause the adjusted beta to
be closer to 1.0.
The change in historical beta between rows two and three reflects
the change in the rolling beta estimation period from ten to five
years. This change produces a notable drop in the historical beta. The
reduction in the beta from .98 to .82 demonstrates that the cross-
matched peer group has been less volatile than the market over the last
five years than over the last ten years.
Lines three and four show that the historical beta for the cross-
matched peer group declines significantly when moving from value-
weighting to equal-weighting. The two largest BHCs based on market
capitalization have substantially higher betas than the other BHCs in
the peer group, with five-year averages of 1.5 and 1.2. With the
exception of two midsize-to-small BHCs, the remaining BHCs in the peer
group all have a five-year average betas of less than 1.0.\24\ The two
largest BHCs account for more than 60 percent of the sample group's
historical beta under value-weighting, while they make up just 24
percent of beta under equal-weighting.
---------------------------------------------------------------------------
\24\ The five-year average betas less than 1.0 range from
.48-.85.
---------------------------------------------------------------------------
Combining the peer group historical betas from table 6 above with
the appropriate interest rate and market data, the pretax return on
equity and the cost of equity\25\ for Reserve Bank priced services in
2005 are shown in table 7:\26\
---------------------------------------------------------------------------
\25\ A minor modification to calculate beta produces slightly
different ROE results when comparing the current CAPM calculation,
shown in the first row, with the current 2005 CAPM calculation shown
in table 2.
\26\ The estimated ROE is applied to the priced services 2005
book value equity balance of $808 million to derive the cost of
equity shown in the table.
[GRAPHIC] [TIFF OMITTED] TN23MY05.008
[[Page 29522]]
In 2005, a 100 basis point change in the pretax ROE increases or
decreases the imputed costs to priced services by about $8.1 million.
This is approximately 1.1 percent of priced-services expenses.\27\
---------------------------------------------------------------------------
\27\ System 2005 budgeted priced services expenses less shipping
are $724.8 million.
---------------------------------------------------------------------------
IV. Broader Issues in the Implementation of Target ROE
As noted earlier in this notice, the Board seeks to fully recover
the costs of its priced-services operations, including the PSAF, over
the long run. To limit unnecessary and potentially disruptive
volatility in its pricing, the Board does not require priced services
to offset previous years' overrecoveries or underrecoveries.
Accordingly, a target ROE for priced services is calculated each year
by the method described in this notice, and that target is factored
directly into product pricing decisions for the upcoming budget year.
The Board notes that among some companies the current practice is
to establish a multiyear ROE target, to be achieved over a strategic
planning horizon. Budget models may focus on specific project and
business line targets or on maximizing profit from year to year.
Strategic ROEs could take a longer-term view and consider changes in
the marketplace and technology and how the firm would respond to them,
along with planned capital investment. Companies may intentionally set
prices in a way that would result in actual ROE performance deviating
from the target year to year; however, they expect to achieve the
target on average over the planning horizon.
The Board would consider adopting a longer-term view if a case
could be made that it would significantly improve the efficiency of the
payments systems. Implementing a less mechanical approach would require
the Board to devise a transparent and replicable method to adjust the
annual ROE targets built into the Reserve Bank priced-services' budget
so as to achieve the long-term objective. The Board seeks comment on
the following questions.
Do firms target a different ROE for near-term budgeting purposes
than for multiyear, longer-term, strategic planning? What advantages or
disadvantages are there to the Federal Reserve setting a PSAF,
including the priced-services ROE, more or less frequently than
annually? What, if any, are the implications if a longer-term approach
to setting the ROE is adopted?
Under the MCA, the fees the Reserve Banks charge for priced
services are to be set to fully recover the costs that a private-sector
provider would incur in providing them over the long run. As the
payments system evolves from paper-based transactions to electronic
forms, the Board will be setting a target ROE for the Reserve Banks
priced-services activities in the context of declining volumes for its
check service line. The Board seeks comment on the following questions.
What are the advantages and disadvantages to the Board changing its
current practice of setting the target ROE for priced services at an
entity level and begin developing target ROEs for each service line? In
what way should the Board adjust the target ROE to consider the decline
in use of paper-based check products, given that the check service
represents a majority of priced-services activities?
V. Looking Ahead
While the Board considers the changes to the current PSAF
methodology discussed above, it recognizes that the changes under way
in the payments industry and regulatory practices will, in all
likelihood, lead to the consideration of more changes to the PSAF model
in the longer term. Historically, the Board considered BHCs a proxy for
the Reserve Bank priced-services peer group because correspondent banks
are the Reserve Banks' primary competitors in providing check services,
which comprises more than 80 percent of the cost of Reserve Bank
priced-services activities. Competitors in the electronic payment
services, however, have typically been market utilities. Market
utilities, such as the Clearing House Interbank Payment System (CHIPS),
which is the primary competitor for Fedwire funds transfer services,
and the Electronic Payments Network (EPN), which is the only private-
sector automated clearinghouse (ACH) operator, are both member-owned
clearinghouses. As paper check volume continues to decline and as the
check service increasingly becomes electronic, market utilities may
replace correspondent banks as the Reserve Banks' primary priced-
services competitor.
Similarly, proposals developed by the Basel Committee on Banking
Supervision (Basel II), once adopted, to improve capital regulations
internationally, make regulatory capital more risk sensitive, include
an explicit operational risk capital charge, and promote enhanced risk-
management practices among large, internationally active banking
organizations may affect the capital structure of the Reserve Banks'
priced-services peer group and warrant consideration in developing the
PSAF equity costs.
The Board would welcome any comments on the possible implications
of these and other environmental changes for the appropriate approach
to calculate the PSAF.
VI. Competitive Impact Analysis
All operational and legal changes considered by the Board that have
a substantial effect on payments system participants are subject to the
competitive impact analysis described in the March 1990 policy
statement ``The Federal Reserve in the Payments System.'' \28\ Under
this policy, the Board assesses whether the change would have a direct
and material adverse effect on the ability of other service providers
to compete effectively with the Federal Reserve in providing similar
services because of differing legal powers or constraints or because of
a dominant market position of the Federal Reserve deriving from such
legal differences. If the fees or fee structures create such an effect,
the Board must further evaluate the changes to assess whether their
benefits--such as contributions to payment system efficiency, payment
system integrity, or other Board objectives--can be retained while
reducing the hindrances to competition.
---------------------------------------------------------------------------
\28\ FRRS 9-1558.
---------------------------------------------------------------------------
Because the PSAF includes costs that must be recovered through fees
for priced services, changes made to the method may have an effect on
fees. The Board is considering changes that may refine the PSAF peer
group and ROE methodology to resemble that of other service providers
as required by the MCA. Consequently, the fees adopted by the Reserve
Banks should be based on the cost and profit targets that are
comparable with those of other providers of services similar to Reserve
Bank priced services. Accordingly, the Board believes that if it
determines to adopt some or all of these changes, the changes will not
have a direct and material adverse effect on the ability of other
service providers to compete effectively, due to legal differences,
with the Federal Reserve in providing similar services.
VII. Paperwork Reduction Act
In accordance with the Paperwork Reduction Act of 1995 (44 U.S.C.
ch. 3506; 5 CFR Part 1320 Appendix A.1), the Board has reviewed the
proposal under the authority delegated to the Board by the Office of
Management and Budget. No collections of information pursuant to the
Paperwork Reduction Act are contained in the proposal.
[[Page 29523]]
VIII. Summary of Comments Requested
A. Imputed ROE
The Board requests comment on alternative methods to calculate the
target ROE.
1. Are there models, other than the three in use, that the Board
should consider?
2. What is considered to be a reasonable target ROE for
institutions that provide services similar to those provided by the
Reserve Banks?
The Board requests comments on whether the CAPM methodology is
appropriate to rely on to estimate a target ROE.
3. What important elements of the ROE calculation might be excluded
if the Board adopts the CAPM-only method?
4. Are there considerations that do not support the use of CAPM to
impute the Reserve Banks' target ROE?
5. Is the DCF model used to estimate a target ROE? What earnings
estimates are the most useful?
6. Are recent published accounting earnings relevant when
estimating a target ROE?
7. Is the volatility of the CAPM-only method acceptable?
8. Should CAPM-only be viewed as a method to develop an ROE that
may be modified; if so, why and how would one modify the model?
B. CAPM Methodology
Risk-Free Investment Horizon
The Board requests comment on the time horizon for estimating a
target ROE.
1. Should the Federal Reserve's priced-services target ROE for the
upcoming year be based on a short-term rate, which might reflect what
the market expects its peers to deliver in the upcoming year, or should
the target ROE be calculated using a long-term rate, which might better
reflect the return that the market expects its peers to deliver, on
average, over time?
2. Is it reasonable for the Board to incorporate a ten-year
Treasury bond less a term premium to reflect an expected average short-
term risk-free rate over a ten-year horizon?
3. What are other factors that could be used to incorporate a long-
term time horizon?
Peer Group
The Board requests comment on the modified approach to selecting a
peer group, and in particular on the following questions.
4. What factors should be considered when determining the Federal
Reserve's priced-services peer group?
5. Is selecting a peer group based on deposit balances, due-to
balances, or a combination of both an appropriate peer group selection
criterion?
6. Is there other criteria the Board should consider?
7. Do the Tier 1 capital-to-risk-weighted assets ratio and solvency
ratings filters improve the selection method?
Beta Estimation Period
The Board requests comment on the beta estimation period.
8. Does a rolling five-year period or a rolling ten-year period
better capture elements that are relevant to calculating a meaningful
beta for estimating the Reserve Bank priced-services ROE?
Weighting of the Peer Group Betas
The Board requests comment on what weighting method is appropriate
to best capture the business risk of a peer group.
9. Is equal-weighting or value-weighting the returns of each BHC in
the peer group preferable when estimating beta?
10. Should an alternative weighting process, such as by deposit or
due-to balances, be used?
11. What are the strengths and weaknesses of each weighting method?
Beta of 1.0
The Board requests comment on incorporating the concept that all
firm betas will be 1.0 over time in the priced-services beta
calculation.
12. Is a beta equal to 1.0 for Federal Reserve priced services a
reasonable simplifying assumption when computing CAPM?
13. Are important elements that should be factored into the CAPM
equation eliminated with this assumption?
14. If an adjusted beta should be considered, what is the best
method for implementing it?
In addition, the Board requests comment on the overall CAPM
methodology changes it is considering.
15. Are the after-tax and pretax ROE results of the CAPM-only
method reasonable?
16. In what ways, if any, does this methodology oversimplify the
calculation?
17. In what ways, if any, is the methodology overly complex?
C. Broader Issues in the Implementation of the Target ROE
The Board seeks comment on the following questions.
1. Do firms target a different ROE for near-term budgeting purposes
than for multiyear, longer-term, strategic planning?
2. What advantages or disadvantages are there to the Federal
Reserve setting a PSAF, including the priced-services ROE, more or less
frequently than annually?
3. What, if any, are the implications if a longer-term approach to
setting the ROE is adopted?
4. What are the advantages and disadvantages to the Board changing
its current practice of setting the target ROE for priced services at
an entity level and begin developing target ROEs for each service line?
5. In what way should the Board adjust the target ROE to consider
the decline in use of paper-based check products, given that the check
service represents a majority of priced-services activities?
D. Looking Ahead
The Board requests comment on the possible implications that
payment industry and regulatory changes may have on the approach to
calculate PSAF.
By order of the Board of Governors of the Federal Reserve
System, May 17, 2005.
Jennifer J. Johnson,
Secretary of the Board.
BILLING CODE 6210-01-P
[[Page 29524]]
[GRAPHIC] [TIFF OMITTED] TN23MY05.009
[[Page 29525]]
[GRAPHIC] [TIFF OMITTED] TN23MY05.010
---------------------------------------------------------------------------
\29\ Differences in calculation timing result in slightly
different value- and equal-weighted betas than shown in Attachment
III.
---------------------------------------------------------------------------
[[Page 29526]]
[GRAPHIC] [TIFF OMITTED] TN23MY05.011
---------------------------------------------------------------------------
\30\ A minor modification to claculate beta produces slightly
different ROE results when comparing the current CAPM calculation,
shown in the first row, with the current 2005 CAPM calculation shown
in table 2.
---------------------------------------------------------------------------
[FR Doc. 05-10168 Filed 5-20-05; 8:45 am]
BILLING CODE 6210-01-C