Equity-Financed Banking

by: John Cochrane

My dream of equity-financed banking may be coming true under our noses. In "the Uberization of banking", Andy Kessler at the WSJ reports on SoFi (SOFI), a "fintech" company. The article is mostly about the human-interest story of its co-founder Mike Cagney. But the interspersed economics are interesting.

SoFi started by making student loans to Stanford MBAs, after figuring out that the default rate on such loans is basically zero. It...

has since expanded to student loans more generally and added mortgages, personal loans and wealth management. Mr. Cagney says SoFi has done 150,000 loans totaling $10 billion and is currently at a $1 billion monthly loan-origination rate.

Where does the money come from?

SoFi doesn't take deposits, so it's FDIC-free. ... Instead, SoFi raises money for its loans, most recently $1 billion from SoftBank and the hedge fund Third Point, in exchange for about a quarter of the company. SoFi uses this expanded balance sheet to make loans and then securitize many of them to sell them off to investors so it can make more loans

Just to bash the point home, consider what this means:

  • A "bank" (in the economic, not legal sense) can finance loans, raising money essentially all from equity and no conventional debt. And it can offer competitive borrowing rates - the supposedly too-high "cost of equity" is illusory.
  • There is no necessary link between the business of taking and servicing deposits and that of making loans. Banks need not (try to) "transform" maturity or risk.
  • To the extent that the bank wants to boost up the risk and return of its equity, it can do so by securitizing loans rather than by borrowing. (Securitized loans are not leverage - there is no promise of your money back when you want it. Investors bear any losses immediately and without recourse.)
  • Equity-financed banking can emerge without new regulations, or a big new Policy Initiative. It's enough to have relief from old regulations ("FDIC-free").
  • Since it makes no fixed-value promises, this structure is essentially run free and can't cause or contribute to a financial crisis.

More. SoFi does not use the standard methods of evaluating credit risk:

Instead of relying on notoriously inaccurate backward-looking FICO scores, SoFi is "forward-looking." That means asking basic questions - "Do you make more money than you spend?" - and calibrating where applicants went to college, how long they've been employed, how stable their income is likely to be over time.

Why can't banks do this? Because if you use depositor money for loans, as all banks do, you fall under the jurisdiction of the Federal Deposit Insurance Corp. and the Community Reinvestment Act...

And Basel and the FSOC and the Fed and so forth. FICO score based mechanical lending standards are also demanded by government-backed securitizers Fannie and Freddie.

Yes, bank "safety" regulations demand that banks purposely lend to people that one can pretty clearly see will not pay it back, and demand that they do not lend money to people that one can pretty clearly see will pay it back.

Now, what will the regulatory response be to this sort of innovation? The right answer, of course, should be hosannas: You have introduced run-free banking that solves all the financial-crisis worries that 90 years of bank regulation could not solve. Let this spread, and the army of bank regulators, lobbyists, lawyers, and associated politicians can all go, well, drive for Uber.

Somehow I doubt that will be the response from aforesaid army. And SoFi might well want to invest in its own lawyers, lobbyists and politicians in today's America.

Rather than by the FDIC, SoFi is monitored by the Consumer Financial Protection Bureau. The overbearing regulator that was Elizabeth Warren's brainchild thus far hasn't come down on SoFi - the CFPB is perhaps too preoccupied with using "disparate impact" analysis of old-school auto-loan businesses to focus on a relatively exotic, app-based form of banking. But Mr. Cagney should watch his back.

Indeed he should. In today's rather rule-free environment, the CFPB - or Department of Justice - might just discover it doesn't like the demographics of Stanford MBAs as target borrowers.

He'd like to get a national lending license, but that would entail federal-oversight entanglements he'd rather avoid.

If he can.

A little puzzle crops up at the end. For now, I gather SoFi does not issue public equity. The plan for expansion is...

insurance companies and sovereign-wealth funds might rent him their balance sheets.

I'm not sure what "rent a balance sheet" means, but it sounds a lot like private equity or long-term debt. It would be even better for stability and low cost to issue public equity, which is liquid - investors who need money fast can sell. But public equity comes with its own regulatory scrutiny, and perhaps even that is too much for innovation these days.