Showing posts with label econometrics. Show all posts
Showing posts with label econometrics. Show all posts

Sunday, May 17, 2026

Stagflation Part 6: The Banking System Under Siege—Bond Selloffs, Liquidity Illusions, and the Coming Balance Sheet Reckoning

  

Central bankers always try to avoid their last big mistake. So every time there's the threat of a contraction in the economy, they'll over stimulate the economy, by printing too much money. The result will be a rising roller coaster of inflation, with each high and low being higher than the preceding one—Milton Friedman 

In this issue:

Stagflation Part 6: The Banking System Under Siege—Bond Selloffs, Liquidity Illusions, and the Coming Balance Sheet Reckoning

I. Introduction: Markets Are Repricing the Stagflation Regime

II. Sovereign Repricing Is Becoming a Banking Problem

III. The Liquidity Boom Concealed Structural Fragility

IV. March 2026: Hidden Cost of Relief Measures

V. Bank Liquidity Improved—But Mainly Through Deposit Expansion

VI. The Wile E. Coyote’s Denominator Effect

VII. Sovereign Absorption, AFS Portfolios, and Hidden Duration Stress

VIII. Reflexivity: When Accommodation Starts Feeding Instability

IX. The Savings-Investment Gap: From Development Narrative to Stagflationary Dependence

X. Why the Oil Shock Broke Mainstream Models

XI. The Banking Contradiction: Why System Normalization Is a Mirage

XII. Conclusion: Accommodation Without Resolution Redux 

Stagflation Part 6: The Banking System Under Siege—Bond Selloffs, Liquidity Illusions, and the Coming Balance Sheet Reckoning 

How inflation, sovereign dependence, and financial repression are turning banks into the shock absorbers of a stagflationary regime. 

I. Introduction: Markets Are Repricing the Stagflation Regime 

On Friday, May 15, 2026, the USDPHP closed at a record 61.721—another historic low for the peso and its 16th record high of the year. Every prior “comfort level” for the currency has effectively been erased. The peso is now among Asia’s worst-performing currencies year-to-date. 

Yet the peso’s decline may not even be the most important market signal.


Figure 1

Far more consequential is the ongoing repricing inside the domestic bond market. BVAL Treasury yields—particularly at the belly of the curve—have surged beyond prior cycle highs, while longer-dated maturities are rapidly approaching 2022 stress levels (Figure 1) 

The move no longer resembles a temporary inflation scare or speculative overshoot. Markets are increasingly repricing sovereign, inflation, and currency risk simultaneously. 

The distinction matters. 

Peso weakness reflects external imbalance. But rising bond yields directly strike the balance sheets of the Philippine banking system.

Banks sit at the center of the country’s macro-financial structure. Backstopped by the BSP, they financed the pandemic rescue cycle, intermediated the post-pandemic liquidity surge, absorbed expanding government debt issuance, and enabled credit expansion into politically favored sectors. In the process, banks became increasingly exposed to the very distortions created by the policies that artificially sustained nominal growth.

Mainstream narratives continue to describe the banking system as “well-capitalized,” “liquid,” and “resilient.” But these are largely backward-looking accounting conditions rather than forward-looking assessments of systemic vulnerability.

The issue is not whether banks currently satisfy regulatory ratios. The issue is the sustainability of a macro-financial structure that has become increasingly dependent on continual liquidity accommodation, regulatory forbearance, and suppressed volatility to prevent the emergence of deeper systemic stress.

That is the deeper significance of stagflation.

Stagflation is not merely the coexistence of inflation and slowing growth. It is the progressive collision between inflation persistence, fiscal dependence, external fragility, and financial leverage.

And in the Philippines, those pressures are increasingly converging on the banking system.

II. Sovereign Repricing Is Becoming a Banking Problem 

Much of the recent discussion surrounding Philippine market turbulence has focused on USDPHP. But the more consequential development may be occurring inside the domestic bond market. 

The scale of the Philippine bond selloff is not background noise. It is the primary transmission mechanism through which macroeconomic stress migrates into bank balance sheets


Figure 2

Philippine Treasury securities have been among Asia’s worst-performing bonds in 2026 following the Iran War, with Philippine 10-year yields rising the most among ASEAN bonds. (Figure 2, top and middle windows)

Ironically, this deterioration has unfolded even as the Philippines prepares for inclusion in the JP Morgan Emerging Market Debt Index in January 2027. Would JPMorgan issue a downgrade? 

The significance of the selloff is frequently misunderstood.

For banks, rising yields are not merely inconvenient market fluctuations. Higher yields translate directly into mark-to-market losses, duration stress, weaker securities valuations, and tighter liquidity conditions.

This matters because Philippine banks substantially increased exposure to government securities beginning in 2015, with the trend accelerating during the pandemic era. Banks’ net claims on the central government (NCoCG) rose, alongside public debt hitting all-time highs last March with NCoCG at PHP 6.258 trillion accounting for 33% of the PHP 18.488 trillion public debt. (Figure 2, lowest image)

The pandemic response institutionalized a regime in which: 

  • fiscal deficits exploded,
  • BSP liquidity injections surged,
  • banks absorbed massive sovereign issuance,
  • and government debt became increasingly embedded as collateral throughout the financial system. 

That framework functioned as long as: 

  • inflation remained politically manageable,
  • the peso avoided disorderly depreciation,
  • and yields stayed artificially suppressed.

Stagflation changes the equation.

Persistent inflation forces markets to demand higher nominal yields. External fragility pressures the currency. Fiscal dependence requires continual debt issuance even as government borrowing increasingly crowds out private credit formation. Every upward move in yields simultaneously erodes the market value of existing bond holdings. 

This is why the present environment matters. 

  • The repricing is occurring precisely when: 
  • public debt remains elevated,
  • fiscal deficits remain structurally wide,
  • external financing conditions are tightening,
  • and growth quality is deteriorating.

In effect, banks are becoming trapped between sovereign financing dependence and market repricing. 

The system cannot easily tolerate market-clearing yields because the fiscal structure, banking system, and asset markets have all become deeply dependent on suppressed financing costs.

Yet suppressing yields amid inflation and peso weakness merely transfers pressure into currency depreciation, financial repression, and deeper balance-sheet distortions.

This is the core contradiction of financial repression

The state increasingly depends on banks to intermediate expanding sovereign debt burdens even as inflation and currency weakness steadily erode the real foundations supporting those balance sheets.

III. The Liquidity Boom Concealed Structural Fragility

The banking pressures now emerging did not appear spontaneously. They were incubated even before the post-pandemic liquidity cycle.

For years, policymakers and mainstream economists treated liquidity expansion as a stabilizing force. Rapid M2 and M3 growth were interpreted as signs of recovery, resilience, and normalization.


Figure 3

Credit (domestic claims) and liquidity (M2) expansion as a share of GDP have been rising since 2011, accelerated in pre-pandemic 2019, and have since reached key milestones. The GDP’s ever-deepening dependence underscores bank-led financialization, even as the GDP rate continues downward path. (Figure 3, topmost pane)

But liquidity creation is NEVER neutral.

The critical issue is not simply the quantity of money creation, but where newly created liquidity enters the system first and how credit allocation is shaped by political and institutional incentives.

In classic Cantillon effect-fashion, the earliest beneficiaries of post-pandemic liquidity expansion were sectors closest to BSP’s sovereign financing and bank credit intermediation—the primary sources of money creation. 

Liquidity increasingly flowed into: 

  • government financing,
  • real estate carry structures,
  • politically connected infrastructure,
  • speculative financial activities,
  • electricity and utility-related lending,
  • and consumer leverage amplified by credit card rate caps.

As a result, credit card lending surged even as household purchasing power weakened. 

Electricity and utility-related lending climbed sharply since 2024 despite deteriorating GDP. (Figure 3, middle graph) 

Consumer finance became one of the banking system’s primary growth engines since the pandemic even as real wage pressures intensified. (Figure 3, lowest diagram) 

This created the appearance of nominal resilience.

But much of the expansion reflected liquidity recycling rather than productivity-driven growth. The banking system increasingly functioned as a transmission mechanism for sustaining aggregate demand despite weakening real income conditions. 

That distinction is critical.

When economies rely on debt expansion to preserve consumption amid deteriorating purchasing power, balance sheets gradually become more fragile beneath the surface.

Stagflation magnifies this process because inflation compresses household cash flows while slowing real activity weakens repayment capacity.

Banks may initially report: 

  • strong nominal loan growth,
  • healthy net interest margins,
  • and stable headline balance-sheet conditions.

But over time, the quality of that growth deteriorates

The result is a system where: 

  • nominal lending remains elevated,
  • asset prices become increasingly policy-dependent,
  • and underlying credit quality quietly weakens beneath the surface.

This is why banking stress under stagflation is often delayed rather than immediate. 

Liquidity masks fragility for awhile. 

Then inflation, higher yields, and slowing real activity begin to expose it. 

IV. March 2026: Hidden Cost of Relief Measures 

The BSP’s April 2026 regulatory and loan relief measures—officially framed as emergency support for the oil shock—should not be interpreted as neutral policy tools

Relief regimes redistribute risk asymmetrically

Large banks, politically connected borrowers, and institutions with privileged regulatory access typically receive greater flexibility, balance-sheet protection, and time than smaller firms or ordinary households. In that sense, crisis accommodation functions not merely as stabilization policy, but as a mechanism that risks deepening moral hazard and reinforcing regulatory capture. 

This institutional structure matters because the BSP’s policymaking apparatus remains deeply intertwined with the banking establishment itself, populated largely by former executives from major domestic banks and multinational financial institutions

The issue is not necessarily conspiracy, but institutional incentive alignment: policymakers shaped by the same financial architecture they supervise will naturally tend to prioritize preservation of that structure. Experience and familiarity shapes incentives. Networks shape policy reflexes. Politically connected interest groups also shape policy trajectories. 

Against that backdrop, March 2026 marked the transition phase before the formal implementation of April’s relief measures. 

Echoing aspects of the pandemic playbook, banks were likely already repositioning balance sheets in anticipation of regulatory flexibility, liquidity support, prudential accommodation, and accounting relief.

V. Bank Liquidity Improved—But Mainly Through Deposit Expansion 

March banking data showed a modest improvement in headline liquidity conditions, though the rebound was driven primarily by deposit expansion rather than internally generated balance-sheet strengthening.


Figure 4

Cash and due from banks posted their first expansion since August 2024, lifting the cash-to-deposit ratio marginally from February’s record lows. Yet despite the rebound, liquidity buffers remained historically thin. (Figure 4, topmost image)

The apparent improvement largely reflected accelerating deposit growth.

Peso and FX deposits both strengthened during Q1, consistent with the sharp rebound in M2 and M3 liquidity growth. BSP accommodation had likely already begun filtering through the banking system even before the formal April relief package. (Figure 4, middle visual)

Yet beneath the headline stabilization, underlying liquidity conditions remained fragile.

Liquid assets-to-deposits continued drifting downward toward pre-rescue March 2020 levels, suggesting banks were still operating with structurally compressed liquidity cushions despite years of extraordinary accommodation.

The apparent stabilization therefore reflected funding inflows more than genuine liquidity resilience.

That distinction matters because stagflation eventually tests liquidity quality—not merely liquidity quantity.

VI. The Wile E. Coyote’s Denominator Effect 

March banking data appeared superficially stable. 

Headline nonperforming loan (NPL) ratios remained broadly steady. But this stability increasingly resembles what we have repeatedly described as the banking system’s Wile E. Coyote denominator effect—where deteriorating fundamentals become statistically obscured by rapid balance-sheet expansion. (Figure 4, lowest chart)

Gross nonperforming loans climbed to fresh record nominal highs in March or bad loans continued rising.

Denominator growth simply outran visible recognition or rapid Total Loan Portfolio (TLP) expansion temporarily compressed headline NPL ratios, masking the deterioration emerging underneath the surface.

Stable ratios can therefore conceal worsening underlying conditions.

The same pattern increasingly appeared in loan-loss provisioning.


Figure 5

Allowance for credit losses rose to near-record levels. At first glance, this appeared reassuring—a sign of prudence and reserve accumulation. (Figure 5, topmost chart)

But once again, denominator growth mattered.

Provisioning growth lagged behind TLP expansion, causing reserve ratios to soften despite intensifying macroeconomic stress.

This raises an increasingly uncomfortable question: 

Are provisions genuinely strengthening resilience, or merely struggling to keep pace with an increasingly leveraged and slowing credit structure? 

Under normal expansionary conditions, rapid credit growth can dilute emerging stress and stabilize reported metrics. 

But stagflation changes the equation. 

If slowing growth weakens repayment capacity while inflation compresses household cash flow, denominator support itself begins to weaken. 

That is when the Wile E. Coyote effect comes into play. It exposes the statistical artifice hidden behind the headline numbers. What once appeared statistically stable deteriorates rapidly once loan growth slows and hidden losses become harder to dilute. 

Like Wile E. Coyote, once he realizes he has run far past the cliff, gravity takes hold. 

VII. Sovereign Absorption, AFS Portfolios, and Hidden Duration Stress 

The sovereign absorption trade also intensified.

Banks continued aggressively accumulating government-linked assets, reinforcing the increasingly symbiotic relationship between fiscal deficits and bank balance sheets.

Held-to-Maturity (HTM) securities presently reclassified as “Debt Securities- Net of Amortization” climbed to record highs, reflecting continued sovereign intermediation. HTMs accounted for 67% of NCoCG. (Figure 5, middle chart)

At the same time, Available-for-Sale (AFS) portfolios surged sharply. (Figure 5, lowest diagram)

On paper, rising securities holdings appear consistent with liquidity strength.

Under stagflation, however, they increasingly become a source of vulnerability.

The recent repricing in Philippine Treasury yields—particularly at the belly of the curve—directly pressures AFS portfolios through mark-to-market losses. 

This creates a predictable institutional response.

Banks increasingly face incentives to migrate securities toward HTM classification, where unrealized market losses avoid immediate recognition.

But this merely alters accounting treatment.

It does not eliminate duration risk.

HTM migration may suppress accounting volatility, but it also reduces balance-sheet flexibility by locking assets into longer-duration structures that become less liquid under stress. 

In effect, banks increasingly face a tradeoff between accounting stability and actual balance-sheet resilience. 

Signs of strain are already beginning to emerge beneath headline stability.


Figure 6

Banking sector’s income growth remained near stagnation in Q1 2026, rising only 2.86%, as accumulated market losses continued suppressing profitability. Financial market-related losses remained elevated at roughly Php 43.5 billion—persistently sustained since Q2 2025 and approaching pandemic-era stress peak levels recorded in Q4 2020. (Figure 6, topmost pane)

At the same time, balance-sheet pressures intensified. Despite record investment holdings, accumulated foreign exchange and fixed-income valuation losses surged toward Php 120 billion in March, revisiting conditions last seen during the December 2022 repricing cycle. Valuation losses have accompanied the spike in 10-year yields. (Figure 6, middle chart)

At the same time, dependence on wholesale funding continued rising, with bank borrowings reaching fresh record highs in March. (Figure 6, lowest graph)

These developments matter because they suggest the banking system entered the oil-shock phase already carrying unresolved vulnerabilities—even before the full effects of stagflation have emerged.

VIII. Reflexivity: When Accommodation Starts Feeding Instability 

The deeper problem is that banking conditions are becoming increasingly reflexive.

  • BSP accommodation boosts liquidity.
  • Banks expand nominal credit.
  • Credit growth reinforces inflation persistence.
  • Inflation pressures bond yields higher.
  • Higher yields weaken securities portfolios.

Banks then become increasingly dependent on regulatory relief, accounting migration, and additional liquidity support to preserve stability.

Authorities subsequently face pressure to deliver even more accommodation to prevent broader financial stress.

Rather than resolving fragility, accommodation increasingly delays recognition while compounding the imbalances generating the stress itself.

This is why March 2026 matters.

The banking system did not enter the oil-shock phase from a position of clear strength.

It entered with:

  • thin liquidity cushions,
  • rising sovereign exposure,
  • growing duration risk,
  • weakening profitability quality,
  • and balance sheets increasingly dependent on denominator growth to suppress visible deterioration.

In that sense, the BSP’s April relief measures do not represent resolution. 

They may instead buy time at the cost of deeper sovereign dependence, greater balance-sheet distortion, and the continued accumulation of unresolved imbalances

What emerges is not crisis resolution, but the institutionalization of permanent accommodation as the operating framework of the financial system. 

IX. The Savings-Investment Gap: From Development Narrative to Stagflationary Dependence


Figure 7

One of the least discussed yet the most critical indicator of the Philippine economy’s underlying fragility resurfaced in Q1 2026: the savings-investment (S-I) gap widened to Php 1.03 trillion, the largest in two years. (Figure 7, upper image)

At first glance, orthodox macroeconomic interpretation treats this as manageable—even desirable.

Weak private demand supposedly justifies larger public spending to sustain GDP growth.

Under this framework, government borrowing and expenditure become stabilizing tools: when households retrench and private firms hesitate, the state steps in as spender, borrower, allocator, and increasingly, guarantor of aggregate demand.

But this framing obscure deeper structural problems.

The S-I gap’s weakness as a framework begins with the fact that it is fundamentally an accounting identity: 

savings minus investment equals the current account balance. 

But accounting identities explain what balances, not whether the underlying structure generating those balances is sustainable. 

A widening S-I gap signals that domestic savings are increasingly insufficient to internally finance the economy’s investment requirements. 

That gap must be financed somehow:

  • domestic borrowing,
  • foreign borrowing,
  • monetary accommodation,
  • or inflationary erosion of purchasing power. 

In practice, the Philippines has increasingly relied on all four

Yet even the accounting itself deserves scrutiny. 

GDP-based national income statistics classify government construction and public expenditures as “investment” regardless of whether such projects satisfy market tests of profitability, cash-flow viability, or sustainable demand. 

Unlike private capital formation—disciplined by profit and loss—politically allocated spending often survives through taxation, subsidies, refinancing, regulatory privilege, or continued deficit support. 

That distinction matters. 

The deeper issue is not merely that investment exceeds savings. 

The issue is whether debt-financed and liquidity-supported investment generates sufficient productive capacity to repay the claims being created today. 

If not, the system gradually becomes dependent on:

  • continual debt issuance,
  • BSP accommodation,
  • financial repression,
  • inflation leakage,
  • and sustained regulatory interventions

simply to maintain nominal growth. 

This is where the government debt story becomes inseparable from the S-I gap. 

The Philippines increasingly appears trapped in a feedback loop where weak domestic savings require greater dependence on debt expansion, while debt-financed growth itself weakens incentives for genuine savings formation. 

Public debt may still appear manageable relative to advanced economies. 

But such comparisons are misleading.

The issue is not merely debt-to-GDP ratios. Q1 debt/GDP hit 65.2%—a 21 year high, although the Palace did raise their supposed ceiling/ debt metric to 70% last year. (Figure 7, lower graph) 

The issue is whether the economy possesses a sufficiently productive and self-sustaining capital structure capable of carrying rising debt burdens without continual intervention. 

Much of recent growth has increasingly depended on: 

  • public spending,
  • sovereign borrowing,
  • liquidity expansion,
  • credit-financed speculation and capital misallocation,
  • and consumption smoothing through leverage. 

Banks increasingly sit at the center of this arrangement.

As fiscal financing requirements expand, financial institutions absorb rising sovereign issuance, redirecting balance sheets toward government exposure. Domestic savings that might otherwise finance entrepreneurial activity and decentralized capital formation increasingly fund deficit spending instead. 

This is the sovereign-bank nexus. 

The more the state depends on debt expansion, the more banks become intertwined with fiscal sustainability itself. 

The result is not necessarily immediate displacement, but gradual crowding out through balance-sheet absorption. Capital increasingly flows toward politically backed financing channels rather than decentralized entrepreneurial allocation. Over time, this dynamic contributes to rising funding costs, weaker private-sector dynamism, and greater systemic dependence on policy support. 

This dynamic helps explain the coexistence of:

  • slowing real growth,
  • persistent inflation pressures,
  • weakening household balance sheets,
  • deteriorating external accounts,
  • peso weakness,
  • and repeated liquidity accommodation. 

The S-I gap therefore becomes more than a macroeconomic statistic. 

It represents a blueprint of the political economy’s development structure itself. 

The widening imbalance reflects an institutional preference for:

  • demand management over productivity reform,
  • centralized allocation over decentralized capital formation,
  • and short-term GDP optics over long-term savings formation. 

Under stagflationary conditions, these dependencies become progressively harder to sustain without some combination of:

  • higher inflation,
  • deeper financial repression,
  • currency weakness,
  • slower real growth,
  • or escalating policy interventions.

The irony is difficult to ignore. 

Policies justified as temporary stimulus to compensate for private-sector weakness may gradually become one of the mechanisms entrenching that weakness in the first place. 

X. Why the Oil Shock Broke Mainstream Models 

The recent Iran War oil shock exposed more than a forecasting error. It revealed a deeper epistemological problem embedded in mainstream macroeconomics—and the fragility of the broader economic structure underlying its models.

Consensus inflation forecasts largely treated price pressures as transitory and primarily supply-driven. Yet econometric models depend on assumptions of relatively stable relationships between variables derived from past statistical regularities. Under asymmetric policy intervention, regime shifts, and politically conditioned responses, however, the sequence and transmission of economic effects become nonlinear and unstable.

Here, Hayek’s knowledge problem resurfaces. Dispersed human adaptation cannot be compressed into static coefficients without losing critical information. Households, firms, banks, and investors continuously adjust behavior in response to policy signals, financing stress, and deteriorating expectations. Besides, aggregates don’t capture individual utilities.

Once BSP and government intervention themselves became dominant market variables—through FX defense, liquidity management, subsidies, emergency powers, and CPI-conditioned signaling—the system became increasingly reflexive. Forecasts influenced behavior, behavior altered transmission channels, and the assumptions underlying the forecasts deteriorated in real time.

This is also where Goodhart’s Law becomes relevant. Once CPI evolved into a political metric of credibility, policies increasingly targeted the appearance of price stability while structural imbalances accumulated elsewhere in the system. Statistical stability increasingly masked mounting financial and economic fragility.

The recent oil shock exposed how vulnerable this framework had become. 

Higher oil and electricity costs did not merely raise transport expenses. 

They cascaded throughout the economy by: 

  • weakening household cash flow,
  • compressing corporate margins,
  • increasing dependence on consumer credit,
  • and intensifying financing stress across sectors. 

Policymakers increasingly responded through: 

  • subsidies,
  • price suppression,
  • emergency powers,
  • regulatory accommodation,
  • and politically mediated financing mechanisms. 

But intervention does not eliminate scarcity or losses. 

It merely redistributes them across balance sheets. 

And much of that redistribution increasingly lands on: 

  • banks,
  • consumers,
  • currency markets,
  • and sovereign financing channels. 

This is why the EO-110 framework matters beyond energy policy. 

Once emergency intervention becomes normalized, financial systems gradually evolve toward permanent crisis management layered on top of earlier pandemic-era accommodation. 

Banks then cease functioning purely as market intermediaries. 

They increasingly become quasi-fiscal transmission mechanisms for stabilizing politically sensitive sectors and sustaining nominal demand. 

If inflation forecasting failed because intervention distorted price signals and altered transmission mechanisms, then the same critique increasingly applies to GDP interpretation itself. 

Again, macroeconomic models rely on assumptions of relatively stable relationships, functioning price signals, and coherent feedback mechanisms. But once policy intervention persistently reshapes incentives, suppresses market adjustments, and redirects capital flows, aggregate output statistics become progressively less reflective of underlying productive conditions. 

GDP then risks evolving from supposedly a “neutral and objective” measure of economic activity into a politically conditioned artifact of intervention-driven stabilization. 

XI. The Banking Contradiction: Why System Normalization Is a Mirage 

The contradiction facing the Philippine banking system is no longer merely financial. 

It is increasingly political, institutional, and macroeconomic. 

After years of liquidity support, sovereign absorption, and intervention-driven stabilization, policymakers increasingly face objectives that are difficult to reconcile simultaneously. 

Authorities want: 

  • growth without recession,
  • lower inflation without adjustment costs,
  • currency stability without external rebalancing,
  • rising public spending without disorderly debt repricing,
  • and a resilient banking system without materially tighter financial conditions.

But these objectives increasingly conflict. 

Containing inflation requires tighter liquidity conditions. 

Yet tighter liquidity risks slowing credit growth, exposing weaker borrowers, and amplifying stress in already leveraged sectors. 

Allowing yields to rise restores market pricing. 

But higher yields increase government financing costs while simultaneously eroding the value of bank-held sovereign securities. 

Supporting the peso may stabilize inflation expectations. 

But it also tightens financial conditions in an economy already dependent on credit expansion.

Meanwhile, renewed liquidity accommodation preserves short-term stability but reinforces inflation persistence and sovereign dependence.

The complexity of the feedback loops escalates. 

This is the banking contradiction of stagflation: 

the policy required to resolve one imbalance increasingly intensifies another. 

The Philippine banking system sits at the center of these tensions because it has become deeply embedded in: 

  • sovereign financing,
  • household leverage,
  • liquidity transmission,
  • and policy stabilization itself.

This is what distinguishes the current environment from a conventional credit cycle.

In normal downturns, banks primarily absorb credit losses.

Under stagflation, banks become transmission mechanisms for multiple overlapping pressures: 

  • inflation,
  • currency weakness,
  • fiscal dependence,
  • bond repricing,
  • and slowing real activity.

The result is not necessarily immediate instability.

The greater risk is policy paralysis driven by structural contradiction. 

Authorities increasingly rely on path dependent responses: 

  • selective tightening,
  • targeted relief,
  • expanded public spending,
  • liquidity support,
  • moral suasion,
  • shaping media narratives,
  • accounting flexibility,
  • and regulatory accommodation. 

But hybrid regimes rarely resolve underlying imbalances. 

They instead delay recognition while deepening structural dependence on future intervention. 

This is why “normalization” becomes progressively more difficult. 

The longer accommodation persists, the more balance sheets adapt to its presence. Imbalances accumulate. Risk becomes embedded in expectations. And even modest tightening can generate disproportionate stress.

That is the deeper trajectory of the current cycle. 

The question is no longer whether the banking system appears stable today. 

The question is whether it can reduce its dependence on a framework of continual accommodation, subsidy, and intervention—or whether that dependence eventually defines the limits of the system through disorderly adjustment. 

XII. Conclusion: Accommodation Without Resolution Redux 

The Philippine banking system is not facing an immediate crisis (yet). 

Headline capitalization remains intact. Liquidity has stabilized temporarily. Regulatory ratios still signal resilience. 

But stagflation rarely begins through sudden collapse. 

More often, fragility accumulates gradually beneath the surface, exacerbating existing imbalances while policy intervention delays recognition. 

This is increasingly the pattern now emerging. 

Rising sovereign dependence, widening savings deficiencies, credit-financed malinvestments, peso weakness, bond-market repricing, and slowing real growth are converging on the same balance sheets policymakers increasingly rely upon to sustain stability.

The contradiction is difficult to escape. 

Banks are expected to finance fiscal expansion, absorb duration risk, support credit growth, and remain resilient—all while inflation, external fragility, and political intervention steadily distort the price signals that normally discipline risk.

The danger is not merely weaker profitability or rising bad loans.

The greater risk is a system that becomes progressively dependent on continual accommodation simply to preserve the appearance of stability.

More concerning still is the INTENSIFYING POLITICIZATION of the industry as it is increasingly mobilized to serve the deepening financing needs of the state.

That is the deeper meaning of the current cycle.

The issue is no longer whether the banking system appears stable today.

The issue is whether the foundations sustaining that stability are becoming increasingly fragile beneath the surface.

The Philippine banking system may not yet be in crisis.

But it is increasingly operating under siege—and drifting toward one. 

___

References

Stagflation Is Already Here—Emergency Policies Are Now Entrenching It 

Stagflation by Design: Policy Contradictions and the Return of the Pandemic Rescue Playbook 

The Anatomy of Philippine Stagflation: BSP Rate Hikes, Record External Deficits, and Fiscal Expansion (Part 3) 

Stagflation Then and Now: Why Philippine Markets Are Repricing Like the 1970s (Part 4) 

Stagflation Part 5: The Q1 2026 GDP Illusion and the Gathering Recession Risk Beneath Price Suppression 

Seed Article:

EO-110 and the Politics of Price Suppression: How the Energy Emergency Is Becoming a Nationwide Economic Intervention


Sunday, June 28, 2020

BSP’s April 2020 FSR: PSE’s Soaring Debt-at-Risk, Bank and Financial Vulnerabilities, Risks of Re-Fitting of the Economy and More…



And it is best that the truth be fully stated and clearly recognized. He who sees the truth, let him proclaim it, without asking who is for it or who is against it. This is not radicalism in the bad sense which so many attach to the word. This is conservatism in the true sense—Henry George

In this issue:

BSP’s April 2020 FSR: PSE’s Soaring Debt-at-Risk, Bank and Financial Vulnerabilities, Risks of Re-Fitting of the Economy and More…

I. Market ‘Stability’ from BSP and Global Central Bank Injections
II. FSR Warns on Interest Rate Coverage Risks of PSE-listed Firms
III. FSR: Vulnerabilities in Banks and Elsewhere In The System
IV. The BSP’s Confession: A Knowledge Problem of a Complex and Dynamic System
V. The FSR: Radical Re-fitting of the Economy; Shopping Malls May Not Be Viable!
VI. The FSR: As Debt Soars, Taxes Will Rise; The Institutionalization of the Command and Control Economy
VII. Telltale Signs: After Deutsche, Nomura’s Exodus from the Stock Market Brokerage Business

BSP’s April 2020 FSR: PSE’s Soaring Debt-at-Risk, Bank and Financial Vulnerabilities, Risks of Re-Fitting of the Economy and More…

Last week, the Bangko Sentral ng Pilipinas led Financial Stability Coordinating Council (FSCC) released their April 2020, Financial Stability Report.

From the BSP’s press release, “The mandate of the FSCC is to make sure that the financial system is functioning properly,” FSCC Chairman Benjamin E. Diokno said. He added, however, that the Council “also understands that the ultimate goal is not just a strong financial system, but a financial system that supports a thriving economy. This is why mitigating systemic risk is all about public welfare.”

The BSP announced a shift in the schedule of the publication of the Financial Stability Report “from an annual to a semestral release reflects its commitment to being responsive to the times.” And the FSCC will likewise issue a regular publication on Macroprudential Policy Strategy Framework, referring to the intervention of authorities for managing systemic risks.

As I have been saying, the BSP communique has been directed at two audiences. (bold original)

Though the BSP releases the FSR to the public, its target audience has been the central bank member peers at the BIS, as well as, the BIS bureaucracy. In contrast, reports targeted at domestic audiences barely touches the risk agenda raised in the FSR.

Differently stated, the BSP has mostly been candid about risks in the financial system when reporting to their colleagues, but the topic about risks evaporates when it publishes the financial system conditions to its domestic audiences.


So most of the domestic media outfits megaphone the positive content of the FSR. For instance, this CNN report (June 23): Local financial markets remain resilient despite the COVID-19 pandemic, the Financial Stability Coordination Council said Tuesday, as they stressed that economic risks have risen in the face of global recession.

Manila Times echoed on their “PH financial system stable – FSCC” June 24th article.

Interestingly, an outlier, the Philstar (June 23), took on the opposite end, “The era of cheap borrowing in previous years, which resulted in a pile of debt, is now creating financial strain in local companies. Corporates lead local borrowers that may face difficulty paying debts as cashflows stagnated when business operations halted due to the pandemic, putting into question a government strategy that heavily relies on the private sector for recovery.”

This outlook will deal with claims of a stable market and the confessions by the FSR of fragility embedded into the system.

I. Market ‘Stability’ from BSP and Global Central Bank Injections

The financial market’s stability, according to the BSP’s perspective: (p.13 to 14) [bold original, bold italics added]

There are, however, notable differences in how rebalancing has been executed in the Philippines. When compared with other Asian economies, the rebalancing in the Philippines stands out (Table 2.1). In Thailand and Indonesia, there is a shift out of every asset class, which suggests a preference for cash. Malaysia shows the shift heading towards bonds, while India curiously shows a rebalancing towards longer-term assets

The Philippines, in contrast, has shun mixed assets and shows a preference for specific asset holdings, particularly for local money market instruments. The country’s credit default swap (CDS) spreads and term premiums have also eased in the recent period. Looking at the spreads between PH and US fixed income instruments, the risk premium gap has also tapered.

With no immediate shift towards foreign currencies, the PHP has been relatively stable compared to its peers. In February, portfolio investments actually posted a net inflow after several months of outflows (BSP, 2020). Recent imports data shows a drop in YoY growth to –11.6 percent in February 2020 from 2.0 percent in February 2019 (PSA, 2020), reducing demand for the USD. Likewise, the high level of gross international reserves (GIR)19 seems to provide some assurance for the market. All these eased any downward pressure on the PHP while most EME currencies weakened sharply in the first quarter of 2020. Spot prices show a stable PHP in April 2020 amidst low trading volume since the ECQ.

Figure 1

Are money market instruments not the most liquid or cash-like assets? Faced with uncertainties, the typical magnet for people looking for safety are cash and cash-related liquid assets. And given the different architectures of the financial systems of Asia, why should flows to money market instruments be considered special? Americans have also been holding enormous amounts of cash.

Along with the BSP, haven’t risk assets around the world been significantly boosted by unprecedented injections of global central banks? Total assets of major central banks have rocketed by about USD 4 trillion to USD 24.3 trillion in May, that’s about 28% of the USD 86 trillion 2019 GDP. Meanwhile, with a tsunami of liquidity, yield chasing on the world stock markets have spiraled valuations of the MSCI index to 2002 highs! Figure 1

Yet, can stability from overriding market forces be sustained? At what costs? Are these interventions not subject to the laws of diminishing returns? Have these not spurred extreme distortions and dislocations in the financial markets that amplify the odds of more incidences of heightened volatility soon?

Aside from the BSP’s QE, wouldn’t the slew of other bailout measures momentarily calm the markets?

As to the record GIRs, from the Inquirer (June 24): The Philippines’ dollar reserves hit a historic high in May —at the peak of the COVID-19 lockdown—thanks to inflows from the government’s foreign borrowings, as well as foreign exchange earnings of the central bank.

How reliable are foreign exchange reserves constructed from financial dealings, through borrowings and derivatives than from economic transactions?


Since these borrowings require repayments, are these reserves not only artificial and temporary but represent USD shorts? That is, shorts as in “the mismatch (maturity) between short-term interbank borrowing (globally) on the liability side supporting and maintaining longer duration loan or security assets”. And as Alhambra Investment wizard Jeff Snider explains, “Once you create those “dollar” assets, you are on the hook for funding them, in “dollars”, until they are disposed of – voluntarily or not”.

The bigger their USD liabilities, the more prone the BSP is to a squeeze.

Moreover, what measures did the BSP tacitly undertake to squeeze foreign participation and foreign selling on the domestic financial markets? (see Nomura’s Exit below)

Now to the BSP’s response to risk aversion via QE injections:   To support funding markets, CBs infused liquidity while reinforcing lower-for-longer yields. As the pandemic threatened macroeconomic and financial stability, CBsre-used their monetary tools deployed during the GFC, such as the reduction of the policy rate to near — if not, at — zero and the resumption of bond-buying programs. The challenge, however, is that if the adverse effects linger further and worsen beyond GFC levels, as suggested by the IMF, financial authorities will have to consider new and additional interventions.”

So have the adverse effects worsened beyond GFC levels for the BSP to slash its overnight policy rates by 50 bps to a record low of 2.25% last week?

Or, as previously discussed*, given the fiscal deficit blowout, is the BSP deepening the use of its Financial Repression policies to reduce the cost of debt servicing, exact an inflation tax on the public through negative real rates (inflation greater than nominal rates), and ward off deflationary pressures from the recession?


If the financial system is sound, why resort to such a scale of bailout measures?

The BSP is now even considering to raise its Php 300 billion QE to Php 550 billion!

The historic rate cut sent Philippine yields suddenly tumbling substantially across the curve, narrowing spreads, indicating more tightening. The other week, the yield curve pointed towards a steepening. The avalanche of interventions that have mucked up the pricing system has left the financial markets dazed. 

A few days does not make up a trend, though.

II. FSR Warns on Interest Rate Coverage Risks of PSE-listed Firms

Now to the risks. (p.15-16) [bold original, bold-italics mine]

A particular concern is debt-at-risk. For some time now, risk prognoses have pointed to the build-up of debt in the low-for-long era. While the level and growth of debt had been frequently cited as possible vulnerabilities, the strains imposed by the pandemic will cause debt servicing difficulties. This will primarily be driven first by reduced income due to suspended economic activity and, then second, through the interlinkage of the income fallout from one entity to another. This is the case between industries, among firms and even among household debt in the informal sector

Available data limits us only to the formal markets. Loans to residents are still dominated by corporate borrowers, accounting for approximately 60 percent of the total (Figure 2.14). For cross-border claims, the non-bank private sector represents the majority of the debt (45.1 percent of total claims), but the sharp increase in the debt of the banking industry warrants further assessment (Figure 2.15). Moreover, the outstanding corporate debt among 200 listed companies stood at PHP9.3 trillion, 28.4 percent of which is denominated in foreign currency (FCY). This year, USD3.46 billion of FCY debt will mature, while PHP553 billion in local currency is likewise due (Figure 2.16). The latter will be tested by any impairment in revenues, and thus capacity to pay, while the former will add pressure on USD liquidity, on top of income capacity.

It should be pointed out that the debt repayment capacity of some PSE-listed non-financial corporates (NFCs) was already declining before the emergence of COVID-19. The interest coverage ratio (ICR), which is a measure of the firm’s ability to service the interest obligations of their debt, has been decreasing in recent periods as interest expense has grown by an annualized rate of 20.9 percent, while earnings before interest and taxes (EBIT) has only grown by 9.0 percent over the past three years (Figure 2.17). Stress test estimates suggest that the ICR declines from 6.44 in Q4 2019 to 4.01 (at 10 percent EBIT decline) or further to 2.23 (at 50 percent EBIT drop). Although the policy rate has been reduced starting April 2019, the impact of lower rates on existing bank debts would not be felt until the repricing of those loans usually a year later.

Ever since the BSP began publishing the FSR in 2018, as a requirement to its membership at the Bank for International Settlements, it has raised the excessive valuations and the broadening mismatch between the disproportionate growth rate of debt relative to profitability plaguing the PSE.

Importantly, balance sheets of both banks and non-financials have been deteriorating even before COVID and the ECQ. As for the ICRs, San Miguel’s debt conditions look like the nation’s paradigm of a zombie-Ponzi finance scheme, as explained in early June.


Figure 2

And it is not just the National Government rushing to obtain foreign exchange financing, domestic firms are, “looking to raise a total of $2.5 billion with bonds, based on regulatory filings, according to the Bloomberg. And the reason for this? To rollover debt:  Philippine firms are set to join the global rush to borrow funds as they prepare for a massive debt bill: about $8.3 billion in corporate bonds and loans will mature in the second half of the year, before that pile climbs to a record $16.4 billion in 2021”.

How can a slowing/recessionary economy and raging debt growth be bullish for equity investors?

III. FSR: Vulnerabilities in Banks and Elsewhere In The System

On the banking and financial system. (p 16 to 17) [bold original, bold-italics mine]

The strain on the banking books will come through a further impairment in past due loans (PD). The pressure on income increases the likelihood of missed debt payments. However, even before 2020, PD were already trending upward, both in absolute amounts and as a percentage of loans (Figure 2.18)… Despite the fact that the share of the impaired accounts to total loans remain minimal, there is a need to closely monitor the PD but not yet NPLs alongside the outright NPLs, and its respective proportion to outstanding loans, to determine the eventual impact of COVID-19 on the banking books especially in the event of a more protracted contraction in economic activities   

There may be vulnerabilities elsewhere in the system. For insurance companies (InsCos), massive and sudden shifts in market yields can cause a mismatch between the long-term returns promised in the policies sold to clients versus the yields realized by their investments. While actuarial estimates are still being recalibrated, there may also be a fair amount of unscheduled claims that may be redeemed by policyholders and it is not clear if liquidity is also at risk, given market conditions.

As one can see, because of the interconnectedness of the system, the BSP admits that financial strains are building up across all sectors, most notably at the heart of the system, banks, as well as other financial institutions.

For banks, liquidity problems have now morphed into credit quality issues.  For the pension and insurance industry, pronounced asset-liability mismatches can become a critical source of significant financial crevices.

And though household credit may be a small segment in the BSP’s statistics, the impact of the economic freeze on the informal sector could function as another potential catalyst leading to a crisis. (p. 17)

For households, we cannot directly estimate the impact on debt servicing from the erosion of incomes. On paper, salaries and wages account for about 36 percent of GDP (based on 2018 data). This, however, includes professionals who are under contract and will be paid on a monthly basis regardless if a pandemic materializes. The most vulnerable are the workers who are part of the informal sector or whose wages depend on the occurrence of events, that is, those who are on no-work-no-pay arrangement in the “gig economy”. This aspect has not been assessed and would not benefit from the current relief program extended in the formal financial market.

If the strain on incomes and economic activity linger, systemic risks will certainly amplify…Moreover, the average induced failures are greater for simultaneous shocks to the system than the summation of the failures emanating from shocks to individual firm. This observation is critical as it highlights one of the key lessons learned in previous crises — that is, small shocks can lead to large dislocations. It is, therefore, imperative to address the brewing risks identified in this chapter before it triggers a cascading failure in the financial system.

Likewise, the BSP recognizes that it has no control over other potential triggers to a financial shock that may ripple to the system.

IV. The BSP’s Confession: A Knowledge Problem of a Complex and Dynamic System

And here’s the striking climax… [bold original, bold-italics and underline mine] (p.28)

The caveat is offered because one cannot tell yet how the public health issue will be resolved and how the corresponding stress points of eroded incomes and suspended business activities will be handled. The three cannot be dissociated, and in turn, these are symbiotic to the state of the financial market. Risk pressures will continue to build because debts will be increasingly difficult to service, banks will find it harder to source new deposits, and risk perceptions draw in further risk perceptions.

It is recommended then to address the risk premium directly. This is not to suggest that one should set aside the public health issues and its macroeconomic shocks. It is simply compartmentalizing, and part of this is an assumption of going concern. It is assumed that financial institutions remain liquid in PHP and USD terms, that depositors can routinely access automated teller machines or make electronic transactions, that clearing and settlement bottlenecks are effectively addressed, that fees for electronic payments are not a disincentive, and that the government is able to source funding for their interventions.

And the BSP’s no control over the potential trigger is a function of the knowledge problem of a complex and dynamic system. It confesses that their (Dynamic Stochastics General Equilibrium) econometric models can’t capture the interactive and interdependent feedback loops occurring spontaneously and simultaneously in the system.

The BSP then makes an important assumption of the functioning liquidity in the system, viz. allowing depositors to access both ATMs and electronic transactions and facilitating the continued clearing and settlements. But what if one of the fragile moving parts, affected by a multitude of factors, fail? Would cash run dry at the ATMs and would online accounts go offline?

And what if credit gridlocks lead to an intractable series of ‘settlement fails’ as they previously raised?

From the 2018 FSR (p.30): It also suggests why unwinding failed transactions can have broad system-level implications. Despite institutionalizing the delivery-versus payment protocol, the system remains vulnerable because a single bilateral failed trade may require a network of unwinding. Unfortunately, such data is not easily accessible and the extent to which these “settlement fails” represent a possible systemic risk—not just in size but more so in terms of interlinkages that can spillover to the rest of the economy—is not readily determinable, at least at this time. In general, payments system data remain largely untapped and not having even a cursory view of the dynamics of the payments network leaves financial authorities blind to their possible consequences. This is a major concern

That said, the establishment consensus drooling for a V-recovery has largely ignored or discounted such elevated risk profile, which even the BSP recognizes.

And yes, the belief is that “government is able to source funding for their interventions”.

But what if domestic and global funding runs out?

V. The FSR: Radical Re-fitting of the Economy; Shopping Malls May Not Be Viable!

And here is another stunning admission. (p.29)

Looking ahead, it would be a major oversight to expect that the economy could still go back to business-as-usual. COVID-19 is leaving scars that even a proven vaccine may not remove. The old economy has to “re-fit” into the new normal of social distancing. Business paradigms that relied on scale (incurring high fixed costs and catering to the retail market in mass) will have to rethink how they can operate in the post-COVID-19 world. Air transport (planes that cost from USD77 million to USD450 million depending on the model, ferrying hundreds of passengers per trip) and big shopping malls, for example, may not be as viable under reduced floor and foot traffic.

To repeat: “Big shopping malls may not be viable under reduced floor and foot traffic”. Incredible!

So what happens to the frantic race-to-build-supply? The FSR commentary virtually exposes the massive malinvestments in the economy partly due to COVID.  Is the BSP aware of the costs and consequences of this radical re-fitting of this key industry into the new normal?

Does the BSP realize that shopping malls, which are part of the retail and the real estate industries, represent the biggest contributors to the GDP, bank industry borrowing, and the largest source of employment?

Retail and Real Estate sectors accounted for 24% of the 2019 GDP. The same sectors comprised 31.06% of the total bank lending portfolio at the close of 2019. More than a third of service sector employment reportedly comes from the said sectors.

Is the BSP aware that once losses become evident and escalate, the sector’s credit chain leading to the banks and bond markets will take a hit?

If the BSP FSR’s prognosis is correct, then the industry will have to face a domino of bankruptcies and liquidations, so how can a sharp GDP recovery happen next year?

VI. The FSR: As Debt Soars, Taxes Will Rise; The Institutionalization of the Command and Control Economy

Finally, the Sisyphean Task of the shoring up of the economy lies at the hands of the National Government! So said the BSP. (p.29)

The key element now is that NGs are taking on the burden for funding the needed relief program. There is no other entity in place that can absorb the ultimate risks and the corresponding financing. This will certainly mean higher debts, much less fiscal space. Intertemporally, this debt can be bridge-financed with more debt just to sustain liquidity. Ultimately though, taxes will have to adjust intergenerationally to make up for the gap. This is a policy issue that, for the moment, is pushed down the road but is unlikely to be avoided.

Translation: to maintain liquidity, public debt will skyrocket (intertemporally). But since there is no free lunch, to pay for this, taxes will have to be raised significantly over time (intergenerationally).

In contrast to the proposition of the NG to chop corporate taxes via the CREATE bill, taxes are bound to surge! The CREATE bill most likely represents a bait and switch; it would reduce corporate taxes but transfer the tax burden through significant increases in VAT, excise, and or sales taxes.

Of course, the politically convenient aim is that such tax burden should be pushed down the road, but as the FSR warned, it is unlikely to be avoided.

The current economic crisis will bring about an extraordinary legacy for our progenies, high intergenerational taxes! 

Yet, to give a perspective of how this evolves, let us look at the fiscal performance for May.

Figure 3
The monthly fiscal deficit soared to Php 202.136 billion in May, the second-highest, after April’s historic Php 273.9 billion, reported the Bureau of Treasury. May’s budget gap pushed the 5-month deficit to a staggering Php 562.18 billion surpassing 2018’s Php 558.26 billion, the previous second-highest on record.

The milestone budget gap was a product of a perfect storm, the second-largest plunge in tax revenues in the face of the next highest public expenditure. BIR and BoC revenues plummeted 45.34% in May to Php 145.195 billion, a follow-up on April’s 56.74%. In the meantime, public spending surged to Php 353.63 billion in May, the second-biggest on the books, up 12.4%.

The funding of May’s deficit has yet to be disclosed by the BSP and or the Bureau of Treasury, although the jump in M3 last April demonstrates the BSP’s record injection to the financial system through QE.

The National Government projects a staggering deficit-to-GDP ratio of 8.4% or Php 1.6 trillion from 2020’s recession.

So aside from higher taxes, the institutionalization of the expanded share of public spending relative to the GDP reinforces the structural shift towards a centralized, command-and-control political economy, signifying the ratchet effect.

VII. Telltale Signs: After Deutsche, Nomura’s Exodus from the Stock Market Brokerage Business

Because of the massive interventions and manipulations, financial market prices are distorted, alright. But actual events are telltale signs.

Foreign money or investors have not only been selling the stock market, and possibly, other Philippine assets, but they have also been reducing their exposure to the real economy.

Figure 4
Through the acquisition of the PCIB Securities, BDO Unibank and Nomura Asia established a stock market brokerage firm, the BDO-Nomura Securities, in January 2016.

Last week, with the exit of Nomura, that 4-year partnership came to a close; BDO acquired the former's 49% share.

It was just last January when Deutsche Bank also exited the securities industry by selling out to its local partners.

Why Nomura’s short stint?

Here are a few guesses.

Since culminating in 2013, annual peso trading volume has been on a downward trajectory. Though the benchmark index hit a record high of 9,058.62 in January 2018, peso volume hasn't supported this. This milestone had signified a product mostly of end-session pumps on select index sensitive issues. Figure 4

Next, reduced foreign participation and outflows have been a significant factor for the decline in peso trading volume.

Or, since August 2018, the share of foreign participation relative to the total turnover has significantly been dropping.

Possibly because of the lack of volume and broad market participation, a scandal involving a 50-year old stock market broker surfaced last year, which may lead to the tightening of the regulatory environment, and raise compliance costs, squeezing profit margins.

The recent market meltdown may have compounded the lethargic broad market sentiment and volume trades.

Brokers may not be only suffering from reduced transactions but also losses on investments/speculations.

Higher taxes from current fiscal activities could also weigh on profits.

Reduced disposable income and stock market losses may limit the growth of retail participation.

Finally, a global trend of zero bound commission rates could also be a factor*.


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