Electronic copy available at: http://ssrn.com/abstract=2055149
Running head: Separating Commercial and Investment Banking 1
Commercial Banking and Investment Banking: Separation vs. Unification
Richard Lartey
, PMP
SMC University
Switzerland
May 5, 2012
The views expressed in this paper are the author’s alone. I am extremely grateful to Dr. John
H. Nugent, Associate Professor, School of Management, Texas Woman’s University, for
constructively reviewing this paper and providing valuable comments. But of course, the usual
disclaimers apply and any mistake is the author’s only and does not engage anyone but the
author!
Electronic copy available at: http://ssrn.com/abstract=2055149
Separating Commercial and Investment Banking 2
Table of contents
Table of contents ........................................................................................................................................... 2
Abstract ......................................................................................................................................................... 3
1.0 Introduction ....................................................................................................................................... 4
2.0 Discussion of the facts and issues ..................................................................................................... 5
2.1 Commercial Banking .................................................................................................................... 5
2.2 Investment Banking ...................................................................................................................... 6
2.3 Separation of Commercial and Investment Banking .................................................................... 7
3.0 Analysis of the facts and issues ......................................................................................................... 9
3.1 Common premise for Commercial and Investment Banking ........................................................ 9
3.2 Unified Banking vs. Separated Banking ..................................................................................... 10
4.0 Conclusion ...................................................................................................................................... 13
5.0 Recommendations ........................................................................................................................... 13
References ................................................................................................................................................... 14
Electronic copy available at: http://ssrn.com/abstract=2055149
Separating Commercial and Investment Banking 3
Abstract
Over the past years, the global financial sector has undergone tremendous transformation
as banking concentration has increased in all banking markets. Increased competition in the
banking industry warrants increased attention of the financial sector regulatory authority to
segregate commercial banking from investment banking. The public-interest discourse for the
separation of commercial banking from investment banking is weak and appears unable to
explain the provisions of the Banking Act. The paper found that the rationale for the separation
of commercial and investment banking was ill-founded.
Keywords: Banking, Commercial Bank, Investment Bank, Regulation, Deregulation
Separating Commercial and Investment Banking 4
1.0 Introduction
Several complexities exist in today’s world of banking and finance. Although banking
regulation has changed the operational platform in which commercial and investment banks
amalgamate, the nitty-gritty of their different businesses remain integral. While most private
banks are able to conduct the full range of banking activities, some tend to specialize in
investment banking, asset management, and trust business. In the 1960s, commercial banks were
the largest providers of venture-capital financing (Craig, n.d.). However, the banking landscape
has over several decades been heavily affected and shaped by regulation and structural barriers
between different financial services aimed at deepening competition in the industry. Rivalry
among banks is often brandished by gargantuan political and economic power.
Prior to the passage of the Banking Act of 1933, bank regulation was greatly tightened in
the United States which led to more than 9,000 banks failing during the great depression years of
1930-1933 (LaRoche, n.d.). Many experts including the legislature have blamed these failures
on the alleged unethical actions arising from the amalgamation of commercial and investment
banking. According to LaRoche (n.d.), these failures happened for three main reasons: “banks
invested their own assets in risky securities, unsound loans were made to boost the price of
securities of companies whom the bank had invested in, and the commercial banks interests in
the price of securities tempted bank managers to pressure customers to purchase risky securities
that the bank was trying to sell.” Although there was little or no evidence of blaming banks’
failures on unified banking, there were differences of opinion between those who sought to
separate commercial banks from investment banking activities and those who favoured
permitting such activities (Craig, n.d.).
While the separation of commercial and investment banking was rationalized using
public speaking, many authors have an opposing view that this public-interest rhetoric cannot be
Separating Commercial and Investment Banking 5
supported theoretically or factually. It is argued that banks whose activities focused on
integrating commercial and investing banking were safer than stand-alone commercial banks and
they issued higher quality securities than independent investment banks (Tabarrok, n.d.). This
paper discusses the concepts of separating commercial banking from investment banking. It
analyzes the regulatory provisions of the Glass-Steagall Act of 1933 that gave rise to the
separation of commercial banking from investment banking and provides a comparison between
split banking (separating commercial banking from investment banking) and unified banking
(combining commercial banking with investment banking).
2.0 Discussion of the facts and issues
The difference between commercial banking and investing banking lies mainly in the
services they provide, and to whom they are provided. This section explores the differences
between commercial banking and investment banking operations and discusses the issues
relating to the separation of these banking activities.
2.1 Commercial Banking
A commercial bank generally provides basic banking needs such as loans to individuals
and small and large businesses. Through commercial banking activities, funds are raised by
collecting deposits from these individuals and organizations, charging interest on loans, and
purchasing bonds from governments and corporate entities. Commercial banking process is easy
and straightforward. In a dynamic theoretical framework, commercial banks compete for
customers by setting acceptance criteria for granting loans, taking regulatory requirements into
account. By easing its acceptance criteria, a commercial bank faces a trade-off between attracting
more demand for loans, thus making higher per period profits, and a deterioration of the quality
of its loan portfolio, thus tolerating a higher risk of failure (Bolt & Tieman, 2004).
Separating Commercial and Investment Banking 6
Traditional commercial banks hold nonmarketable or illiquid assets that are funded
largely with deposits (Boot, 2008). Commercial banks are more risk averse than investment
banks since their traditional line of business focuses on accepting deposits and making loans
available to borrowers, thereby receiving profit only if the borrowing corporations repay. Vault
(n.d.) found that even before the repeal of the Glass-Steagall Act, commercial banks have long
competed for the business of legally underwriting debt directly with investment banks, and some
of the largest commercial banks have developed substantial expertise in underwriting public
bond deals.
2.2 Investment Banking
From a transaction orientation perspective of modern banking, investment bank’s role
could be interpreted as that of a broker; i.e., matching buyers and sellers for the firms’ securities.
Modern banking practices have narrowed the description of an investment bank’s economic role
as investment banks’ added value are often confined to their ability to economize on search or
matching costs (Boot, 2008). But Boot (2008) argues that investment banks do more to the extent
that they almost without exception underwrite public issues, thereby absorbing credit and/or
placement risk. Investment banks, by nature, are not financial intermediaries i.e. they focus on
assisting corporations in the issuance of securities (principally stocks and bonds), hence they
have higher risk tolerance levels than do commercial banks. LaRoche (n.d.) accentuates that the
reputations of investment banks are indicted when they assist companies that perform poorly, in
spite of the fact that the receipt of revenue not being tied to the performance after issuance makes
them relatively risk tolerant.
In their paper, Altınkılıç, et al. (2007) found that investment banks’ governance has
responded to the deregulation of commercial bank entry into investment banking by virtue of the
Separating Commercial and Investment Banking 7
repeal of the Glass-Steagall Act. An investment bank, however, often focuses on investing a
depositor’s assets in a finance portfolio and managing these investments. For an investment
bank, the processing and absorption of risk is a typical intermediation function similar to a
commercial bank engaged in lending (Boot, 2008). Unlike commercial banks which already have
funds available from their depositors, investment banks typically do not earn interest; they spend
considerable time finding investors in order to obtain capital for their clients. With this in mind,
an investment bank involved in the offering does not own the bonds but merely places them with
investors at the outset and the bondholders earn this interest in the form of regular coupon
payments (Vault, n.d.).
2.3 Separation of Commercial and Investment Banking
Recent debates over the structure and performance in the banking system have some
antecedents from researches based on the German, British and American banking system. Unlike
other developed countries, the U.S. has historically maintained a severance between commercial
banking and investment banking until the late 1980s. Due to the persistent challenges in the
banking system, certain regulatory and legislative mechanisms have been put in place by various
governments to segregate commercial and investment banking practices and to combat banking
crisis. One of such frameworks is the Banking Act of 1933, also known as the Glass-Steagall
Act, which was enacted to isolate commercial banking from investment banking (Tabarrok, n.d.).
In alignment with the provisions of the Glass-Steagall Act, some proponents emphasized that the
segregation of commercial banking activities from that of investment banking would enhance
investor and customer safety while lowering conflicts of interest both on the part of the bank and
customers.
Separating Commercial and Investment Banking 8
The regulatory provision of the Glass-Steagall Act which impacted significantly on the
banking industry was the limitation of interest rates on deposit accounts, registration of bank
holding companies, extension of statewide branching rights to national banks in states permitting
similar rights for state-chartered institutions, and the separation of commercial and investment
banking (Filipiak, 2009). With this legal provision, the severance of commercial and investment
banking activities certainly aided commercial banking by protecting its industry from
competitors in a closely related field that had lost all value. The risk tolerance and culture
differences between commercial and investment banks make them to be likened to the “water
and oil” phenomenon; they can never mix. While commercial banks and investment banks are
complementary in some areas, differences in their level of risk tolerance and culture pose serious
challenges when they are merged. For example, the merger of J.P.Morgan and Chase Manhattan
Bank was one that was perceived by many analysts to have proven beneficial but the culture
clash and risk tolerance differentiation prevented the new firm from ever achieving the synergies
the financial world was expecting (LaRoche, n.d.).
From a micro-historic perspective, some individual bankers spearheaded the provisions
of the Glass-Steagall Act that separated commercial banking from investment banking. But some
authors argue that although the Banking Act was benefited from and supported by only private
interest groups such as investment bankers, they provided no direct evidence (Shughart, 1988;
Macey, 1984; Benston, 1982, cited in Tabarrok, n.d.). In the case of the Morgans vs. the
Rockefellers, separation of commercial and investment banking hurt the House of Morgan
disproportionately whilst it offered the Rockefeller group a decisive advantage in their battle
with the Morgans although their cost of banking was raised (Tabarrok, n.d.).
Prior to the enactment of the Glass-Steagall Act of 1993, a lot of concerns were raised
with regards to abuses by investment banks that were affiliated to commercial banks. These
Separating Commercial and Investment Banking 9
investment banks were alleged to have over-stated the quality of the underwritten securities
issued by the commercial banks’ clients, packaged bad commercial loans into securities, misused
responsibility for trust accounts etc (FRBSF, 1995); hence the need to pass the Glass-Steagall
Act to proscribe commercial banks from undertaking investment banking activities with the
object to protecting investors’ interest from future abuses. The isolation of commercial banking
from investment banking was intended to “maintain the integrity of the banking system, prevent
self-dealing and other financial abuses, and limit stock market speculation (Jackson, 1987).
3.0 Analysis of the facts and issues
Commercial Banks and Investment banks operate at different levels. But as far as
companies are concerned, they use and treat investment banks as commercial banks. Thus
commercial banking and investment banking both involve the provision of financial services and
advice to individuals and organizations. This section analyzes the similarities and common
activities of commercial and investment banks that provide the rationale for their integration or
otherwise.
3.1 Common premise for Commercial and Investment Banking
Commercial and investment banks have a considerable level of commonality in their
services so unifying them can prevent duplication and reduce the cost of operation. For instance,
both commercial banks and investment banks engage in merchant banking and they most
commonly invest in one type of security (common stock) as well as securities with an equity
participation feature such as convertible preferred stock or subordinated debt with conversion
privileges or warrants (Craig, n.d.). Regardless of how magnificent the hedge created by the
separation appeared, there was a total collapse in this “wall” of separation after several decades
Separating Commercial and Investment Banking 10
of its implementation as commercial banks created new financial products resembling securities,
whiles investment banks innovated new financial products similar to loans and deposits
(Jackson, 1987).
Most financial analysts argue that the fusion of banking activities has not always proved
beneficial for insurance companies and securities firms that purchased banks and commercial
banks to underwrite insurance and securities (LaRoche, n.d.). It is in this regard that the UK's
Independent Commission on Banking has espoused more radical reforms that could be geared
towards capital provisioning (The Economic Times, 2011). With this suggestion, the underlying
philosophy focuses on protecting commercial banks from their investment arms in order to limit
taxpayer bailouts.
3.2 Unified Banking vs. Separated Banking
In recent years, most of the debates over banking structure reforms have been directed
towards reassessment of the provisions in the Glass-Steagall Act that mandated the separation of
commercial and investment banking. Since the repeal of the Glass-Steagall Act in 1999 by the
Gramm-Leach-Bliley Act, many banks have engaged in both commercial and investment
banking activities, which is believed to have been a major contributing factor to the bust of the
internet bubble in 2000 and 2001, and the beginning of the 2007-2008 global financial
meltdown.
At the most basic level, security investments (such as stocks and bonds) are liquid and
publicly efficient for depositors and bond holders. This often makes many securities appear to be
less risky than loans. But even if investing in securities is more risky than loans, Macey (1991,
cited in Tabarrok, n.d.) argues that preventing banks from investing in securities could increase
bank risk due to diversification benefits. Many are of the view that banks with security affiliates
Separating Commercial and Investment Banking 11
(amalgamated banking) create an undue risk to depositors but Benson (1990, cited in Tabarrok,
n.d.) disagrees to this assertion. According to Tabarrok (n.d.), “separated banking is riskier than
unified banking.” This is in alignment with White’s (1986, cited in Tabarrok, n.d.) argument that
banks without security affiliates are four times more likely to fail than those with security
affiliates.
While it is often argued that banks with security affiliates have conflicts of interest,
unified banking supports investor interest more clearly than segregated banking because
investors are able to threaten stronger punitive action if they invest with a unified bank than with
a stand-alone investment bank (Benson, 1990; Saunders, 1985; Kelly, 1985, cited in Tabarrok,
n.d.). In line with Benson’s (1990) evidence of fabricated records, Kroszner & Rajan (1994)
found that the conflict of interest argument is contracted by investor behaviour because unified
banks issue higher quality securities than stand-alone investment banks (cited in Tabarrok, n.d.).
All these arguments support Randall Kroszner’s comment that “there was no evidence to back
the “public interest rationale” for the separation of commercial and investment banking” (Mayer,
2009).
In proposing to combine commercial and investment banking, many experts and
practitioners in the global banking industry have made several counter-arguments that seek to
relax the restrictions of the Glass-Steagall Act. Jackson (1987) outlines four cases that were
made against preserving the Act. The first argument highlights how banks now operate in
"deregulated" financial markets in which distinctions between loans, securities, and deposits are
not well drawn; and how banks are losing market shares to unregulated securities firms and
foreign financial institutions. T