2008年金融危机中全球几大央行的货币互换绝对不能被当作常态，真正的常态是1998年的亚洲各国遭遇的情景，没有哪个国家能用本币从联储互换到美元，他们的人民遭遇的只有苛刻的条件和傲慢的拒绝

作者：季天鹤，万门大学CFO，央行观察特约专栏作家

2015年3月8日由公众号“央行观察”发表的《外汇储备不是税，那是啥？》以及3月28日发表的《划拨外汇储备能否崩坏央行资产负债表》讨论了人民银行和外汇局三点反对无偿划拨外汇储备的理由中的两点，即“外汇储备来源和税收不同”与“划拨外汇储备会引发资产负债表的不平衡”。本文试图讨论最后一点，即外汇局所说的“将外汇储备无偿划拨给国内经济部门使用，由于在国内不能使用美元等外汇储备货币，这些部门必须将外汇进行二次结汇，这相当于再次增加了货币投放，带来通货膨胀压力”。

为了说清这一问题，我们先来讨论结汇这一操作。

客户持美元纸币来银行结汇。银行资产侧增加美元纸币，负债侧增加人民币存款，而客户资产侧减少美元纸币，同时增加人民币存款。若其他条件不变，一笔人民币存款被创造出来，也就是实现了货币投放。如果客户取出人民币纸币，则银行总资产回到结汇前的规模，银行资产侧人民币纸币减少而美元纸币增加，而对客户资产侧减少美元纸币增加人民币纸币。如果银行想保持原有的人民币纸币的合意水平，那么银行需要向央行借入人民币纸币或将资产（比如美元纸币）售与央行换取人民币纸币。

但银行将美元纸币售与央行换取人民币纸币的过程不同于银行客户将美元纸币售与银行换取人民币纸币的过程，因为作为央行负债的人民币纸币是银行与其客户的资产。银行与客户的外汇纸币交易不会导致银行资产增加，但银行和央行的外汇纸币交易会导致央行扩大资产负债表，所以银行与央行的上述交易本质是一种结汇而非买卖。央行当然可以选择卖出其他资产换取外汇，例如国债和对其他银行债权等，但直到2015年1月底，上述非外汇资产仅约6万亿人民币，远不及27万亿的外汇占款。因此，外汇流入的迅猛势头，决定了央行只能以扩大负债的方式吸纳外汇，而不能以减少其他资产的方式持有。而且，即使央行有足够的国债用于出售，由于上述例子里银行需要纸币满足客户需要，央行必须创造出人民币纸币给银行，出售国债不能解决问题。

如果客户不提取人民币纸币而仅停留在人民币存款这一步，我们会发现银行的准备金率下降了，因为人民币存款增加但人民币准备金存款不变。在其他条件不变的情况下，结汇这一操作增加了银行体系对准备金存款的需求。央行可以通过借贷（增加债权和准备金存款）或者结汇（增加外汇和准备金存款）解决，也还可以降低准备金率。如果通过降低准备金率的方式解决，那么银行目前持有的22万亿准备金头寸以及对央行的6500亿债权就都是外汇头寸，央行的资产负债表也会比现在小22万亿（剩下的约5万亿外汇占款应该对应了5万亿纸币）。考虑到目前110万亿左右的存款，银行的准备金率恐怕在低于1%的水平。

如果出口商不通过银行结汇而是和其他非金融机构直接进行交易，那么或者人民币升值速度会快很多，或者大量境内交易美元化，而这两者都是央行不愿意看到的。银行可以通过出售资产（例如贷款，国债）从而在总资产不变的情况下增持外汇，但市场上还没有大规模的资产证券化或债券投资基金，于是银行只能通过增加人民币存款的方式接盘。然而，无论是出售资产还是扩张负债，在央行希望的升值速度下，银行都会累积庞大的外汇头寸，但银行也不会愿意也无法承受美元贬值的损失，因为银行没有央行那样的会计特权，于是就需要央行干预。

但如上所述，央行也没有足够的资产出售，结果就是央行也只能扩张负债发行准备金存款，但准备金存款增速高于央行希望的货币量增速，于是准备金率不断提高，银行资产侧持有大量准备金存款而非外汇，央行资产负债表也大幅度扩张，形成了今天的局面。市场似乎从来没有把央行和商业银行出售资产换取外汇的选项严肃考虑过，但财政部却在2007年建立中投的过程中让央行增持国债而减持外汇，总资产不变，这是央行近年来做过的唯一一笔外汇买卖，其它都是央行结售汇。

下面我们来讨论二次结汇。

当央行支付外汇储备时，无论是用于购买国外资产或用于国外消费，还是购买国内资产或用于国内消费，外汇收入方得到外汇都可以找银行结汇。因此，即使没有划拨，二次结汇也会发生。外汇局声称“外汇储备资金必须在境外投资和运用，国内转移时不能无偿拨付，并且需要严格防止二次结汇”，但人民币有离岸市场，境外主体收到外汇储备也可以结汇。随着资本项放开，境外主体也可以将收到的外汇储备汇入国内结汇，或者把国外结汇后的人民币汇入国内。因此，即使在境外运用，二次结汇也会发生。

划拨的真正问题其实就在于划拨本身。货币总量由银行存款负债和央行纸币负债构成，而形成原因是结汇和放贷。在去杠杆中，对外汇市场而言，对汇率压力最小的情况是放贷产生的货币在归还贷款的过程中相互消除而不是换取美元，但依然剩下一些货币对应外汇。由于商业银行之前找了央行结汇，所以如今能做的就是从央行处购汇，或者直接使储户成为准备金存款的持有者。乍一看，央行只要把自己持有的外汇储备给准备金存款的持有者，就完成任务了。但问题出现在价格上：外汇储备和由结汇产生的准备金存款到底以怎样的价格对应？

这就是我在《划拨外汇储备能否崩坏央行资产负债表》中讨论的问题。外汇占款和准备金存款在央行结汇的时候同时等量产生，外汇占款是投放人民币准备金存款的加总结果，但外汇储备除了结汇产生的外汇外还有收益以及价值变动，所以目前已经是一个3.8万亿美元外汇储备对应27万亿外汇占款的格局，因此上述准备金存款的持有者只能以7.1的价格兑换美元。如果划拨外汇储备，相当于人民银行资产侧减少外汇的时候没有任何负债项的相应减少，即使在资产负债表上外汇占款不变，准备金存款也不变，但外汇储备是确确实实地减少了。

划拨外汇储备没有消除人民币，而二次结汇则以市价（例如1美元兑换6.2人民币）创造人民币。因此，如果3.8万亿外汇储备全部被划拨，然后又二次结汇产生了23.5万亿人民币，央行重新持有3.8万汇储备，那么即使所有的贷款都有序地变成了相互的债权，随贷款产生的存款全部消失，我们会发现对应3.8万亿外汇储备的不会是27万亿外汇占款，而是50.5万亿外汇占款，这个时候的兑换价格就只能是13.3人民币兑换1美元，央行稳定外汇市场的能力大幅削弱。

所以划拨的根本问题不在于资金来源、资产负债表或者二次结汇，而在于划拨本身没有收回任何的人民币或者其他能够收回人民币的资产（比如国债），从而导致的风险，是一种不在现在而在未来会发生的问题。不光是划拨，消费或者缺乏流动性的投资也都会产生同样的问题，其中投资虽然不影响帐面的资产金额，但流动性却少了。当然会有人说，本来货币量就超过110万亿，如果纷纷挤兑美元，央行定然招架不住，何况银行可以发放贷款创造更多人民币去挤兑央行的美元。但我认为，并不能说央行无论如何也招架不住，就认为划拨了央行的外汇储备也无所谓。

外汇储备和黄金的特点在于本国央行无法任意扩大数量。四大行即使全面技术性破产，由于有央行的流动性支持，永远不会被挤提倒闭。只要央行资产侧增持国债，负债侧增计政府存款，国家财政发行国债获得的“人民币占款”就永远可以划拨出去。但外汇缺乏和黄金缺乏都不能通过本国央行记账解决，前者需要外国央行的恩准，后者需要地球的配合。因此古往今来，外汇和黄金问题的结局一般都是本币贬值或者放弃兑换。2008年金融危机中全球几大央行的货币互换绝对不能被当作常态，真正的常态是1998年的亚洲各国遭遇的情景，没有哪个国家能用本币从联储互换到美元，他们的人民遭遇的只有苛刻的条件和傲慢的拒绝。

The currency swaps between major central banks during the 2008 financial crisis cannot be considered the norm. The real norm was the situation faced by Asian countries in 1998. No country could exchange its own currency for US dollars with the Federal Reserve. Instead, they encountered strict conditions and arrogant refusals.

Articles published on March 8th and 28th, 2015, by the public WeChat account "Central Bank Observation" discussed two of the three reasons why the People's Bank of China (PBOC) and the State Administration of Foreign Exchange opposed the gratuitous transfer of foreign exchange reserves. These reasons were "the different sources of foreign exchange reserves and taxes" and "the imbalance in the central bank's balance sheet caused by the transfer of foreign exchange reserves." This article aims to discuss the last point, which is the concern raised by the State Administration of Foreign Exchange: "If foreign exchange reserves are gratuitously transferred to domestic economic entities for use, since foreign exchange reserves cannot be used domestically, these entities must undergo secondary foreign exchange settlement, which effectively increases currency issuance and brings inflationary pressures."

To address this issue, let's first discuss the concept of foreign exchange settlement.

A customer brings US dollar banknotes to a bank for foreign exchange settlement. On the bank's asset side, US dollar banknotes increase, while on the liability side, Chinese yuan deposits increase. For the customer, their assets decrease in US dollars, while their assets in Chinese yuan deposits increase. Assuming other conditions remain constant, this process results in the creation of Chinese yuan deposits, which means currency issuance occurs. If the customer later withdraws Chinese yuan banknotes, the bank's total assets return to the size they were before the foreign exchange settlement. On the bank's asset side, Chinese yuan banknotes decrease while US dollar banknotes increase. For the customer, their assets decrease in Chinese yuan banknotes, and their US dollar banknotes increase. If the bank aims to maintain the same level of Chinese yuan banknotes, it would need to borrow Chinese yuan banknotes from the central bank or exchange assets (such as US dollar banknotes) with the central bank for Chinese yuan banknotes.

However, the exchange of US dollar banknotes for Chinese yuan banknotes between the bank and its customers is different from the exchange of foreign exchange banknotes between the central bank and commercial banks. This is because the Chinese yuan banknotes held by the central bank as a liability are assets for the banks and their customers. While the exchange of foreign exchange banknotes between the banks and their customers doesn't lead to an increase in the bank's assets, exchanges between the central bank and commercial banks do expand the central bank's balance sheet. Therefore, the foreign exchange transactions between the central bank and commercial banks can be seen as foreign exchange settlement, rather than simply buying and selling. Although the central bank can choose to sell other assets, such as government bonds or claims on other banks, until the end of January 2015, the amount of these non-foreign exchange assets was only about ¥6 trillion, far less than the ¥27 trillion in foreign exchange deposits. Thus, due to the rapid inflow of foreign exchange, the central bank could only absorb it by expanding its liabilities, as it lacked the option to reduce other assets. Furthermore, even if the central bank had sufficient government bonds to sell, because banks would need banknotes to meet customer demand, the central bank would have to create Chinese yuan banknotes to satisfy banks. Selling government bonds wouldn't solve the problem.

If the customers don't withdraw Chinese yuan banknotes and leave them in Chinese yuan deposits, the bank's reserve requirement ratio decreases, as Chinese yuan deposits increase without an equivalent increase in Chinese yuan reserves. Assuming other conditions remain constant, this leads to an increased demand for reserves in the banking system due to foreign exchange settlement. The central bank can solve this by lending (increasing claims and reserves) or through foreign exchange settlement (increasing foreign exchange and reserves). Alternatively, it can lower the reserve requirement ratio. If it does so, the Chinese yuan banknotes generated by previous foreign exchange settlement processes will be closer to the required reserves, and the other part will turn into excess reserves. Assuming the conditions remain unchanged, the additional Chinese yuan banknotes generated by the foreign exchange settlement process will lead to a decrease in the reserve requirement ratio, which results in the expansion of bank lending.

If export businesses directly trade with non-financial institutions abroad instead of exchanging with banks, either the Chinese yuan's appreciation will accelerate significantly, or a large volume of transactions will be dollarized domestically. Both of these outcomes are undesirable for the central bank. The banks can increase their foreign exchange holdings by selling assets (such as loans or government bonds) while keeping their total assets constant. However, the market lacks significant asset securitization or bond investment funds. Therefore, banks can only expand their balance sheets by increasing Chinese yuan deposits. Regardless of whether banks sell assets or expand their liabilities, under the central bank's desired exchange rate, they will accumulate significant foreign exchange positions. However, banks won't be willing or able to withstand losses due to a potential depreciation of the US dollar, as they don't possess the same accounting privileges as the central bank. As a result, the central bank will have to intervene.

However, as mentioned earlier, the central bank also lacks sufficient assets to sell. Consequently, the central bank can only expand its liabilities by issuing required reserve deposits. However, if the growth rate of required reserves is higher than the central bank's desired growth rate of the money supply, the reserve requirement ratio will keep increasing. This will result in banks holding a large amount of required reserves instead of foreign exchange on the asset side, and the central bank's balance sheet will expand significantly. This has led to the current situation. It seems that the market has never seriously considered the option of the central bank and commercial banks selling assets to exchange for foreign exchange. However, the Ministry of Finance did make the central bank increase its government bond holdings and reduce foreign exchange holdings during the establishment of the China Investment Corporation in 2007. The total assets remained unchanged. This is the only foreign exchange transaction the central bank has conducted in recent years; the rest have been foreign exchange settlements.

Now let's discuss the concept of secondary foreign exchange settlement.

When the central bank pays foreign exchange reserves, whether it's for purchasing foreign assets, overseas consumption, domestic asset purchases, or domestic consumption, the recipient of foreign exchange reserves, whether abroad or at home, can choose to exchange these reserves for their domestic currency. Therefore, even without gratuitous transfers, secondary foreign exchange settlement can still occur. The State Administration of Foreign Exchange claims that "foreign exchange reserve funds must be invested and used overseas. Gratuitous transfers domestically cannot occur, and we need to strictly prevent secondary foreign exchange settlement." However, the Chinese yuan has an offshore market, and entities abroad receiving foreign exchange reserves can still engage in foreign exchange settlement. With the gradual opening of the capital account, offshore entities can also transfer their received foreign exchange reserves domestically for settlement, or they can repatriate the Chinese yuan obtained from foreign exchange settlement abroad. Thus, secondary foreign exchange settlement can still occur even when foreign exchange reserves are utilized overseas.

The real issue with gratuitous transfers lies in the transfers themselves. The total amount of currency is composed of bank deposit liabilities and central bank currency liabilities, and it is created through foreign exchange settlement and lending. During the process of deleveraging, in terms of the foreign exchange market, the least pressure on the exchange rate comes from loans leading to currency issuance, which is used to repay the loans rather than exchanging for US dollars. Nevertheless, some currency corresponding to foreign exchange still remains. As the commercial banks had previously exchanged with the central bank, the only option left now is to purchase foreign exchange from the central bank or directly make deposit holders holders of required reserves. At first glance, if the central bank transfers its foreign exchange reserves to holders of required reserves, it would accomplish its goal. However, the problem arises with the exchange rate: how should foreign exchange reserves be priced against the Chinese yuan?

This is the issue discussed in "Can Gratuitous Transfer of Foreign Exchange Reserves Collapse the Central Bank's Balance Sheet?" The foreign exchange deposits and required reserves are created simultaneously during central bank foreign exchange settlement. Foreign exchange deposits are the result of injecting Chinese yuan as required reserves. However, foreign exchange reserves not only include the foreign exchange generated by foreign exchange settlement but also include profits and changes in value. As a result, there is currently a pattern where $3.8 trillion in foreign exchange reserves corresponds to ¥27 trillion in foreign exchange deposits. Thus, the holders of required reserves mentioned earlier can exchange their required reserves for US dollars at a rate of 7.1. If foreign exchange reserves are transferred, it means that when the central bank's asset side decreases foreign exchange, there is no corresponding reduction in liabilities. Although the foreign exchange deposits and required reserves remain unchanged on the balance sheet, the foreign exchange reserves have indeed decreased.

Gratuitous transfers of foreign exchange reserves don't eliminate the Chinese yuan. Secondary foreign exchange settlement, on the other hand, creates Chinese yuan at market rates (e.g., 1 US dollar to 6.2 Chinese yuan). Therefore, if the $3.8 trillion in foreign exchange reserves were transferred and secondary foreign exchange settlement generated ¥23.5 trillion, and the central bank once again holds $3.8 trillion in foreign exchange reserves, we would discover that instead of ¥27 trillion in foreign exchange deposits corresponding to the initial foreign exchange reserves, it would be ¥50.5 trillion. At this point, the exchange rate would be 13.3 Chinese yuan to 1 US dollar, significantly weakening the central bank's ability to stabilize the foreign exchange market.

So, the fundamental issue with gratuitous transfers lies not in the source of funds, the balance sheet, or secondary foreign exchange settlement, but in the transfers themselves, which do not reclaim any Chinese yuan or other assets that can be reclaimed for Chinese yuan (such as government bonds). This leads to a future risk that may not be immediate but will eventually occur. Not only gratuitous transfers but also consumption or illiquid investments can create the same issue. While investments may not affect the asset amount on paper, liquidity is reduced. Of course, some might argue that the money supply is already over ¥110 trillion, and if there is a rush to convert to US dollars, the central bank would inevitably struggle, especially since banks can create more Chinese yuan to exchange for the central bank's US dollars. However, I believe that we cannot simply assume that the central bank is unable to handle the situation and that gratuitous transfers of foreign exchange reserves wouldn't matter.

Foreign exchange reserves and gold are characterized by the fact that the domestic central bank cannot arbitrarily expand their quantities. Even if the four major banks were to undergo a comprehensive technical bankruptcy, with the support of the central bank's liquidity, they would never be pushed to insolvency. As long as the central bank increases its holdings of government bonds and increases its liability to the government, the "Chinese yuan deposits" obtained through the issuance of government bonds can always be transferred. However, both foreign exchange and gold lack the ability to be expanded by a domestic central bank's accounting alone. The former requires the approval of foreign central banks, while the latter requires coordination on a global scale. As a result, throughout history, the conclusion to both foreign exchange and gold problems has generally been either currency depreciation or the abandonment of convertibility. The currency swaps among major central banks during the 2008 financial crisis cannot be considered the norm; the true norm was the situation faced by Asian countries in 1998. No country could freely exchange its currency with the Federal Reserve. Instead, they faced demanding conditions and arrogant refusals.