A COMPARISON BETWEEN THE ECB AND THE FEDERAL RESERVE SYSTEM

Chuheng Guo, Bachelor in Business Economics. Department of Social

Sciences and Solvay Business School, Vrije Universiteit Brussel, Pleinlaan 2,
1050 Brussels, Belgium, e-mail: chuheng.guo@vub.be;
Philipp Bezler, Bachelor in International Finance. Department of International
Finance, University of Nürtingen-Geislingen, Neckarsteige 6, 72622 Nürtingen,
Germany, e-mail: bezlerp@stud.hfwu.de
This paper will discuss the differences and similarities between the European
Central Bank and the Federal Reserve System. We will compare the two
entities and provide some recommendations for reforms that could boost their
efficiency in the future. We concluded that the ECD and the federal reserve
differed from each other mainly due to the political and geographical
differences between the United States and European Union countries. This, in
part, made making recommendations for either quite difficult, although both
would benefit from some reforms.

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1 INTRODUCTION
The European Central Bank and the Federal Reserve System are familiar names
in financial magazines or newspapers. They are the two largest and most powerful
central banks in the world. On the one hand, the ECB acts as the central bank for the
entire eurozone and those European Union member states that do not have the euro as
their national currency. The Federal Reserve, on the other hand, is the central bank for
only the United States of America. In this paper, we will discuss the similarities and
differences in terms of policy and operations between the European Central Bank and
the Federal Reserve System.
More specifically, chapter 2 focuses on the origins of both banks, whereas
chapter 3 discusses their governance, including their geographical division and their
governing bodies. Then, in chapter 4, we will examine the capital and profits distribution
of the two banks, after which we devote chapter 5 to monetary policy, paying special
attention to the policies that both banks pursued before and after the 2008 global crisis.
Finally, chapter 6 closes with the banking regulation and supervision of our two entities.

2 ORIGINS OF US AND EUROPEAN CENTRAL BANKS

In this chapter, we deal with the historical aspects to the founding of the
European Central Bank and the Federal Reserve System. As such, we provide a timeline
for how the nowadays indispensable monetary authorities have developed since their
creation.

2.1 THE FEDERAL RESERVE’S HISTORICAL BACKGROUND

The Fed was established as the result of the Federal Reserve Act (FRA, 1913)
after the U.S. financial crisis in 1907. It was created as a system of banks with limited
power spread between 12 of the most powerful U.S. states. We say that the Fed’s power
was limited because Congress could restrict its actions. However, it was still charged
with discounting commercial paper, accepting bills, and promoting an effective national
payment system. Furthermore, the Fed also had the authority to "coin money and
regulate the value thereof."
Before 1913, the American monetary system was distributed among several
private banks, each authorized to issue their own bank notes. These banknotes were
backed by gold, and there were more than 7000 of them in circulation at certain times.
The need to reconsider the existing banking system became obvious with the bank run
in 1907. As a result, a proposal for a central banking system modeled after the German
Reich bank – “the Aldren plan” – was put forth. To achieve a decentralized Federal
Reserve, the U.S. territory was divided into twelve Federal Reserve Districts, each of
which would house a branch of the bank. Although Congress can alter or dissolve the
Fed through legislation, the Fed largely retains its independence from government
influence.

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2.2 THE HISTORICAL BACKGROUND OF THE EUROPEAN CENTRAL BANK
The ECB as the sole monetary authority in the euro zone was based on the
existence of the European Economic area. Since a common economic area was already
in place in Europe, it was natural to introduce a common currency for use in that area.
The ECB was created in 1998 through the Maastricht Treaty, and it consists of the central
banks of the European Union member states. As an independent authority, its sole task
is to conduct and perform monetary policy inside the euro area, thereby assuring a stable
euro and stable prices. As such, the ECB aims to keep inflation close below 2%.
Due to the recession following the corona pandemic, the ECB has slightly
increased their target inflation rate to about 2% per year. Apart from being the sole
official of banknotes in the eurozone, it also offers advice to the European Commission
and the member state authorities.

3 GOVERNANCE
For every company and financial institution, the board, specifically its
composition, its powers, and the voting rights of its members, is of great importance. It
is therefore necessary to make a rigorous comparison of the governing bodies of the two
largest central banks in the world. In both cases, their boards consist of three entities,
which we will discuss below.

3.1 EXECUTIVE BOARD AND BOARD OF GOVERNORS

The Executive Board of the European Central Bank and the Board of Governors
of the Federal Reserve System are the operational governing bodies of their respective
central banks. They consist of six and seven members, and at the head of each, we have
the chairman, who is also the face of the bank.

3.1.1 APPOINTMENT
The appointment of members is relatively even. The Board of Governors is
chosen by the President of the United States of America, upon approval of the Senate
(Federal Reserve Board, 2022). The Executive Board, on the other hand, is elected by
the heads of government of the members in the euro area. This is done by
recommendation of the European Council and after consultation of both ECB’s
Governing Council and the European Parliament (Scheller, 2006). In other words, both
operational governing bodies are put together by the heads of the nations for which they
are responsible.
At the European Central Bank, all members, including the president and vice
president, are appointed for a one-time term of eight years (Executive Board, sd). In
contrast, members of the Board of Governors are appointed for a one-time term of 14
years. In some cases, a governor may serve longer than 14 years if he filled in for an

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early retiring governor before. However, the chairmen and vice chairmen at the ECB are
elected for non-renewable 8-year terms, whereas those at the Fed serve for 4 years at a
time, but are eligible for reelection throughout their 14-year tenure. The major difference
in the appointment of members of the two entities thus lies in the lengths of their terms
in office.
In the United States, the chairman of the Fed can remain in power for years. An
example of this is former chairman William M. Martin, who was in power for 19 years
(Federal Reserve Bank of St. Louis, sd) due to the renewability of his position and the
early retirement of the previous governor. In Europe, by contrast, a president serves a
maximum 8 years. Excessively long terms of service can lead the economy astray. An
example of this is Alan Greenspan, who sat as chairman of the Federal Reserve System
for 18 years until his resignation in 2006, just before the financial crisis (Board of
Governors Members, 1913 - Present, 2022). Many economists worldwide consider
Greenspan one of the causes of the crisis in 2008. One might wonder, therefore, whether
the crisis could have been avoided if the Americans had applied the European system.

3.1.2 POWERS
Although both the Board of Governors and the Executive Board are seen as
operational governing bodies, they also differ from each other in notable ways. It is true
that both are responsible for setting monetary policy in the nation(s) that lie within their
jurisdiction. It is also true that their members have permanent voting rights. However,
the two governing bodies differ significantly in the powers they exert. Although their
members are fully present at the meetings where monetary policy decisions are made
and are able to vote on these decisions, only the Executive Board can implement them
(Executive Board, sd). Apart from the implementation of such decisions, the Executive
Board also determines interest rates and informs the national central banks of any
changes in monetary policy (Executive Board, sd). In contrast, the Board of Governors
can only co-decide on the evolution of monetary policy, while its actual implementation
falls under the jurisdiction of the Federal Open Market Committee (FOMC).
The Federal Open Market Committee is a branch of the federal reserve system
that controls the direction of the monetary policy in the United States by directing Open
Market Operations. These operations include the Fed’s purchase and sale of securities
in the open market. The committee consists of 12 members, including 7 members of the
board of governors, the president of the Federal Reserve Bank of New York and 4 other
Reserve Bank presidents.
One could argue that since the Board of Governors is part of the FOMC, it is
also indirectly responsible for the implementation of monetary policy. While this
argument is in some sense correct, it is not entirely accurate. Although it is the FOMC
that implements monetary policy on paper, it is really the Federal Reserve Bank of New
York that pulls the strings when it comes to this implementation.

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 Further differences between the Board of Governors and the Executive Board
arise from the geographical and political states of the two. Indeed, the Board of
Governors helps the Federal Reserve Banks with their day-to-day management and
banking supervision. Furthermore, it sets budgets and is responsible for electing three
members of the Board of Directors and appointing the president (Federal Reserve Board,
2022). In contrast, the Executive Board oversees the day-to-day management of the ECB
itself and performs tasks imposed by the Board of Governors (Executive Board, sd).

3.2 GOVERNING C OUNCIL AND FEDERAL OPEN MARKET C OMMITTEE

The next two entities to be compared are the ECB’s Governing Council and the
Fed’s Federal Open Market Committee. These have already been cited above as being
the entities where monetary policy is formulated for their associated nations. The
Governing Council and the FOMC consist of 25 and 12 members, respectively. Our
discussion will be based on powers and voting rights.

3.2.1 POWERS
Both the Governing Council and the FOMC bear the huge responsibility of
setting monetary policy for the nations they operate over to maintain a stable economy.
Although the FOMC exercises no other duties, the Governing Council is in charge of
other tasks as well. Furthermore, the president of Federal Reserve Bank of New York
has more power than any of the other members of the FOMC, whereas those of the
Governing Council share their responsibilities in a more equitable manner. The
establishment and maintenance of each nation's monetary policy are of utmost
importance for a stable economy. It is, therefore, more than logical that completely
separate entities exist for that purpose.

3.2.2 VOTING RIGHTS

Although the members of the Board of Governors and the Executive Board
retain their voting rights at all times, those of the Governing Council and the FOMC
enter a rotation system. At the ECB, the 19 eurozone countries get 15 votes in total.
Those countries are split into two groups. The first group consists of the five countries
with the largest economies and is endowed with four votes, whereas the second group
consists of the remaining 14 countries and is granted 11 votes. That means that in each
round of voting, four countries cannot participate, but this does not prevent them from
attending the meeting. Each month, voting rights are redistributed so that countries that
could not vote in one session can do so in the next.
For the FOMC, there are five votes for the 12 presidents of the Federal Reserve
Banks. The Federal Reserve Bank of New York has permanent voting rights. The
remaining 11 Reserve Banks are divided into four groups, with each group having one
vote. Each year, that vote is passed around from one district to the next within each group

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through a rotation system. The districts that do not have a vote can, of course, participate
in the meetings.
The voting power in the FOMC is particularly unfairly distributed because
districts have been without a vote for as long as two years despite their economic
importance. For example, the Federal Reserve Bank of San Francisco includes branches
in Washington and California, home ports for some very important Fortune 500
companies. Besides, the banks in Atlanta, St. Louis, Dallas, etc. also play important roles
in the American economy. However, these districts are often left with little say as
members of the FOMC due to insufficient voting rights and remain subservient to New
York. However, the ECB does try to capitalize on economic growth by revising the
capital allocation key once every five years. That is, it reexamines whether the five
countries currently in group 1 still have the largest economies in the country. If this is
not the case, the groups will be rearranged such that the countries with the strongest
economies are more likely to vote (European Central Bank, 2022). Even though the
FOMC is a great asset to the Federal Reserve System, it can learn from the ECB when
it comes to fair voting rights. A first step in the right direction could be to increase the
number of rotations each year.

4 CAPITAL AND DISTRIBUTION OF PROFITS

An important balance sheet item in the annual report of any company or financial
institution is its equity capital. In the case of the ECB and the Fed, we will focus on a
subdivision of that equity, the capital, and compare their distribution of profits and losses
with each other.

4.1 CAPITAL
Both the ECB and the FEd have a large amount of capital. The balance sheet
item on their financial statements comes from different sources and also differs in size.
The ECB currently has an issued capital of about 10.8 billion euros, of which a
rounded 8 billion is fully paid up. This capital comes from the 28 countries that make
up the European Union. The difference between subscribed and paid-up capital is due to
the fact that nine countries in the EU only have to pay up to 3.75% of their share of
subscribed capital to cover operational costs (Subscription to ECB capital, 2022).
Similarly, the Fed also has a difference between its subscribed and paid-up capital. The
difference between the issued and paid-up capital is due to the fact that the banks
subscribing to the shares of the Federal Reserve Bank in their district do so for shares
worth $100, of which only $50 must be paid up in full (Financial Accounting Manual
for Federal Reserve Banks, 2022). Increases in capital is possible at the two central
banks. The ECB can legally increase its capital by a maximum amount of 5,000 million
euros with the capital allocation keys adjusted, and the remaining amount must be paid
up in full by the countries of the European Union (Scheller, 2006). The Fed can do this

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by having its Reserve Banks pay up the remaining $50 per share paid in full (Financial
Accounting Manual for Federal Reserve Banks, 2022).
The sizes of the capital of the two central banks differ for two reasons. On the
one hand, we have to consider the origination date between the two banks. As one could
read in chapter 2, the Fed was founded in 1913, and the ECB, on the other hand, only
came into existence in 1998. Since the ECB is 85 years older than the fed, it makes sense
that the former has a higher proportion of capital on its balance sheet items than the
latter. We must also take into account the geographical and political differences between
the two central banks mentioned earlier. At the ECB, the 28 countries of the European
Union subscribe to the capital, with the nine non-euro countries having to pay up only
3.75%. However, the Federal Reserve System draws its capital from the affiliated banks,
which are required to subscribe to Federal Reserve Bank shares from the district to which
they belong.
Both the ECB and the Fed have reserve balances, on which some of the profits
end up, which can be used to cover losses at a later time. In Europe, it is up to the
Governing Council to decide what percentage of profits to transfer to the reserve balance
sheet. This can only be done for a maximum of 20 percent and as long as the reserves
do not exceed the capital per se (Subscription to the capital of the ECB, 2022).

4.2 DISTRIBUTION OF PROFITS AND LOSSES

The net profits generated by both the ECB and the Fed during the year are traded
in different ways. The ECB collects its net profits and distributes them based on the
capital distribution key to the euro area countries. The individual monetary income,
which is the income obtained from the implementation of monetary policy in each euro
area country, is added up and redistributed according to the capital distribution key.
Thus, each country gets what it is entitled to, and there can be no competition among
euro countries (Scheller, 2006). In the United States, the banks that subscribed to the
capital, depending on their size, are paid a dividend. Thus, the remaining profits do not
go to the banks, but are transferred to the U.S. Treasury Department, also known as the
state treasury (Financial Accounting Manual for Federal Reserve Banks, 2022).
Although this state treasury is a governmental enterprise, it is completely separate from
the president, Senate, and Congress.
If the ECB made a loss rather than a profit, it could use its reserve balance sheet
to cover that. Should these reserves be insufficient, the euro countries will pay for the
loss incurred. The profits resulting from their monetary policy will then be used to cover
the ECB's loss. The nine non-euro countries need not worry about this, since they do not
share in the profits either (Scheller, 2006).

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 In the U.S., when a particular district makes a loss, it can use its surplus. If the
loss exceeds what the district has available in reserves, then it does not have to transfer
anything to the state treasury, as long as the net profit is not large enough to cover the
previous loss.

Annual consolidated balance sheet of the Euro system (europa.eu)

U.S. Fed balance sheet chart 2007-2022 | Statista

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5 MONETARY POLICY
The monetary policy of each central bank is of great importance in keeping the
economy stable. Although each bank has mechanisms in place to achieve this goal, they
all operate based on the scarcity and value of money. In the next section, we will pay
attention to the ECB and the Fed’s use of interest rates and their respective responses to
the 2008 crisis.

5.1 INTEREST RATES

The ECB makes direct use of its interest rates. Indeed, banks will borrow money
in part from the ECB either at a fixed or variable interest rate. With a fixed interest rate,
set by the ECB, each bank determines how much money it wants to borrow. When the
ECB decides to move to float rates, it sets a minimum rate at which to bid and an amount
to borrow. The banks in question prepare a bid, in which they indicate how much money
they want to borrow and at what rate. The highest percentages get the full amount. The
remaining banks can also lend money as long as the predetermined amount is not reached
(The Monetary Policy of the ECB, 2022). In this way, use is also made of interbank
relationships, since not every bank get its loan. This differs greatly from the Fed’s
operation. There, the FOMC sets a Target Fed Fund Rate, where it hopes that banks will
borrow money themselves at a rate as close as possible to the target. Of course, there is
more to that, because it pushes banks in the right direction through its Open Market
Operations. The Open Market Operations, organized by the FOMC, aims to address the
scarcity of money, causing the rates to rise or fall (Conducting Monetary Policy, 2022).
It is clear from Section 3.2 that the FOMC represents one of the major
differences between the ECB and the Fed. Apart from that, the two central banks also
differ in the implementation of their monetary policy due to their difference in interest
rates. On the one hand, banks borrow money from the ECB at a fixed rate set by the
Governing Council or at a variable rate where a minimum was set. The Fed, on the other
hand, uses targets set by the FOMC, directly manipulating the banks to respect this target
as much as possible through Open Market Operations. Moreover, banks in the euro area
borrow money directly from the ECB, and interbank relationships play a lesser role than
they do in the United States. At the Fed, direct borrowing from the Federal Reserve Bank
is an emergency solution. The U.S. central bank prefers that banks under its jurisdiction
lend to each other and only come to them when there are no other options left. That is
also why the Fed discount rate is higher than the Fed Fund Rate (Conducting Monetary
Policy, 2022).

5.2 RESPONSES TO THE FINANCIAL CRISIS

The 2008 financial crisis left its mark on the world. Consequently, the ECB and
the Fed both had to overcome a lot of struggles to stabilize its economy. The most
commonly used method was to cut interest rates, as the ECB’s main refinancing rate and

9
the Fed Fund Rate were both brought to historically low levels. Furthermore, some non-
conventional measures were taken by both banks, given that the ECB enhanced credit
support and the Fed purchased large-scale assets. We will not compare individual
measures here, but rather make a general comparison of the central banks' reactions.
The financial crisis of 2008 started in the U.S., and only later spread to the rest
of the world. The fall of Lehman Brothers caused a domino effect on Wall Street, leading
to a huge bank bailout by the Fed. While Americans at the time saw firsthand what the
failure of one big bank could to the world, the Europeans mainly felt victimized by
American politics. As a result, the ECB did not take enough measures to prevent future
crises, and the European economy collapsed once again during the 2010 credit crisis.
Only years later did the ECB launch its Single Supervisory Mechanism to provide
thorough banking supervision.

6 REGULATIONS
After the financial crisis of 2008, the main monetary policymakers in
Washington and Brussels decided that everything could not be left as it was. In this
chapter, we will discuss some precautionary measures that the central banks of the
eurozone and the US have put in place in order to detect problems in the financial sector
at an early stage.

6.1 REGULATION AND INCENTIVES FOR RISK-TAKING

In the U.S., banks and borrowers took excessive risks, which led to the Subprime
Mortgage crisis, wereas in Europe, the financial crisis introduced the debt crisis. In the
European currency zone, Basel III was then proposed as post-crisis regulation to prevent
severe future catastrophes. Meanwhile, in the U.S., the Dodd-Frank Act tightened the
regulatory requirements in place for almost every part of the nation’s financial services
industry. Since 2014, the ECB's Single Supervisory Mechanism has been monitoring the
130 largest financial institutions in the euro area. Moreover, the ECB's TARGET2
payment system has turned out to be a quasi-unconditional, interest-free credit system,
worth around 900 billion euros.

7 CONCLUSION
From this study, we compared the ECB and the Fed, and found the following
similarities and differences between the two:
First, there is difference in lengths of the terms in office between the members
of the Executive Board and those of the Board of Governors. In the American system,
presidents and vice presidents can stay in power for almost two decades. As a
recommendation, therefore, we suggested that the terms in office of the members of the
Board of Governors be changed to eight-year terms.

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 The Executive Board and the Board of Governors also differ in terms of powers.
In the eurozone, the implementation of monetary policy is covered by the Executive
Board, while at the Fed, it is under the remit of the FOMC. In particular, the ECB’s
Governing Council negotiates monetary policy, leaving its implementation to the
Executive Board, whereas the FOMC takes care of the whole process in a more efficient
manner. In the FOMC, we found that votings rights are unfairly distributed among their
12 member districts. As a result, certain monetary zones are economically
disadvantaged, as they are not allowed to vote on monetary policy for up to two years.
The Governing Council, however, rotates voting rights from member to member on a
monthly basis. Therefore, we recommended increasing the number of rotations each year
at the FOMC.
Our study also revealed major differences between the ECB and the Fed in terms
of capital and profit distribution. The differences in size and origin of capital could easily
be attributed to the political and geographical differences between the euro area and the
United States. As to profits, the ECB sends them entirely to its shareholders, the euro
countries, whereas the Fed transfers them directly to the U.S. Treasury Department,
which – in turn – makes fiscal decisions that benefit the entire nation. We recommended
a similar strategy for the ECB, where profits are transferred to the European Union, with
the European Commission making decisions about the allocation of that money.
However, both banks do anticipate potential losses in the same way – by creating reserve
funds.
Although both banks use interest rates to keep the economy and inflation stable,
they demonstrate some differences at the monetary level. The commercial banks in the
eurozone go directly to the ECB for a loan, either at a fixed or a variable interest rate. In
the U.S., however, banks borrow from each other and manipulate the rates with the help
of the FOMC and its Open Market Operations.
The ECB and the Fed also differed in their reactions to the 2008 global financial
crisis. Although both banks lowered interest rates to historically low levels and also took
some nontraditional measures, the U.S. recovered more quickly from it than the
eurozone did. This was not only because the crisis originated in the U.S., but also
because they responded to it as a united front while the eurozone took a more “every-
man-for-himself” approach.
Finally, we concluded that the world's two largest central banks hold more
differences than similarities. Many of these can be attributed to the political and
geographical differences between the U.S. and the eurozone. Although this made making
recommendations for reforms quite difficult, we nevertheless managed to come up with
some that might be worth testing out in the future.

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