Big news for government and bank bond markets: APRA shuts down $139 billion Committed Liquidity Facility, forcing banks to buy government bonds

There has been very big news today for both the government and bank bond markets in what would have come as a significant shock to the banking system and almost all fixed-income investors: Australia's fearless banking regulator, in concert with the RBA, has effectively zeroed the massive taxpayer subsidy that was the $139 billion Committed Liquidity Facility (CLF), which will force banks to replace this existing portfolio of illiquid and relatively risky bank loans, bank bonds and residential mortgage-backed securities (RMBS) with much lower risk (in fact, riskless) and more liquid Commonwealth and State government bonds. 

This also has quite far-reaching and important investment ramifications for the fixed-income market, which few if any folks have been thinking about of late (save, if I can say so, a few of us) as everyone was working on the basis the CLF would be around "for many years to come", and if it was ever phased-out, it would be reduced over a "very slow glide-path of 3-5 years". That was the mantra being relentlessly pushed by the banks and trading desks...

For investors, this is very good news for Commonwealth and State government bonds, which will benefit from a lower cost of capital, and less positive for bank-issued, Aussie dollar senior bonds and AAA rated RMBS, which will have undergo a normalisation in their credit spreads back to at least the levels observed prior to the COVID crisis. 

But fear not: bank paper and RMBS is in incredibly high demand globally, and the increase in spreads, once it occurs, should offer attractive future payoffs. (Bank paper and RMBS have had their credit spreads artificially suppressed by banks buying one another's bonds, and RMBS, for their CLF portfolios.)

You can read a detailed recap of what the CLF is from us here. In short, it was a portfolio of internal bank loans, bank bonds and RMBS that a bank could hold instead of buying Commonwealth and State government bonds. It was created for a world when Australia had very little public debt. Because of the explosion in government debt to over $1.5 trillion, it is no longer needed, as Signal Macro's Matt Johnson has clearly demonstrated here and here.

It was a terrific regulatory arbitrage, because the banks themselves were the first to admit that they earned much more money on their portfolio of internal loans, bank bonds, and RMBS than they could earn on holding Commonwealth and State government bonds.

And Australia was globally unique in allowing banks to buy each other's securities instead of holding government bonds in this way. It was a great caper for as long as it lasted: the banks would regularly buy half-to-two-thirds of one another's bond issues, keeping their cost of capital artificially low while maximising their returns on equity.

While Coolabah had forecast that the CLF would be quickly zeroed given APRA's very clear and public remarks on the subject, as had others like Signal Macro's Matthew Johnson and UBS's Giulia Specchia, the banking system was mostly very resistant to the proposition.

APRA has over the last 12 months repeatedly written to the banks stating that the CLF would likely not exist in the "foreseeable future" given the explosion in the availability of government debt. 

And yet as public debt issuance continued, the banks, and investors, were incredibly complacent around the risks of APRA delivering on its statements. And boy has it done so.

In a pithy release this morning, APRA stated that the banks will not be able to rely on the CLF to meet their minimum Liquidity Coverage Ratio of 100% by 1 January 2022 (ie, within four months). And then they have 12 months to completely eliminate their reliance on the CLF (ie, by end 2022). In APRA's words:

APRA expects ADIs to purchase the High Quality Liquid Assets (government bonds) necessary to eliminate the need for the CLF. Specifically, no ADI should rely on the CLF to meet its minimum 100 per cent LCR requirement from the beginning of 2022 (although ADIs may continue to count any remaining CLF as part of their liquidity buffer). ADIs should then reduce their use of the CLF to zero by the end of 2022. 

In a companion piece of blockbuster news, the RBA has lifted its estimate of the total share of the government bond market that banks can hold from 30% to 35%. This only underscores the the point that the CLF is unlikely to make a comeback any time in the next decade. 

This is especially true because APRA has also created a new backup Contingent Liquidity Proposal that banks have to have in place by the end of this year, which will be worth another 30% of their emergency liquidity. Coolabah had previously speculated that this new requirement might presage the disappearance of the CLF.

When we have surveyed bank treasurers in the past about what they would do if the CLF was eliminated, they have consistently responded that they would have to issue wholesale debt and buy government bonds, as other banks around the world are required to do.

While you will hear stories about the banks holding hundreds of billions of dollars of excess cash on deposit at the RBA, the truth is that Aussie banks are not carrying that much excess liquidity right now.

APRA mandates that they have to hold high quality liquid assets (HQLA) worth at least 100% of the cash-outflows that banks would suffer in a 30 day crisis. HQLA includes cash on deposit at the RBA plus Commonwealth and State government bonds. 

The banks then internally run minimum LCR targets above 125%. And all the banks are pretty close to these minimums except ANZ and Macquarie. As we have previously noted, only ANZ's Adrian Went has been compliant with APRA's APS 210 standard that requires banks to buy as much HQLA as they can to meet their LCR targets before requesting help via the CLF (and to only request such help if sufficient HQLA does not exist). 

In recent years ANZ has worked hard to radically reduce its reliance on the CLF in contrast to its larger peers by running down its portfolio of CLF assets by more than $30 billion since 2019 compared to Westpac, which only reduced its CLF by a miserly $15 billion.

What that means is that as the CLF is zeroed over the next year, banks are going to have to replace it with new Commonwealth and State government bonds. And to pay for these assets, the banks will have to issue debt.

So for investors, the key take-aways are probably as follows:

• Banks were one of the biggest buyers of 5-year bank senior bonds and 3-to-5-year AAA rated bank and non-bank issued RMBS in Aussie dollars for their CLF books. This demand is likely to shrink dramatically, normalising the credit spreads on 5-year bank senior paper and 3-year AAA rated RMBS back to pre-COVID levels (eg, at least 30 basis points higher than current spreads, which would still be very, very low for the post-GFC period). One could see 5-year major bank senior spreads back at circa 70bps above BBSW and AAA rated, 3 year major bank RMBS back to say 80 to 90bps over BBSW;
• Banks have, somewhat bizarrely, sold over $100 billion of government bonds since mid 2020, as Matt Johnson shows here. They are going to now be net buyers of Commonwealth and State government bonds in potentially very large size, which should support these sectors. UBS's excellent analyst Giulia Specchia, who called the shuttering of the CLF only this week, writes (where "semis" are State government bonds):

We expect Semis’ gross issuance to be ~$94bn in FY-22, and we expect the RBA will buy $30bn. This means net-net issuance is on track to be $41bn in FY-22 (Figure 4) – unchanged from last fiscal year. While this is material, the unwound of the CLF should help support demand for Semis. Notably, the CLF reduction from now until the end of Dec-21 is worth ~$35bn; and another ~$52bn over the period Jan-Jun-22. That is $87bn of potential demand. While not all of the reduction in the CLF has to be translated into demand for Semis (ADIs could just hold cash at the RBA), we still think that – especially at the current level of spreads – it makes sense for ADIs to buy Semi-government bonds. Amid ongoing support from RBA QE, and likely strong demand from ADIs over the next months, we think that risk reward has shifted in favour of a tighter Semi-bond spread.

Now you will read lots of narratives as to why "this is no big deal". One myth is that banks are carrying massive excess cash at the RBA, and don't need to buy any HQLA at all. That is wrong: they are running LCRs close to their internal minimums of 125%, and will have to replace the lost $139 billion from the CLF with new HQLA. That is why APRA explicitly said today "APRA expects ADIs to purchase the High Quality Liquid Assets (government bonds) necessary to eliminate the need for the CLF".

Another argument might be that banks can just issue the debt they need to replace the CLF and then sit the cash on deposit at the RBA. The problem with this is that these deposits pay no interest. So cash at the RBA is a huge revenue and net interest margin drag for the banks. It is an especially big drag when you are issuing expensive wholesale bonds to buy HQLA, and then putting that money on deposit at the RBA earning nothing

Banks therefore have a very strong commercial incentive to spend the cash on deposit at the RBA on HQLA (ie, Commonwealth and State government bonds) that pay them real interest above the 0.06% pa cost of the wholesale liability levy that bank funding attracts. This is the minimum hurdle rate of interest that Commonwealth and State government bonds have to pay banks in order for them to prefer these assets over cash at the RBA.

Another extremely silly suggestion is that APRA will simply allow the banks to lower their internal minimum target LCRs from 125% currently to some lesser number to offset the loss of the CLF. That was an idea bandied around by one major bank researcher. 

But it is oxymoronic: that logic suggests that when the banks were buying one another's bonds, they could run LCRs over 125%, but now they have to hold real HQLA, they are going to run materially lower LCRs. 

There is zero chance this will happen because banks themselves internally target LCRs of more than 125% as a buffer beyond the hard APRA hurdle of 100% (as they do with all their regulatory hurdles). It would be wishful thinking that either bank boards or APRA would allow banks to get away with lower LCRs.

A final idea is that the RBA's QE program will create the HQLA for the banks. Yet we have seen LCRs declining over the last 12 months despite persistent QE.  And the cash held at the RBA is not distributed evenly with, for example, custodial banks accumulating a lot. There is once again a strong commercial incentive for banks to spend zero-interest earning cash at the RBA to avoid being the bank left accumulating it. 

Finally, after mid 2022, the excess cash at the RBA will start dropping fast. The banks will be repaying the $188 billion they owe the RBA under the Term Funding Facility, which destroys excess cash on deposit at the RBA. And the RBA's portfolio of bonds will eventually start maturing, further reducing excess deposits that banks hold with it.

Combined with ongoing balance-sheet growth and deposit growth, both of which normally necessitate additional HQLA, banks are likely to have long and strong demand for Commonwealth and State government bonds.

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