The Fed Funds Rate Should Be Reduced To 1% Or Less For An Indefinite Period

We are foolishly paying hundreds of billions of dollars of interest on the National Debt. Many European nations pay negative interest rates. We should reduce our interest rates and save the interest costs. It will reduce inflationary pressure and the interest saving can be used to fund infrastructure spending.




After every stock market crash we search for the causes and change rules and regulations to prevent future recurrences. Politicians are not well suited for the task. It is unlikely that the current rules and regulations will prevent a future crash because they fail to prevent or adequately limit use of practices which exacerbate market declines such as short selling, stop loss orders, chart theory and excessive margin buying which leads to margin liquidations in declining markets. Managers of many large pools of capital understand the effects of such practices and execute trades timed to further enhance extreme market declines so that they can then become buyers after the precipitous decline.

The talking heads on financial news networks have speculated lately on whether a 20% stock market decline like the one that occurred on October 19,1989 might occur again. They discuss the fact that a 600 point decline in the Dow is currently only about a 2% decline and that a 20% decline would amount to more than 5000 points in the Dow. They often talk about the differences in the US economy between 1989 and now, the possibility of a recession, the strength of corporate earnings and balance sheets, the trade war with China, tariffs, the effects of negative European interest rates, the rate of inflation and the Feds current stance on interest rates and its balance sheet. However, I haven’t heard them talk recently of governmental regulations or controls in place to prevent the recurrence of a 1989 type decline. The safety net value of current regulations and controls in place were about to be tested last year until the Fed reversed its course on interest rates after raising interest rates too fast and projecting ridiculously stupid further interest rate increases and balance sheet reductions. Has the Fed already forgotten the result of its successful policies which enabled our economy to escape from the Great Recession. Does the Fed understand that excessive stock market declines can lead not only to a recession, but as in the 1930’s to a depression? Fed chief Powell stupidly talks of patience when he should have admitted his error in adopting overly restrictive Fed policy decisions. 

Most of us learned from old western movies that a rancher who wishes to avoid a stampede of his horses or cattle builds secure fences or takes precautionary measures when moving his herd. Our current securities regulations and controls which are designed to stem an out of control decline were influenced by investment bankers seeking to maximize their profits by encouraging speculative practices in disregard of stock market stability. Brokers profit from charging high rates of margin interest and charging short sellers for borrowed stock. Speculators often profit in declining markets from short sales at declining prices made possible by the elimination of the uptick rule. A combination of factors acting in concert, including short selling at declining prices,  stop-loss order liquidations, margin calls, tax selling, reaching chart theory sell points and panic, cause stock price declines to be exaggerated.

Now is the time to take action to change the government regulations and controls of the securities markets to greatly reduce the probability of a crash. The Fed and the SEC should work together. Here is what I propose:

  1. The SEC should immediately reinstate the uptick rule and prevent way to avoid it. It was lunacy to remove it.
  2. The SEC should ban all new short selling when  any of the Dow, S&P or the NASDAQ averages (the “leading market averages”) have declined more that 20% from their 6 month highs; and continue the ban until all such averages have recovered at least 10% from their low point after the ban is put in place.
  3. The Fed should limit the risk of margin liquidations by changing margin requirements to provide that aggregate initial margin in an account shall be reduced to 40% during each 30 day period after which any of the leading market averages has hit a 12 month high.
  4. The SEC should change the way stop loss orders operate. Make them become good until canceled limit orders and not market orders when the stop loss point is reached. This will reduce the avalanche aspects of sales at declining market prices and discourage misplaced reliance on the protection of stop loss orders.
  5. Try to reduce dumping of large numbers of shares by active traders by charging a small fee on the dollar amount of all sales of securities held less than 5 years.

The Feds goal of full employment is negatively impacted by stock market declines. A reduction in the wealth of investors negatively impacts their spending. The Fed should stop talking foolishly about “patience” and clarify that it intends to reduce interest rates and engage in QE whenever stock prices decline significantly.

The Fed Should Have Raised The Initial Margin Requirements, Not Interest Rates

Investors who utilize maximum margin to leverage their equity purchases in rising stock markets often greatly increase their gains. The problem is that they also increase their risk of loss. Investors who keep utilizing their buying power resulting from price increases to maximize their margin debt are like casino gamblers who never take any chips off the table. No-one should expect a favorable run to continue forever. Rising stock market averages and prices of the common stock of even the most successful entities tend to overshoot their fair value and eventually incur corrections.

Present margin rules as set by the Fed require initial margin of 50% and maintenance margin requirements of 25%. The maintenance requirement only comes into play if the value of a portfolio declines. For example, assume you have $10,000 to invest. You could buy $20,000 of stock on margin. “The broker lends you the other $10,000. If the stock triples and goes up in value to $60,000 giving you an equity of $50,000  you can borrow an additional $40,000 and purchase additional securities of the same or a different entity. You  have maximized your use of margin. Had you not bought on margin your investment would be worth $30,000. Now suppose the portfolio doubles again. Your initial investment is now worth $150,000 ($200,000 of equity minus $50,000 of debt) versus $60,000 of equity had you not utilized margin. Suppose you borrow an additional $100,000 to purchase additional securities leaving you with $300,000 of securities with maximum margin debt of $150,000.

Now, let’s assume the stock market goes into correction and your securities decline by 20%. They are now worth $240,000, leaving you with $90,000 in equity and $150,000 in debt. To meet the 25% maintenance requirement you must have a total equity of  $187,500 (25% above the debt of $150,000). Suppose the decline from the top reaches 40% leaving you with an aggregate value of $180,000 or a net equity of $30,000. This is below the 25% maintenance requirement and you will be required to either add cash or sell securities to reduce the debt to meet the maintenance requirement. After a meteoric rise from $10,000 to $150,000 the value of your account is back to $30,000. Had you not bought on margin your hypothetical investment would be worth $36,000 ($60,000 less $24,000). Had you not borrowed the last $100,000, Your investment would be worth $$70,000 ($120,000 minus $50,000). You would not have received a margin call.

Every investment situation is different. The above example is an attempt to examine the risks and potential advantages and disadvantages of use of margin leverage. In periods of “irrational exuberance” the risk of loss increases. The Fed can reduce margin risk by increasing the initial margin requirement thereby limiting the ability to increase margin debt if it perceives a significant risk of a market decline.

The Fed should be cautious of margin risk. Sales to meet margin requirements whether by choice or by requirement can exaggerate a decline in a falling stock market. Such sales, coupled with the inept uptick rule adopted by the SEC that permits short sellers to initiate a market decline  and the potential waterfall effect of  stop loss orders that might in a declining stock market be executed electronically at declining prices, can be leading contributors to a stock market crash.

The Fed is raising the wrong rate. As described in my previous post it should not be raising interest rates which both cause inflation and slow the economy leading to stagflation or a recession. It should have been concerned about controlling individual investor and market risk caused by excessive margin debt as market averages and p/e ratios rose to new highs. Hopefully, it will have that opportunity again in the future.






Eliminating Recessions, Minimizing Interest Payments On The National Debt And Maximizing Economic Growth Should Be Added To Fed Mandates

Brilliant action by the Fed, which kept interest rates low for more than 8 years, was instrumental in preventing the Great Recession from becoming a depression.  It was an exceptional achievement considering the mess our bankers has created. Low interest rates and QE debt purchases ended the downturn and worked together with technology improvements, the Amazon effect and other factors to fuel a low-inflation recovery. Eliminating many Obama administration regulations and the once in a generation business tax cut spearheaded by President Trump have greatly stimulated the GDP.  But a large number of fools including those currently leading the Fed seem bent on ending the upturn and causing a recession. Chairman Jerome Powell apparently learned nothing from the Fed’s efforts of recent years. Maybe it’s his banking background. Banks make higher profits in periods of rising interest rates. It is no surprise that most bankers think that rising interest rates are desirable, even necessary, in a growing economy to prevent excessive inflation.

Since wealth begets wealth perpetual economic growth in the range of 5 to 10% should be attainable. China has grown at that rate for many years. It’s clear that it will not happen under Chairman Powell if he follows the advice of incompetent economists who want three or four rate increases this year and at least two more next year accompanied by a faster reduction in the Fed’s balance sheet. Such actions will choke off the growth and are likely to cause short term interest rates to exceed long term rates. Economists debate whether an interest rate inversion will cause a recession. Why foolishly create the risk?

Interest is the cost of money. The higher the rate, the greater the cost of funding business operations,  including the cost of capital investments and carrying inventory and receivables. It will also over a few years have a devastating impact the cost of carrying our $20 trillion National Debt as the debt rolls over at higher rates. Rising interest rates will as usual CAUSE, not PREVENT, inflation by pushing up costs and lead our economy into the much-anticipated recession. Interest rates should at all times be kept at or below the desired rate of inflation. By doing so and controlling its balance sheet the Fed can (assuming sound fiscal policy and adequate regulation of banks and excessive risk) avoid future recessions.  Eliminating recessions, minimizing interest payments on the National Debt and maximizing economic growth should be added by Congress to the Fed mandates. Each is consistent with maintaining full employment. The Fed should be given the responsibility to react to events such as natural disasters or significant stock market declines or even a slowing of economic growth to keep the economy on a steady course.

The nonsensical talk about Fed independence is back in vogue. Of course the Fed should be independent to make its decisions. But, it does not act in a vacuum. It should invite criticism of its actions and be in constant contact with and coordinate its actions with Congress and Executive Branch.



Improving The Republican Tax Proposals

Dear President Trump,

I applaud many of the provisions of the proposed House and Senate tax proposals, but, as discussed below, the reduction or elimination of important deductions will result in unfair tax increases for too many taxpayers and may adversely effect the solvency of high tax states and the growth of the US economy. I fear that the current proposals, if  modified and passed into law, may cause almost as much harm as good to our economy. You can encourage Congress to find better ways to raise offsetting revenue than by eliminating important deductions. This letter will suggest changes to improve the tax proposals by eliminating current loopholes that let many of our most successful individuals avoid paying hundreds of billions of taxes during their lifetimes. I know it is late in the process and that time is of the essence, but I expect there will be almost immediate approval of  the suggested changes. I believe that if the proposed changes are adopted at your suggestion they will be recognized as the major accomplishment of your presidency by making the tax code fairer and enable you to achieve your goals of greatly accelerating the growth of the economy and helping the middle class.

1. THE PROPOSED LIMITATION OR ELIMINATION OF THE HOME INTEREST AND PROPERTY TAX DEDUCTION. I consider the elimination or reduction of deductions for home mortgage interest and property taxes to be the most unjustifiable change. By allowing depreciation of rental properties and not private homes, the tax code currently favors renting over home ownership. The proposed changes compound the unfairness. Prior to the collapse in home values caused in large part by improvident or fraudulent lending practices, owning a home was a major source of wealth accumulation by the middle class as one’s home mortgage was repaid over time and the home value rose due to inflation. Young families today are beginning to rediscover the wonderful benefits of home ownership and the economy has benefitted. The reduction of the tax benefits for home ownership will make it much more difficult financially to purchase and meet the monthly costs of owning a home. It will also significantly reduce the equity value of current homeowners and cause great harm to the home building, maintenance and improvement industries and lead to reduced funding for public school education. It will result in the loss of millions of middle class jobs. We must find a better way to pay for the tax reductions contained in the current proposals even if it means raising the corporate rate to 21% or 22%. Property taxes and interest on mortgages up to at least $1,000,000 should remain deductible.

2. RAISING THE ESTATE TAX CREDIT OR ELIMINATING THE ESTATE TAX. Raising the Estate Tax Credit as proposed or even to eliminate the Federal Estate Tax on estates of spouses with aggregate estates of up to $25 million or $50 million is a good idea to protect family businesses and farmers. But, eliminating the Federal Estate Tax is likely to be political suicide for Republicans. You will be endlessly criticized for giving an enormous and unjustifiable benefit to our richest taxpayers, including you. The richest people in our country are among the most under-taxed. Their aggregate income and wealth that is growing by hundreds of billions of dollars per year is in the form of unrealized capital gains that are not taxed for valid reasons. Our wealthiest people, many of whom will probably be worth well over $100 billion at the time of their death, also avoid federal gift or estate taxation by making large charitable gifts or by creating charitable foundations. We should either deny the charitable deduction for estates or otherwise taxable gifts or provide for a capital gains tax to be payable at death or at designated dates (such as every three or  five years after the change is passed) or by individuals at the time they make charitable gifts of appreciated property. We could provide for such tax to be payable in kind or over a period of years. The assets paid to the government in kind could be non voting while held by the government and be redeemable or sold over time. The rate of tax should be open for discussion, but the amount of the tax should be very significant and allow for most of the deductions being targeted for elimination to be retained. Just think of the US government as one of the largest shareholders of Berkshire Hathaway, Microsoft or Amazon. I do not think Warren Buffett, Bill Gates or Jeff Bezos will object. Tax deductible contributions will be reduced, but mainly be reducing the size of charitable gifts by an amount equal to the current tax underpayments. Eliminating the estate tax might also reduce charitable gifts.

3. REDUCING THE TAX ON PASS-THROUGH ENTITIES. This is also a questionable change favoring the rich. C Corporations pay a tax on net income (after deducting salaries paid that are taxed at individual tax rates) and stockholders pay a SECOND tax on dividends paid. Pass through entities avoid double taxation and they do not need the added benefit of lesser rates. If a C Corporation is more favorable, a Subchapter S Corporation or LLC can convert to a C Corporation.

4. TAXING THE CARRIED INTEREST. After years of discussion your wall street advisers left taxing of the carried interest out of the tax proposal. The amount recovered may not be great, but closing a loop-hole is important for tax fairness. It should have been included with appropriate relief for illiquid positions, such as permitting payment of the tax over time or in kind.

5. THE ELIMINATION OF THE SALT DEDUCTIONS. States with high income tax rates are already losing high income taxpayers to no income tax states. Some of them currently face insolvency. The elimination of SALT deductions causes a sudden change that is unfair to people who relied on the SALT deductions and bought homes and created business in high tax states. As discussed above, most, if not all, of the lost revenues from the rate reductions could be recovered by fairly taxing the unrealized gains of the super-rich and by properly taxing carried interests and pass-through entities. Limiting the SALT deductions to an amount such as 5% of taxable income may be needed to offset a portion of the proposed reduced tax revenues, and such limit should be phased in if possible and the middle class exemptions should be enlarged.

6. ENCOURAGE WAGE INCREASES BY OFFERING A FIRST YEAR TAX CREDIT FOR WAGE INCREASES OF LOWER PAID EMPLOYEES. We are permitting corporations to bring back trillions of dollars of funds parked overseas. Some of it will be spent on capital investments, but most of it will be used for dividends and stock buy-backs unless we encourage middle class wage increases. We could generate much higher GDP growth by giving employers a first year tax credit for wage increases to employees except for the top 10% of wage earners. Such credit would be lost if the wage increases were not continued during the next year. Including such a tax credit may prove to be revenue positive over ten years since it will grow the economy and increase individual incomes.


Stephen Feinberg

Approving and Improving the Kudlow, Moore, Laffer and Forbes Tax Proposal

Kudos for the Kudlow, Moore, Laffer and Forbes “Three Easy Pieces” tax proposal. However, the depreciation change is unnecessary and unrealistic and the tax rate is probably better at 20% or even 22%. I suggest a 4th piece, namely a 100% tax credit for the 1st year of all wage increases except for increases to the top 20%. Otherwise expect most of the earnings growth from tax savings to go to dividend increases, stock redemptions and increased compensation for executives as has been the main use of earnings growth in recent years.

Interest Rate Lunacy

The Obama administration missed an opportunity to extend the term of the US Debt. Each 1% increase in interest rates on the US Debt will soon cost our government $200 billion per year. Janet Yellen babbles on about unemployment, inflation and normalization of interest rates. She ignores the overriding need to keep interest rates as low as possible. The June increase in rates was a major mistake.