In the United States, the Treasury bond repurchase market is huge. As of October 20, 1993, the balance of Treasury bond repurchases carried out by primary dealers reached US$852 billion, accounting for 29% of the balance of tradable bonds at the end of the third quarter of 1993. Among them, the balance of overnight and continuous repos (Continuing Repos, which refers to repurchase agreements in which both parties to the transaction have the right to terminate at any time) is 466 billion yuan, accounting for 54.7%, and the other 386 billion yuan is the repurchase agreement with a relatively long term. Primary dealers also carried out repurchase business, with a balance of US$670 billion during the same period. Securities lending was modest, with primary dealers lending $5 billion and borrowing $184 billion.
In the mid-1980s, a number of Treasury dealers went out of business, leading to the bankruptcy of several savings and loan associations, and the subsequent collapse of the Ohio Deposit Insurance Corporation. One of the reasons for the collapse of the brokerage firm was that after signing a repurchase agreement with a customer, it did not transfer the agreed securities into the customer's account, but instead used the same securities to conduct repurchase transactions repeatedly. Two of the treasury bond dealers, the dealers, have a single business and are only engaged in the buying and selling of treasury bonds, so the supervision they received was originally very loose. After the problem arose, the Government Bond Act passed in 1986 placed government bond dealers under the supervision and management of the Treasury Department and the Securities and Exchange Commission (SEC).
The repo market in other Western countries is much smaller, and many countries have regulatory or tax restrictions on securities repurchases and securities lending. In Japan, repo transactions are called Gensaki transactions. At the end of September 1993, the balance of Japan's repurchase transactions (including non-government bonds) was 10.6 trillion yen ($101 billion), accounting for 9.8% of the balance of national debt. Among them, the short-term treasury bond repurchase market is relatively active, accounting for 28% of the treasury bond trading volume, and securities companies are the main fund borrowers. Japan regards long-term government bond repurchases as a form of securities trading and is therefore subject to transaction tax. The tax rate for securities sold by financial institutions is 0.01% of the transaction price, and that of non-financial institutions is 0.03%; both the repurchase party and the reseller party are required to pay tax when selling securities, and the scale of long-term government bond repurchase is therefore greatly restricted. In 1989, Japan launched a securities lending business (Bond Lending). Since it did not pay transaction tax, it developed rapidly and became an important source of liquidity in the securities market. The securities lending period is as short as overnight; on the contrary, short-term trading business is rarely carried out because of the high tax burden and high cost.
Germany’s repurchase transactions are unique. Banks that borrow repurchase funds must withdraw a certain proportion of reserves according to regulations. In this way, the existence of the repo market in the country is effectively eliminated. The German Bund repo market in London is very private, with most transactions in long-term bonds. This market is closely linked to trading in German Bund futures contracts, and German companies are active on the market.
The French government bond repurchase traders are two high-level executives, Uncle Nei and Overseas. Although there are no tax restrictions on the domestic repurchase market, there are great uncertainties that hinder the development of the market; at the end of 1993, the French government passed a law to eliminate these uncertainties. As of December 1993, the domestic repurchase balance was approximately 200 billion francs, roughly twice the overseas repurchase balance. Italy's domestic repo market is also relatively developed, and long-term government bond transactions are particularly active. At the end of 1993, the balance of repo transactions, including interbank repos, was 92 trillion liras.
In the UK, there is no market for gilts among the private sector, and there is only a limited gilt borrowing market that allows gilt market makers to borrow gilts through exchange money brokers. In January 1994, the Bank of England activated gilt securities repos as a regulated open market instrument. Canada's treasury bond repurchase market is very flexible. In 1992, the cross-border repurchase tax was abolished, and U.S. investors joined in, which effectively promoted the development of the market.
There are also many problems in the repurchase markets of various countries. First, the legal validity of repurchase agreements has not been well resolved on some occasions. The repurchase agreement has the nature of the old school of mortgage lending, but in the event of bankruptcy, the repurchase agreement has legal uncertainty and may not be accepted during bankruptcy liquidation. Another issue is the tax burden. Repurchase agreements combine mortgage borrowing and securities loans, but they are not loans in the usual sense. In fact, they are more like a bond sale with a resale futures contract. In some cases, particularly when a dealer conducting a repo business lends the counterparty custody of the securities, the question also arises of what constitutes a true transfer of ownership of the securities.
There is also a technical issue, namely the settlement of repurchase agreements and securities lending. In principle, the settlement method of these transactions is the same as the settlement of cash transactions of securities, but due to the complexity of repurchase transactions, it is very difficult to implement them in practice.
Finally, repurchase agreements may create potential "systemic" problems. Hedged-traded funds sometimes make large leveraged purchases in the Treasury market, and securities firms issue mortgage loans to the funds through repurchase agreements. A typical repurchase agreement has a short term (less than one week), and because security prices often fluctuate, the starting price of the mortgage security slightly exceeds the loan amount. If the market price fluctuates too much, securities companies will face the problem of insufficient collateral.