A hail bawbee mine and aw tae mysel
Wi joy I’m like chowking if truth I maun tell
How best I micht spend it I cannae richt say
I’m fair in a muddle tae ken what tae dae
My First Bawbee, by Archibald McKay
What currency would be used in an independent Scotland? Probably no other issue caused more confusion in the 2014 referendum campaign or cast more doubt on the coherence of the plans of supporters of independence. There are three core options – the pound sterling, the euro, or a new Scottish currency which, for ease of reference, I will christen the bawbee. For completeness, I note that there are hybrid possibilities: a bawbee pegged to either sterling or the euro, and perhaps initially operating alongside sterling. And some are excited by the possibilities of new digital currencies. Indeed a group of enthusiasts has already added Scotcoin to the long list of newly-minted cryptocurrencies.
Today’s financial world is very different from the one that Innes Smith described in the lectures on Money and Banking which I attended at Edinburgh University in 1968. That world was overtaken by financial deregulation in the 1970s and 1980s which ended exchange controls, abolished restrictions on credit, replaced reserve requirements on banks by rules on capital adequacy, and allowed these banks to engage in a wide range of activities that the bank managers of an earlier era had not even imagined. In London in the 1960s, the new Eurodollar market allowed American and European banks to trade with each other outside the purview of the Federal Reserve. New technologies made many of these activities possible.
The theory of money and banking I learned as a student followed the traditional identification of the tripartite functions of money – medium of exchange, unit of account, and store of value. The Chartalist theory of currency associated the provision of money with the sovereign state. Often literally so; the medium of exchange was typically gold or silver, stamped with the head of the king or emperor, who would occasionally be tempted to debase the coinage by mixing the precious metal with less valuable material. In more modern times, banks issued notes partially backed by the gold in their vaults. The opportunities for fraud and mismanagement which arise from this practice are obvious, and in the nineteenth century, governments responded by taking a legal monopoly of note issue. Thus the association of currency and sovereignty continued.
In 1971 President Nixon abandoned the link between gold and the US dollar and the age of the gold standard finally ended. Until the 1980s, many countries worldwide, including the UK, maintained exchange controls so that resident individuals or companies needed government or Central Bank approval to deal in foreign currency. (UK exchange control was abolished in 1979.) But with the growth of foreign travel, global trade and financial innovation, it is impracticable for financially-advanced democracies to implement such controls.
Today you can make payments almost anywhere in the world in virtually any currency you choose. And both households and businesses do. You can order a coffee in Aarhus, Los Angeles or Zagreb and the payment will be debited in your preferred currency in the country where you choose to locate your account. (Although many banks, remittance agents and the – never use them – airport change desks still attempt to impose ludicrously wide margins, fintech is reducing the price of cross-border retail transactions to nominal proportions.) East Europeans sceptical of their own country’s government and judiciary make contracts in dollars or euros, enforceable under English law. The age of Chartalism is at an end.
Money in a Modern Economy
Theories of money have always been fertile territory for cranks and conspiracy theorists. The exploits of the Scottish adventurer John Law in the early eighteenth century might be the origin of the claim that truth is stranger than fiction. William Jennings Bryan, who famously demanded that “you shall not crucify mankind upon a cross of gold” was three times Democratic Party candidate for the US Presidency. Major Douglas’s theory of ‘social credit’ was the foundational doctrine of several political parties. Some actually won power in Canadian provinces, though their leaders struggled to explain the practical implications of ‘social credit’ to an increasingly bemused electorate. And the financial crisis of 2008, which demonstrated that bankers’ understanding of the theory of money was less developed than their sense of entitlement to it, gave a new opportunity for old and new bizarre ideas about ‘money’ to emerge.
Money is transferable debt. The nineteenth century Scottish economist Henry Dunning McLeod made the point in dramatic terms; ‘If we were asked who made the discovery which has most deeply affected the fortunes of the human race? We think, after full consideration, we might safely answer – the man who first discovered that debt is a saleable commodity.’ (Macleod, 1872). When Sir Walter Scott left Abbotsford for Naples in the final months of his life, he probably carried a bag of sovereigns – but also a letter of credit to a correspondent bank which would enable him to obtain Neopolitan piastres to throw to the boys on the quayside who carried his trunks.
Money is today, and always has been, a means of transferring credit. Consider the three principal ways in which individuals or businesses transact today. You walk into a Hawick woollen mill and buy a sweater with five ten pound notes. These notes state that the Bank of England promises to pay the bearer, on demand, Ten Pounds Sterling. On its face, the promise is meaningless – if you go to the Bank of England, it will simply replace your £10 note with another.
Still, the British government will accept your notes in payment of taxes – though not readily, and this is not how people pay their taxes in practice. The note will be widely accepted in payment by other people, though much less widely than before the covid pandemic. At that point of acceptance, the Bank of England’s obligation to you becomes its obligation to someone else – the debt is transferred. And under current law and practice, the principal duty of the Bank of England is to maintain the value of the currency – to ensure that these notes will be accepted tomorrow on broadly similar terms to those that apply today.
The most common method of payment, however, is to transfer money between bank accounts. When you pay a £50 electricity bill, the £50 that the Bank of Scotland owes to you becomes £50 that the Royal Bank of Scotland owes Scottish Power. And when you buy the sweater online with a credit card, you incur a debt of £50 to Barclaycard which is converted into a debt of £50 from Worldpay or whatever business is the online shop’s merchant acquirer, to the retailer of the sweater.
The process of converting an obligation from A to B into an obligation from X to Y is an electronic one that frequently has many stages. C substitutes for A, and then D is substituted for B, and so on until the desired final outcome is reached. Several agents may be involved in the chain – some with acronyms like CHAPS and BACS, agents of the major Banks, some private companies such as Visa and Mastercard, the Bank of England, which inter alia serves as the bankers’ bank. This is the digital process of payment and money transmission in a modern economy.
Measures of money
Money is simply transferable debt. Such debt may be issued by governments or private actors and specified in any unit of account. There are different statistical measures of money depending on the identity of the issuer and the term of the debt. The Bank of England reports a variety of such measures of the sterling money supply.
The most familiar and narrowest concept of money is the banknote. The value of notes currently circulating in Scotland is probably around £7bn – £8bn, roughly equally divided between Bank of England notes and those of the Scottish banks (Bank of England, 2021c). (Anomalously, Scottish banks are allowed to issue their own notes, which must, however, be fully backed by Bank of England notes.) This figure should be compared with Scottish national income of around £163bn (National Statistics 2021).
A comparison with overall Scottish government debt is also relevant. Liability for existing UK government debt would remain with the rUK government. The division of assets and liabilities would be a complex and central issue in independence negotiations. It may be reasonable to assume that Scotland would begin independent life carrying, explicitly or implicitly, a pro-rata share of UK debt, which might be in the region of £180bn, and would acquire a share of UK foreign exchange reserves, around £15bn. Scotland would need to borrow to cover its budget deficit after independence, a figure which might initially be between £10bn and £20bn annually. This scale of borrowing should not be difficult to service if the new government showed ordinary fiscal prudence. However, it is likely that international lenders would choose to provide – and look to receive payment in – pounds, dollars or euros rather than bawbees.
Issuance of notes and coins is therefore very small relative to the scale of government borrowing, yet very large relative to the practical need of the public for a medium of exchange. The value of sterling notes held outside the banking system is well over £1000 per head of population, a startlingly high figure. Cash was only used in about 20% of UK transactions in 2019 (down from around 80% in 1990) (Caswell et al., 2020). Since few high value transactions are made in cash, the proportion of the value of transactions represented by cash is much smaller.
Since the pandemic, the amount of cash withdrawn from ATMs has fallen by at least 30% year-on-year, as more vendors prefer or insist on contactless payment. However, the amount of cash in circulation has continued to increase. This may reflect a rise in ‘cash in hand’ self-employed activity during lockdown and furlough. But much of the public holding of cash probably relates to its use in criminal or money laundering activities, a conjecture supported by the still higher level of per capita cash circulating in euros and – especially – dollars (Rogoff, 2017) and the startling proportion of that cash represented by high denomination notes. The shift to electronic money leads many authors to welcome ‘the death of cash’ – an end state already approached in some countries such as Sweden. It is probably all to the good that the bawbee is unlikely to be of much interest to international criminal networks. Debate as to which famous Scots would be portrayed on bawbee notes, although entertaining, is of little relevance.
Innes Smith taught his students to pay particular attention to M0, ‘the monetary base’. M0 adds to notes and coin the amount of operational deposits held by commercial banks at the Bank of England. Banks were at that time required to hold interest free reserves at the Bank of England equivalent to a fraction of their deposits – hence the reference still frequently made to ‘fractional reserve banking’.
The size of the monetary base – the total of the note issue and reserves held at the Central Bank – thus determined the scale of bank lending and deposits – M1 – and control of this base was the essential tool of monetary policy. But these restrictions on banks have been removed, and under the international Basel agreements, which an independent Scotland would be expected to follow, banks are now obliged instead to maintain regulatory capital – shareholder funds – based on their risk-weighted assets. Today, commercial reserves at the Central Bank bear interest and are now simply the amounts these banks decide to place there. These reserves are debts of the Central Bank to the commercial banks and are effectively the debts of its owner – the government
Central Bank reserves are used to facilitate payments between banks. If transfers from Bank of Scotland accounts to Royal Bank accounts exceed the volume of transfers in the opposite direction, the resulting indebtedness of BoS to RBS can be settled by adjusting balances at the Bank of England. A Scottish Central Bank could operate an analogous sterling clearing system in Edinburgh, but need not, since one already exists in London to which all banks operating or likely to operate in Scotland have access. If, however, these banks provided bawbee accounts, then it would be necessary to establish a bawbee clearinghouse in Edinburgh which might, though it need not, be operated by the Scottish Central Bank.
Commercial bank reserves at the Central Bank were formerly the modest amounts needed to lubricate the payments system, but they have grown explosively since the global financial crisis. These deposits far exceed the amount of notes and coin and today total just under £100 billion (Bank of England, 2021b). This growth is mainly the result of ‘quantitative easing’ – the policy under which Central Banks buy long-term government, and some commercial, debt. The effect is not just to fund current government debt through short-term borrowing from financial institutions but to refinance existing debt on a similar basis. The Bank of England has acquired around £900bn of assets in this manner.
While the Central Bank can influence the scale of the money supply – and the Federal Reserve, ECB and Bank of England have done so by flooding markets with short-term government debt – it is households, businesses and financial institutions which determine its scale. M0 is the amount of immediately repayable short-term government debt that commercial banks choose to hold. M1 is now the amounts bank customers, businesses and households choose to hold in their current accounts. M0 is the debt of the Central Bank to the commercial banks, Bank deposits, M1, are debts of the commercial banks to their customers. All money takes the form of transferable debt.
The unit of account
Just as no single agent – government, central bank – today controls the medium or mechanism of exchange, no one ‘owns’ the unit of account. Among large British companies, AstraZeneca and BP choose to present their reports in dollars, Vodafone in euros. All these companies, and many smaller ones, trade in many currencies and maintain both bank accounts and their own management and statutory accounts in many of them. I personally have sterling, dollar and euro accounts and use software that records transactions in multiple currencies. Most physical commodities are traded in dollars and foreign currency mortgages are common in Europe. Within Europe, most exports are invoiced in Euros; outside Europe, more than 80% of all trade takes place in dollars. 80% of cross border liabilities are denominated in dollars or euros. Half of all dollar notes are outside the United States (Bertaut, 2021). No agreement from any central authority is required for any of these things. In particular, neither households, businesses or – potentially – governments need the permission of the Bank of England to use sterling as their unit of account or the Bank’s notes as a medium of exchange.
Currency has substantial network effects. Particularly as a medium of exchange, but also as a unit of account, it is convenient to use the currency which is already locally the most popular. The desirability of aligning the preferred unit of account with trade and employment patterns leads to the concept of an ‘optimum currency area’, which identifies an economically integrated geographical area and minimises the need for adjustments to prices as a result of events elsewhere. That analysis lies behind the concern of the EU with the close association of the single market in goods, the free movement of labour, and the shared currency. Now and for the foreseeable future, England’s status as principal trading partner along with the existence of a common travel area and labour market, whose continuation would presumably be negotiated, means that the UK is the optimum currency area for Scotland.
Thus the choice of currency is nowadays not just a matter for governments but also a matter of the choices made by households and businesses. The machinery of monetary transmission is largely independent of government. In fact for much of history, that machinery operated without any official engagement or sanction and could readily do so again today. Firms and households will choose the units of account most relevant to their own circumstances. All of these mechanisms are now digital. It is difficult to overemphasize the significance of these developments for the Scottish currency debate. The age of Chartalism is at an end. The decisions of households, of Marks and Spencer and Sainsbury’s, of Wood Group and Baillie Gifford, of cab drivers and the Balmoral Hotel, will be as important as those of the Scottish government in determining the outcome.
Government and currency
But governments have three roles concerning currency. The ability to define legal tender. The power to legislate on the use of currency. And the obligation to choose the unit of account in which governments maintain their own accounts, pay bills, and impose and collect taxes.
Governments determine what is legal tender in their jurisdiction. To repay debt in legal tender is to settle it conclusively. In the modern world, legal tender has no practical significance. There could be no better illustration than the curiosity that, by historical accident, the only legal tender in Scotland today is coin from the Royal Mint. If you want to annoy your bank, redeem your mortgage in legal tender. Reckon on about 1,000kg of pound coins per £100,000 outstanding or, if you really want to make trouble, 35,000kg of pennies. You may find your lender prefers other means of payment even if they are not legal tender. And even your cabbie may take the same view.
Governments can influence currency choices by passing legislation. Such laws might require businesses and households to maintain accounts in a particular currency and prohibit the holding of accounts in another currency. Some despotic states have provisions of this kind – typically more honoured in the breach than in the observance – and some of the former Soviet republics did make illegal continued use of the ruble at the break-up of the USSR. It is, I hope, unimaginable that a Scottish government would try to do this.
A more serious option is to legislate to rewrite existing contracts in a new currency. For example, the European Commission issued regulations in 1997 and 1998, binding in all member states, which decreed that all contracts in French Francs were converted at a rate of 6.56 FF to the Euro and imposed similar conversion ratios for all eurozone members (Meyers and Levie, 1998). A Scottish government could legislate that any reference to the pound should be construed as a reference to ten bawbees. But the differences are immediately apparent. The French transition applied to all agreements involving the French Franc, virtually all agreements in French Francs were made under European laws, and the external value of the French franc had been fixed relative to other potential eurozone currencies for several years. As a result, no one perceived any gain or loss as a result of the change or saw any need to rearrange their business or financial affairs in anticipation.
None of these conditions would apply to the introduction of the bawbee by a Scottish government. Self-evidently, most sterling contracts do not involve Scots residents or Scots law. So what would be the scope of the Scottish legislation? Whose pounds, exactly, would be translated into bawbees? As the Greek government has learnt, the logistics of joining a currency union are much easier than the logistics of leaving one.
Unless the change were purely cosmetic – a possibility, as in the earlier 1960 French legislation which substituted one New Franc for 100 old Francs, and an option which will be discussed further below – the move would have some effect, positive or negative, on the value of existing loans, mortgages and bank deposits which were in some manner related to Scotland. The consequential gains and losses raise problems of equity, politics and law. While a reduction in the burden of existing mortgages would undoubtedly be welcomed, a corresponding reduction in the value of existing bank deposits and pensions would not. If the bawbee represented an appreciation, mortgagees would be upset, but depositors and pensioners delighted. The measure would invite claims of expropriation and challenge under the European Convention on Human Rights, to which Scotland would presumptively be a signatory.
Perhaps more seriously still, anticipation of such changes and associated uncertainty would lead to damaging preemptive action. Czechoslovakia experienced such major disruption at the break up of its monetary union, even in the context of a tightly-controlled financial system inherited from its recently Communist past. As the introduction of the bawbee approached, loans secured against Scottish property would be hard to obtain; the savings of Scots residents would be moved outside the potential jurisdiction of Scots law (capital flight). The financially sophisticated would gain at the expense of the rest of the population.
In the light of these considerations, it is essential that any discussion of currency options after independence make clear that a future Scottish Government would have no intention of changing the terms of its own existing contracts or of legislating to change the terms of private contracts. This assurance should particularly include, but should not be confined to, agreements governing savings and loans, employment and pensions. This paragraph is the most important in this essay.
The introduction of the bawbee
A minimalist option for the introduction of a new currency involves the issue of a limited number of notes. The channel island of Jersey prints Jersey pounds (so do Guernsey, Alderney, and the Isle of Man). These notes are treated as interchangeable with Bank of England notes within the islands. The pound notes affirm that the States of Jersey (the island’s government) promises to pay the bearer one pound on demand and I imagine that if you turned up at the office of the Jersey Treasury someone would, with mild amusement, reach into pocket or purse and pull out a coin from the Royal Mint. Jersey law limits the note issue to £125 million and this exceeds substantially the amount of actual issue; adjusting pro rata for population this limit would equate to £6.3 billion for Sctoland.(Currency Notes (Jersey) Law, 1959). Jersey institutions maintain bank accounts for customers in all major currencies; Jersey residents make everyday banking transactions in pounds and the question of whether these are Jersey pounds or pounds sterling simply does not arise. It is relevant that Jersey has a substantial offshore financial services sector, and therefore needs to maintain a reputation for cautious and conservative economic management, and does.
The only Jersey pounds which exist are those which are printed on behalf of the States of Jersey. But, as described above, most currency in modern economies is created by the private sector: principally, but not necessarily, by commercial banks. Money is transferable debt, and anyone can incur debt in any currency they choose if they can find someone willing to accept it. The Jersey pound is little different from monopoly money and its only economic significance is the modest seignorage which the States of Jersey derives from its issuance.
The key to any currency transition is the decision to change the government’s own unit of account. Every government must decide in which currency it will keep its own records, pay its employees and beneficiaries and require payment of taxes. Most Scottish government expenditure is in fact incurred through agents with some autonomy – local authorities and NHS trusts are the largest recipients – but it can be expected that these would choose, or be required, to follow the lead of central government. This choice of accounting system is the third, and most important way, in which government influences currency in the modern world.
It is a choice that does not necessarily have any implication for private actors. To illustrate with a ludicrous thought experiment, if the Scottish government chose to adopt bitcoin or the Vietnamese dong for its receipts and payments, then an exchange booth might immediately spring up in St Andrew Square to enable bitcoin or dongs to be readily converted to and from some more practically useful medium of exchange. Neither Satoshi Nakamoto nor the Central Bank of Vietnam need be consulted. And the coffee shop in the Square would no doubt continue to accept sterling and prefer plastic cards.
In practice, it is unlikely that the Scottish Government would make any payments at all in cash. The days when pensioners queued at post offices each week clutching a book of vouchers have gone and the UK government is currently finally phasing out the small residual cash payments of benefits made in this way. Virtually all Scottish Government expenditure would be made by direct transfer to the commercial bank accounts of recipients. If the payments were in bitcoin or dongs, the recipient bank would likely effect the conversion automatically, and the exchange booth would enjoy little, if any, custom. The expectation of such immediate conversion means that the Scottish Government would need to adjust its payments in bitcoin or dongs to maintain the value of its payroll to the recipients, and to secure supplies of goods and services in the face of fluctuation in the exchange rate of the dong or the value of bitcoin.
How much changes if the payments are in bawbees? If, as described above, the bawbee is to be used only in agreements made after its introduction, it is not apparent that businesses and households would have much desire to make such agreements. On Independence Day, almost every adult in Scotland would have a fistful of pound notes and a sterling bank account, many would have a credit card agreement denominated in sterling. Every business operating in Scotland would have a sterling bank account. Some would want to change these to bawbees out of patriotic fervour; others might take the opposite view. And many, uninterested in political statements, might simply prefer the familiar to the new.
Police Constable Rabbie Burns, receiving his pay in his newly established bawbee account, might want to celebrate the monetary transition with a wee dram. Most transactions in shops and places of refreshment would, as now, be made using plastic cards and the existence of more than one currency would accelerate the displacement of cash. The tickets on shop shelves might be labelled in pounds or bawbees or, as in the eurozone for several years, in both. And at online retail sites, be quoted in whatever currency the buyers chose.
But how much would Constable Burns receive? (The bulk of Sir Walter Scott’s royalties would continue to be paid in sterling, and the manager of the Hawick Woollen Mill might sensibly wait to see how the transition evolved.) The Scottish Government would presumably determine an initial exchange rate, say ten bawbees to the pound, so that PC Burns’ £25000 annual salary might become BB 250000. And the Scottish Government might also offer to sell ten bawbees in return for a pound.
But would it also offer to buy them at that or a similar rate? Counter-intuitively, the demand for bawbees might initially exceed supply, since although Scottish Government expenditure would exceed tax payments, much of that expenditure – pensions, payments to contractors, etc. – would continue to be denominated in sterling. Situations in which demand exceeds supply in the short run but the balance is likely to be reversed in the long run are those for which financial speculation was invented. Either the Scottish Central Bank is willing to buy bawbees at ten to the pound, in which case it may have to buy rather a lot of them, or it is not, and Constable Burns is at the mercy of global finance. Recall that in 1992 George Soros and a handful of other speculators were able to break the Bank of England (established 1694).
This is only a preliminary sketch of some problems involved in a currency transition. Such transitions are not impossible and the appendix describes international experience. Relevant and successful examples are the transitions in Ireland and Singapore. But both of these were some time ago and occurred in the context of economies that were then far less developed than modern Scotland and a global financial system far less complex than exists today. The only transitions that have occurred since the 1971 breakdown of the Bretton Woods system are those associated with the establishment of the eurozone and the collapse of the Soviet era. Thus there are no relevant precedents.
The very clear lesson of past transitions is that successful transition is gradual, and this would be true of any transition to the bawbee. A lesson from other experiences is that abrupt and botched transition can cause considerable economic damage and personal distress, although eventually governments and the private sector together evolve some functioning system of money and credit.
The wag who said the Scottish currency should be called the thistle – lovely to look at but not to hold – made a serious point. There is a real possibility that a premature and ill-planned introduction of a Scottish currency would be an embarrassing fiasco, ignored by most of the world and unappreciated by Scottish residents.
Given the considerable difficulties of dissolving the existing monetary union, it is appropriate to review the advantages which might accrue from it. An independent Scotland with its own currency would be able to determine its own monetary policy. It could also allow the value of its currency to float, in recognition of any particular character of Scotland’s imports and exports and any particular pattern of growth or recession in the Scottish economy. It could derive seignorage; banknotes represent interest-free borrowing, and the interest saving has value. And an independent Scotland could attempt to borrow in bawbees rather than an established internationally-traded currency.
Three small west European countries – Norway, Denmark and Sweden – remain outside the eurozone. Norway is a special case because of the dominance of oil revenues and its decision to remain outside the EU. Denmark rejected eurozone membership in a 1992 referendum but has nevertheless pegged its currency to the euro. As in Hong Kong, with which it shares the honour of successfully linking its currency to another over a long period, Denmark’s currency would appreciate if unpegged, with the consequence that foreign currency reserves have accumulated and interest rates are marginally lower than in the eurozone – some Danes have obtained negative rate mortgages although fees make this less attractive than it sounds. Denmark and Hong Kong are both able to call on substantial foreign currency reserves. But they do not need to; these reserves are the result of a long period of undervaluation of their currencies rather than the source of the ability to sustain the peg. In Denmark as in Sweden cash has almost disappeared from daily transactions although shops are still legally obliged to accept it.
Sweden, outside the eurozone and with no intention of joining, may provide the model of independent financial aspiration for an independent Scotland, although as with all the Scandinavian countries the EU is its principal trading partner. Sweden has a long history of prudent financial management and is one of the very few small countries able to borrow internationally in its own currency on a significant scale.
Still, as can be seen in the graphs below, the degree of independence of Sweden’s monetary policies from those of the ECB is limited: the Swedish Kronor has been stable against the Euro as compared to the US Dollar; and their interest rate decisions follow the ECB closely. Sweden attempted to return interest rates to more normal levels after the financial crisis more rapidly than the ECB but abandoned this policy after experiencing capital inflows and unwanted appreciation of the kronor. Small open economies like Sweden – or an independent Scotland – may theoretically be able to run an independent monetary policy; but in practice their larger neighbours exercise considerable influence and the central bank cannot diverge too far from them.
Since the 2008 global financial crisis and the reduction of official interest rates to almost zero, the principal tool of monetary policy has been quantitative easing – the process described above of financing purchases of long-term debt and other assets with short-term borrowing from the commercial banking system. This process is commonly but misleadingly described as ‘printing money’. This essay is not the place to assess the rationale or effectiveness of these measures, (see House of Lords Economic Affairs Committee, 2021 for a summary) but it is appropriate to review the ability of a Scottish Central Bank to carry out such policies.
It is unlikely that there would be any considerable amount of either government or private long-term debt denominated in bawbees in the short or medium term. The Scottish government could, however, issue fresh long-term debt in any currency and encourage the Scottish Central Bank to buy it with bawbees. The Bank could even buy tangible assets – housing, offices, warehouses – but would need to persuade financial institutions or citizens to hold the short-term bawbee debt issued to pay for them. It is difficult to envisage much demand for such debt. The asset-holding patterns of Scots residents and institutions would be influenced little by the policies of the Scottish Central Bank but much by the policies of the Bank of England, the ECB, and the US Fed. This financial interdependence remains a reality whether Scotland is constitutionally independent or not.
Banking in an independent Scotland
What might a Scottish banking system look like after a successful transition to the bawbee – one in which the bawbee was widely, though almost certainly far from universally, used by Scottish residents and businesses?
M1 – narrow money – adds to M0 the current account balances maintained by households and businesses. A pro-rata share of the UK figure would indicate that Scots might maintain balances of around £200bn (Bank of England, 2021a). However, conditions after independence would determine the nature and location of these balances. At present, all banks operating in Scotland are members of groups with the majority of their activities outside Scotland. These banks might take deposits from Scottish resident individuals and businesses through branches – which might be virtual branches – or by establishing Scottish subsidiaries. These deposits might be of sterling, bawbees, or indeed dollars or euros and would be repayable in the currency of deposit and transferable to the currency of the depositor’s choice. It is realistic to anticipate that a substantial fraction of this £200bn of ‘money’ might be held outside Scotland and in currencies other than bawbees. This currency diversification is still more likely to be true of M3 or M4 – ‘broad money’, which includes other short-term assets such as Treasury bills and commercial paper. Like all measures of ‘money’ broad money holdings have increased substantially over the past decade as a result of ‘quantitative easing’.
Because money markets are global, and the international demand for bawbees likely to be limited, especially in the short term, both the scale and denomination of broad money held by Scots households and businesses would be a product of their decisions and international forces rather than the actions of a Scottish Central Bank. The measure of ‘broad money’ relevant to the Scottish economy would be much wider than bawbee M4 and much narrower than sterling M4.
Under retained EU law, the EEA principle that regulation of bank branches and liability for their deposit insurance lies with the home country but responsibility for subsidiaries with the host continues to apply. This rule would seem likely to remain as part of the Scottish independence settlement. Liability for such insurance falls – at least in the first instance – on other financial institutions. A Scottish Government would sensibly require Scottish-based subsidiaries to maintain at all times sufficient collateral of high quality assets to enable their operations to be taken over by the Scottish Central Bank if their ability to meet their obligations was in doubt. (A regime described as one of ‘pawnbroker for all seasons’ by former Governor of the Bank of England Mervyn King.) (The End of Alchemy, 2016)
That regime could secure the stability of the Scottish monetary system at little or no actual or potential cost to the Scottish taxpayer. The Scottish Central Bank has neither resources nor obligation to act as ‘lender of last resort’. (The concept of lender of last resort came into use in the nineteenth century to describe emergency liquidity assistance to solvent banks. By 2008 the meaning appeared to have been extended to include a duty to bail out failing international banks.) The Scottish government does, however, have resources and obligation to protect the deposits of Scottish households and SMEs and secure the continued functioning of the payments system in Scotland, and could and should act accordingly.
The opportunities and difficulties that currency questions would raise for an independent Scotland have both been greatly exaggerated. The debate is unduly influenced by an outdated Chartalist model in which coinage stands alongside flag, anthem and army as symbols of sovereignty; and by an understanding of money and banking also derived from a bygone era. For better and worse, most decisions about currency, money and banking in an independent Scotland will not be made by a Scottish Government or Central Bank but by individual businesses and households, by international banks, by foreign exchange markets controlled by no one at all, by the Federal Reserve and the European Central Bank, and by the influential Central Bank in Scotland’s larger neighbour and principal trading partner.
Nevertheless, the circulation of ideas that are poorly thought through, even if they are not implemented, can damage the credibility of a future Scottish government and the reputation of a financial services sector which is an essential contributor to the Scottish economy. It is not the case that an independent Scotland could be free of constraints on public expenditure because it could print its own money. Or that the country could expect to maintain the value of the bawbee through foreign exchange reserves built by the issuance of short-term government debt denominated in bawbees.Nor is it plausible that the Sauchiehall St branch of a London-based bank could supply its customers with dollars or euros or, with a few days notice, Vietnamese dongs but would be unable to provide them with sterling. (All these arguments have been presented, evidently seriously, by protagonists in the currency debate.) But if people think these things might happen, they will take steps to protect themselves against them, actions which may be costly to them as individuals and detrimental to the Scottish economy. And while there may be good arguments against separatism, the assertion that countries need to be big so that they can rescue too big to fail banks is not one of them. The lesson for the newly appointed Governors of the Scottish Central Bank, and the Ministers who appoint them, is clear – first do no harm.
The recommendation of the Sustainable Growth Commission that an independent Scottish government should continue to use sterling as its unit of account for the foreseeable future, with the consequence that its citizens would continue to use sterling as the medium of exchange (to the steadily diminishing extent that they use any currency as medium of exchange) is a prudent and feasible approach (Sustainable Growth Commission, 2018). Once an independent Scottish government has established its credentials for fiscal responsibility with its own population and the international financial community, once trading patterns have adapted to new constitutional arrangements, there would be an opportunity to review these arrangements. But in the short term, there is little to gain and much to lose from precipitate change – or the threat of it.
The crookit bawbee
Ye ken na the laddie that gied ye the penny
Ye ken na the laddie wha’s been true tae thee
But I ken the lassie wha wears the auld plaidy
The lassie that’s keepit ma crookit bawbee
And are ye the laddie that gied me the penny?
The laddie I’ll loe till the day that I dee
Ye may clad me in satin and mak me a lady
And I will gang wi ye tae bonnie Glenshee
Traditional Scottish folksong
Currency Transitions in other countries
Leaving a monetary union and creating a new currency is, historically speaking, a rare event. And when historical examples are sought for questions to do with currency, the experience of Weimar Germany, Venezuela, and Zimbabwe loom large – none of which are good comparisons for an independent Scotland. There are, however, some useful case studies that can shed some light on what might happen, whilst not exactly paralleling it.
The Irish Free State (subsequently the Republic of Ireland) came into being in 1922 and initially no changes were made to monetary arrangements – both Bank of England notes and others issued by Irish banks but fully backed by sterling notes, as the Scottish bank note issue is today, continued to circulate. In 1926 the Irish Punt was launched – but as a currency fully convertible to Sterling, with an independent Currency Commission holding a mixture of Sterling notes, British government debt, and gold (as Britain had returned to the gold standard in 1925). Over time, Ireland began to develop its monetary institutions, but very gradually – its central bank was set up in 1940 when the war disrupted relations between neutral Ireland and the belligerent UK. The Central Bank of Ireland acquired new powers over subsequent decades but the main goal was maintaining the Sterling peg.
Change eventually came in 1979, when Ireland entered the European Monetary System (EMS). In practice, this meant that it agreed to ensure the Punt did not move too far out of alignment with the other 7 currencies in the EMS. Sterling was not amongst these, and so fairly soon the link was broken. But Ireland was just exchanging one source of discipline for another. And in 1999 it took this one step further, becoming a founding member of the Euro.
The Republic’s aim, throughout its history, had been to prioritise stability – for citizens and traders – over monetary flexibility. Switching from Sterling to the EMS was not a sudden decision, but the culmination of years of analysis and debate as to whether the United Kingdom or EMS nations were the more important trading partner. And because it had gradually built up the credibility of the Punt – which meant gradually building up the credibility of the Republic’s government and institutions, and foreign reserves – Ireland was in a position to make that change. Banks provide a good analogy: we are relaxed about the fact that established banks cannot pay back all depositors if they all demanded their money at once, because we don’t believe that they will. But if a new bank was set up, outside of existing juridictions, we would be more sceptical. Over time, it would acquire credibility, and not have to keep such a large proportion of deposits on hand. Similarly, a currency need not be fully backed when it is mature, but when it begins this is much more important.
Singapore became independent in 1965, and followed a similar path to Ireland. Whilst it was part of the Straits Settlement with Malaysia, it had a common currency, but in 1967 it issued its own Singapore dollar. This was pegged to Sterling until 1972, and then the US Dollar, but when the Bretton Woods system collapsed in 1973 Singapore had to find a new ‘nominal anchor’. After a few years of experimentation – supported by the reserves the Currency Commission had built up in the decades before – it moved to a ‘managed float’: its Monetary Authority (central bank) buys and sells currency to keep the Singaporean Dollar roughly stable against a basket of other currencies, with the importance of each currency in the basket being determined by how much trade they had with Singapore. Because Singapore is so dependent on imports and exports, this was (in their view) the most effective way to prevent surges in inflation.
We can see similarities with Ireland here – the focus on stability and basing exchange rate policy on trade – but also differences, enabled by Singapore’s long history of acquiring foreign currency reserves.
In 1901 Australia’s 6 colonies federated, but they mainly still used British currency until 1910, when the Australian pound was established and pegged at parity to Sterling. Australia mainly stuck to that peg – throughout the period of the gold standard, and then in Bretton Woods – although between 1929 and 1931 the Australian pound was devalued. The logic was the same as Ireland’s: most of Australia’s trade was denominated in Sterling, so a peg would keep trade and inflation relatively stable. In 1966 Australia decimalised its currency, launching the Australian dollar to replace the Australian pound, and in 1971 the Reserve Bank changed the currency’s peg from Sterling to the US dollar. This proved unsatisfactory and new arrangements were tried – first pegging against a basket of currencies, as Singapore does, and then changing this to a ‘crawling peg’ which was regularly updated – and in 1983 the Australian dollar was finally allowed to float freely.
Choosing to let the Australian dollar float was a response to two pressures. Firstly, in the 1980s ‘monetary targeting’ became popular – the idea that to manage inflation central banks should directly target the quantity of currency. (Readers who paid attention to the definitions at the beginning of this piece might ask which quantity: M0, M1, M4? This was indeed one of the problems with the policy.) This is difficult to do whilst maintaining a fixed exchange rate, because the central bank is committed to meeting all the currency trades offered to it, and so is constantly adjusting the money supply for those reasons. Secondly, speculators realised that the Australian dollar would have to appreciate and so poured money into the economy, buying from the central bank at what they considered a low price. The government realised that they would either have to stop these flows by imposing capital control – stopping money flowing into the country, which they did not want to do – or by floating and letting the currency appreciate (which, as the speculators expected, it initially did).
In 1989 Czechoslovakia experienced its ‘Velvet Revolution’ – a remarkably peaceful transition out of Communism. The union of Czechs and Slovaks, however, was not sustainable, and when elections in 1992 resulted in different parties controlling the Czech and Slovak areas of the federation, it was decided that they should separate. The plan was for both to retain their common currency, the koruna, for 6 months and perhaps longer, with governance by a Monetary Committee with members from both countries’ central banks.
However, the economies of the new countries were too different from each other for this to be sustainable: the new Czech Republic had already had a stronger economy and much more foreign investment, but because there were no longer fiscal transfers into Slovakia this led to a growing imbalance between the two. Observing this, and knowing that the monetary union was temporary, Czechs and Slovaks expected the new Slovak currency, when it appeared, to immediately devalue against the new Czech currency. This meant that a coruna in the Czech Republic was effectively worth more than a coruna in Slovakia, and so they flowed westwards: through trade; bank transfers; rapid payment of debts; etc. Releasing the situation was unsustainable, the governments agreed to end the monetary union after just 6 weeks. Notes were ‘stamped’ in each country, and were then exchangeable for the two new currencies which were brought into existence. This put an end to the excessive cross-border flows and, because it was accomplished rapidly, did not cause too much economic dislocation. The new Slovak koruna did depreciate against the new Czech koruna, but thereafter the economies stabilised and, in 2008, Slovakia adopted the Euro.
The breakup of the USSR led to similar problems – although because of the number of new states formed, some of which were antagonistic to Russia, there was a broader array of responses. Initially there was a ‘ruble zone’, with Russia providing official rubles and newly-independent states creating ‘coupon currencies’: unofficial rubles only for use within the country. In theory these were equivalent to rubles; in practice, they traded at a discount, not least because the new states took advantage of the seignorage revenue available from printing and so oversupplied them. Inflation was very high anyway – by 1993 it was still over 10% per month in Russia – and the new republics faced very different economic prospects and policies, like the Czech Republic and Slovakia writ large.
The Baltics moved first – they were eager to reform their economies and saw leaving the ruble behind as a necessary part of this. Estonia chose to make the change very quickly: a currency board was set up to back the kroon, which was pegged to the Deutschmark. (It held reserves to fully back the monetary base, but not all the money created by private banks.) Adoption of the kroon was further ‘encouraged’ by banning transactions in rubles. This is an example of what Lotz and Rochereau have referred to as a ‘launching vehicle’ for a new currency: governments can make new currencies legal tender and, more importantly, make the old currency illegal. In contrast, Latvia introduced the Latvian ruble but did not ban the use of foreign currencies, and it was estimated that by the end of 1992 up to half of transactions were not made in the Latvian ruble.
Another ‘launching vehicle’ is the compulsory removal of all the old currency. This is especially important when that old currency still exists and so can be used elsewhere. Kyrgyzstan set up a new currency, the som, but did not forcibly redenominate rubles in the country, instead leaving it up to citizens. Mindful of their dependence on Russia for imports, and perhaps suspecting the new currency would initially depreciate, only a few did so: a quarter of the rubles were exchanged for som.
Both of these ‘launching vehicles’ are examples of government power being deployed to force the general adoption of a new currency. Both would likely be considered inappropriate in the Scottish context. However, there is another way to promote a new currency: outcompeting an existing one. The Baltics resisted the urge to run large government deficits when they adopted the new currencies, reducing the pressure to create seigniorage revenues and therefore building trust in them – given high inflation rates in Russia, this likely played some role in encouraging adoption of the new currencies. This is, in a sense, the reverse of ‘dollarisation’: when a more stable currency such as the US Dollar crowds out a local, unstable currency. Zimbabwe is a tragic, but not isolated, example.
The transition that did not happen
We can also examine a case where a change in currency did not take place, but fears that it might sparked panic. As the hardest-hit country in the European sovereign debt crisis, Greece endured frequent speculation as to whether it would remain in the Eurozone. A common (and correct) diagnosis was that the Euro was overvalued from Greece’s perspective, making its exports too expensive and its economy uncompetitive, which in turn meant it had no way to dig its way out of the sovereign debt hole it was in. Since it did not control exchange rate policy, it could not devalue the Euro, so the only way to become more competitive was ‘deflation’: lowering the cost of producing goods in Greece. Unfortunately, this would mean lowering Greek wages – probably through a large bout of unemployment – which was understandably unpopular in Greece. But there was a potential solution: Greece could leave the Euro, readopt the drachma, and let that depreciate against the Euro.
The problem with this plan was that it was predictable. Like the Slovaks before them, the Greeks – and others with money in the country – sought to withdraw it, so that it would not be trapped by capital controls, redenominated, and then devalued. Some transferred it to bank accounts abroad, especially in Britain and Cyprus; those who could not do this withdrew cash, sometimes even storing it in safety deposit boxes at banks! The reasoning was that, since the Euro would not cease to exist, cash kept out of the authority’s sight would escape the redenomination and could later be retrieved. Billions left the banking system, and Grexit did not happen.
Scotland’s currency and EU membership
If Scotland were to rejoin the EU while rUK remained outside, labour markets, trade flows and other economic conditions might develop in such a way that Europe would be a more likely optimum currency area – although even now it is hard to argue that the entire eurozone represents an optimum currency area. And Scotland would be required to acknowledge that the currency of the EU is the euro. But initially Scotland would not even come close to meeting the Maastricht criteria for eurozone membership and it is likely that both Scotland and its EU partners could agree that adoption of the euro is no more than a far distant aspiration.
There is, however, a more immediate issue. For a country to join the EU, each chapter of the Acquis (the EU’s body of law) must be ‘closed’, i.e., the new member must agree to implement it. Chapter 17 states:
“New Member States are also committed to complying with the criteria laid down in the Treaty in order to be able to adopt the euro in due course after accession. Until then, they will participate in the Economic and Monetary Union as a Member State with a derogation from the use of the euro and shall treat their exchange rates as a matter of common concern.”
To adopt the Euro, countries must meet the Maastricht criteria: the relevant one is “Exchange rate stability”, defined as “Participation in ERM [Exchange Rate Mechanism] II for at least 2 years without severe tensions, in particular without devaluing against the euro”.
In practice, the Maastricht criteria are a more strict version of ‘treating exchange rates as a matter of common concern’. The potential problem for Scotland, if it continues to use Sterling, the potential problem for Scotland is that it has no control over the £/€ exchange rate. On a straightforward reading of the legal text, this might seem to prevent Scotland from joining the EU.
But things are not so simple. As discussed above, even if a Scottish government ‘adopted the euro’ many Scottish residents and businesses would continue to hold sterling accounts and trade in sterling; even if Scotland did not adopt the euro they might hold euro accounts and trade in euros. The phrase ‘treat as a matter of common concern’ is not precise – and, as with much involving the EU, is not intended to be.
Montenegro is currently applying to join the EU and has as its currency… the Euro. The spirit of the criteria is met; but the terms of the text are not, since Montenegro cannot participate in the ERM II. A solution will obviously be found. And it seems reasonable to believe that the same could be worked out for Scotland, even if Scotland continued to use Sterling as its primary de facto currency. One option would be to establish the bawbee as little more than a souvenir currency, initially pegged against sterling and backed 1:1 by Sterling reserves, but with the aim of it maturing in the fullness of time and Scotland playing a more active role in its management vis-à-vis the Euro. And of course, the fullness of time might (to the satisfaction of all involved) be a very long time indeed.
There are greater impediments to Scotland joining the EU than arguments over exchange rates: the analogue of the Irish Border problem is the obvious one; and opposition from members such as Belgium and Spain, who have their own reasons for discouraging separatism, is another. The impact of Scotland’s currency choice on potential EU membership is a matter of judgement for the reader, but it is unlikely to be the straw that breaks the European-bound camel’s back. The EU has a pragmatic history of finding a way when there is political will, and encountering real or imaginary obstacles when there is not.
There is considerable current interest in the idea of central bank digital currencies. The key idea is that anyone would be able to set up their own Central Bank account which they could access electronically. This would confer an explicit government guarantee on depositors, bypass the often inefficient intermediary services of existing banks, and remove the opportunity for these banks to use their deposit base as collateral for their speculative trading activities. Fintech businesses (formerly known as banks) could compete to provide user-friendly access to Central Bank deposits and the Central Bank could lend to credit-providing businesses (formerly known as banks) against high quality collateral, such as residential mortgages, which are much the largest component of current bank lending to non-financial borrowers. Some people favour the greater potential control over lending which this would confer on government and its agencies; others, including the present author, regard this as a drawback. Money transmission systems are already electronic. Effectively, central bank digital currency is a possible means of modernising an antiquated but entrenched banking system by stealth and it is conceivable that Scotland could be an international pioneer in banking for the fintech era.
Appendix 5 Modern Monetary Theory
Modern Monetary Theory (MMT) begins from the correct observation that the analogy between household management national budgeting, widely attributed to and employed by, Margaret Thatcher, is flawed. Government is immortal and it can always roll over its liabilities.
MMT then conflates two premises. One, which has considerable merit, is that if the economy is operating at less than full capacity governments can and should incur deficits until the emergence of inflation signals that full capacity is being reached. The other premise is that if a government is the sovereign issuer of its currency, it can never default on its debt because it can always print more money to repay that debt, and hence there are few practical constraints on the level of government borrowing to finance public spending.
It does not require a sophisticated understanding of international finance to see the flaw in the second premise. Lending to a government that espouses such thinking would not even be attractive even to domestic savers, far less international capital markets.
Many people unfamiliar with the relevant data have a greatly exaggerated sense of the economic significance of notes and coin. As discussed above, physical currency in circulation in Scotland is of the order of £7 billion. This compares with a likely annual budget deficit of twice that figure and is less than 5% of the likely level of Scottish government indebtedness. Put another way, if the Scottish government were to increase public spending by 5% and finance the expenditure by printing money, the quantity of notes in circulation would rise by 40% per year. That is the road to the economies of Venezuela and Zimbabwe.
Much confusion arises from the common practice of describing the issuance of short-term debt as ‘printing money’. Some advocates of MMT and similar policies do not literally mean ‘printing money’ but regard commercial bank reserves at the Central Bank as the same thing, presumably because such reserves are freely exchangeable for banknotes. But the ability literally to print money is the capacity – the only capacity – that distinguishes a government with its sovereign national currency from any other borrower. A government that does not control its local currency, or a private business such as a bank or large industrial company can also issue short-term debt to the commercial banking system and can roll it over on a daily basis; the (unimportant) difference is that it cannot print banknotes in repayment – unimportant because the demand for banknotes is small relative to the principal monetary and other economic aggregates.
Bringing about an increase in commercial bank holdings at the Central Bank is not the same thing as ‘printing money’ and as described in the text, commercial banks today hold reserves at the Central Bank only if they want to do so. The Central Bank can create such indebtedness only to the extent that banks find it attractive to hold these reserves, or temporarily until these banks substitute other forms of short-term lending – to government or private borrowers.
MMT originates in the United States of America and its advocates are perhaps unduly influenced by US practice and experience. The dollar is the premier international reserve currency and 80% of all foreign exchange holdings are of dollar or euros. Almost half of all dollar notes are thought to be outside the United States. It is tempting, and not wholly fanciful, to think that demand for dollars and dollar securities is inexhaustible. That would certainly not be true of the demand for freshly minted bawbees.
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