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Fed Shuts Down BTFP and Bolsters Discount Window: Implications for the Lender of Last Resort Role

Fed Shuts Down BTFP and Bolsters Discount Window: Implications for the Lender of Last Resort Role

Jan 28, 2024
The Fed

Fed Shuts Down BTFP and Bolsters Discount Window: Implications for the Lender of Last Resort Role

The Federal Reserve (Fed) has announced the shutdown of its Bank Term Funding Program (BTFP), an emergency tool created during the banking crisis of the previous year. This move is coupled with an enhancement of the discount window facility, suggesting a strategic shift in the Fed's approach to lending support to financial institutions. This article will explore the implications of these changes, focusing on the Fed's lender of last resort function and the ongoing challenges that necessitate such adjustments.

Bank Term Funding Program (BTFP) Overview

The BTFP was introduced as a response to the banking crisis in March and April of the previous year. It allowed depository banks to borrow at an interest rate tied to the Overnight Index Swap (OIS) plus a ten-basis-point surcharge. As of the current period, this rate stands at approximately 4.9%.

Due to a fall in OIS rates over recent months, a profitable arbitrage opportunity emerged for banks. They could borrow from the Fed at 4.9% and leave the borrowed funds in their reserve accounts, earning interest on reserves (IOR) or interest on excess reserves (IOER) at a rate of 5.4%. This situation resulted in a de facto "free money" profit of around 50 basis points.

In response to negative publicity and to close this loophole, the Fed has decided to align the borrowing rate with the IOR rate until March 11, after which it will no longer accept new loans under the BTFP.

Concerns and Implications

The immediate concern is determining the extent to which the BTFP's current usage is based on this arbitrage opportunity versus the genuine funding needs of banks in the marketplace. The Fed's anxiety appears to center around this differentiation, as it could indicate underlying strains in the banking system.

The move to phase out the BTFP and shift focus to the discount window, traditionally known as primary credit, raises questions about the Fed's ability to address its foundational lender of last resort responsibilities. Historically, the Fed has had to frequently revise its support mechanisms, which suggests difficulties in achieving a stable and effective intervention strategy.

Financial Crisis vs. Monetary Crisis

The distinction between a financial crisis and a monetary crisis is crucial to understanding the Fed's challenges. A financial crisis typically involves the revaluation of mispriced assets, leading to economic pain as markets adjust. A monetary crisis, however, is characterized by a severe liquidity shortfall that prevents even solvent institutions from liquidating assets at reasonable prices, causing widespread market dysfunction and potential contagion.

The Role of the Discount Window

The discount window's effectiveness as a lender of last resort tool is contingent on banks having adequate collateral. The recent banking failures highlighted that some institutions lacked the necessary collateral, rendering the discount window inaccessible. This has led to discussions about improving the preparedness of banks to use the discount window, including the pre-positioning of collateral.

These discussions indicate the Fed's recognition of the limitations of private repo markets during times of stress and the need for a more reliable and immediate funding source for banks.

The Underlying Systemic Issues

The focus on the BTFP and the discount window obscures a larger concern: the frequent breakdown of wholesale funding markets, such as repo, and their implications for global liquidity. The Fed's regulatory authority is limited to domestic banking, which may explain its concentration on US banks rather than the broader global financial system.

The systemic issues often point to dealer balance sheet constraints and the broader eurodollar system—factors that go beyond the Fed's domestic purview but are essential to understanding and addressing the root causes of financial instability.


The Fed's move to sunset the BTFP and enhance the discount window signals not just a tactical shift but also an acknowledgment of deeper issues in its lender of last resort functions. The challenges faced by the Fed are emblematic of the complexities of the modern financial system, particularly the international eurodollar market that operates outside its jurisdiction. As the Fed continues to iterate on its intervention tools, the underlying systemic issues within the global monetary framework remain in need of attention and resolution.


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