Bank Stress Tests and the Problem of Ignoring Reality

“Too large a proportion of recent "mathematical" economics are mere concoctions, as imprecise as the initial assumptions they rest on, which allow the author to lose sight of the complexities and interdependencies of the real world in a maze of pretentious and unhelpful symbols.”

                                                                                        - John Maynard Keynes

The 2011 European Bank stress tests were largely held in disregard.  They had managed to assume away the implications of a chief risk held by the banks being tested – that countries within the EU could default – culminating in several banks easily passing the tests, only to fail soon thereafter.

The results were released in July 2011, with Dexia and Bankia and the Cypriot banks passing and sometimes easily passing the tests. Dexia failed in October 2011. Bankia survived a little while longer, before being nationalized in May 2012. The Cypriot banks never triggered any kind of concerns among the key monitoring agencies, the EU, EBA, IMF or BIS, well, not before the Cypriot banking collapse.

The editorial board at Bloomberg View just put out a piece on why the US Fed's bank tests lack credibility.  Same problem, here: a lack of basis in reality:

"...the simulation [being run] is a far cry from what happens in a real crisis. It doesn't fully capture how contagion can afflict many of a bank's counterparties at once, magnifying losses many times over. It also assumes that a thin minimum layer of equity capital -- just $4 per $100 in assets -- would be enough to maintain the market's confidence in a bank's solvency. These flaws make a passing grade almost meaningless."

Reality is very different, and modeling behavior in a stressed environment is necessarily a different process from modeling a normal environment, as what was previously uncorrelated or even inversely correlated can suddenly become correlated ... as the economic principles break down and legal rules change.

We're not saying this is easy – but there's little comfort to be gained in performing a test if that test fails to capture the harsh reality that, in times of crisis, our (joint) behavior itself will compromise the predictive value of the theoretical process we're modeling.  

Perhaps a picture will say it best:

So You Think You Can ... Run a Bank?

You’re probably not alone in thinking you could have done a better job running one of the banks.  

Now you can see if that’s true, thanks to the Banking Simulator, a creative, educational tool designed by PF2 team member Joe Pimbley.  Like a flight simulator for pilots, it will give you a chance to hone your skills in simulated, but realistic, market conditions and risk scenarios.

Bank managers and executives use models for VaR, loss distributions, economic and regulatory capital, to help with decision-making, but of course those cannot capture the human element of a manager’s decision-making process during a downturn or in reaction to a “black swan” event.

Click on the slideshow for detailed instructions

In the Banking Simulator, you'll be playing the part of the bank CEO or CFO; you'll have to make many quarterly decisions and contend with several risks to keep your bank afloat in whatever situations we throw at you... including bank runs. You decide on the level of debt and equity to issue, and the amount of risky assets to acquire. You also decide the strength of your risk management.

You must make quarterly decisions to: 

• buy and sell risky assets
• issue deposits
• issue, redeem, and repurchase debt
• issue and repurchase equity
• pay dividends  

The simulator will show you your bank’s net income and stock price at the end of every quarter. You'll be encouraged to monitor and manage your asset-to-debt and reserve ratios, and you'll need to buffer against asset-liability or maturity mismatches.

Can you run a profitable bank, and at the same time maintain your reserve ratio, satisfy regulatory stress tests? 

Take your chances.  Let's see how resilient you can be, under changing market conditions.  Will you survive a run on the bank?

A New Free Sovereign Risk Database

Happy New Year Readers!

Today we are introducing a free, public database of historical sovereign risk data. It is available at http://www.publicsectorcredit.org/sovdef.

The database contains central government revenue, expenditure, public debt and interest costs from the 19th century through 2011 – along with crisis indicators taken from Reinhart and Rogoff’s public database.

Why This Database?

Prior to the appearance of This Time is Different, discussions of sovereign credit more often revolved around political and trade-related factors. Reinhart and Rogoff have more appropriately focused the discussion on debt sustainability. As with individual and corporate debt, government debt becomes more risky as a government’s debt burden increases. While intuitively obvious, this truth too often gets lost among the multitude of criteria listed by rating agencies and within the politically charged fiscal policy debate.

In addition to emphasizing the importance of debt sustainability, Reinhart and Rogoff showed the virtues of considering a longer history of sovereign debt crises. As they state in their preface:

“Above all, our emphasis is on looking at long spans of history to catch sight of ’rare’ events that are all too often forgotten, although they turn out to be far more common and similar than people seem to think. Indeed, analysts, policy makers, and even academic economists have an unfortunate tendency to view recent experience through the narrow window opened by standard data sets, typically based on a narrow range of experience in terms of countries and time periods. A large fraction of the academic and policy literature on debt and default draws conclusions on data collected since 1980, in no small part because such data are the most readily accessible. This approach would be fine except for the fact that financial crises have much longer cycles, and a data set that covers twenty-five years simply cannot give one an adequate perspective…”

Reinhart and Rogoff greatly advanced what had been an innumerate conversation about public debt, by compiling, analyzing and promulgating a database containing a long time series of sovereign data. Their metric for analyzing debt sustainability – the ratio of general government debt to GDP – has now become a central focus of analysis.

We see this as a mixed blessing. While the general government debt to GDP ratio properly relates sovereign debt to the ability of the underlying economy to support it, the metric has three important limitations.

First, the use of a general government indicator can be misleading. General government debt refers to the aggregate borrowing of the sovereign and the country’s state, provincial and local governments. If a highly indebted local government – like Jefferson County, Alabama – can default without being bailed out by the central government, it is hard to see why that local issuer’s debt should be included in the numerator of a sovereign risk metric. A counter to this argument is that the United States is almost unique in that it doesn’t guarantee sub-sovereign debts. But, clearly neither the rating agencies nor the market believe that these guarantees are ironclad: otherwise all sub-sovereign debt would carry the sovereign rating and there would be no spread between sovereign and sub-sovereign bonds - other than perhaps a small differential to accommodate liquidity concerns and transaction costs.

Second, governments vary in their ability to harvest tax revenue from their economic base. For example, the Greek and US governments are less capable of realizing revenue from a given amount of economic activity than a Scandinavian sovereign. Widespread tax evasion (as in Greece) or political barriers to tax increases (as in the US) can limit a government’s ability to raise revenue. Thus, government revenue may be a better metric than GDP for gauging a sovereign’s ability to service its debt.

Finally, the stock of debt is not the best measure of its burden. Countries that face comparatively low interest rates can sustain higher levels of debt. The United Kingdom avoided default despite a debt/GDP ratio of roughly 250% at the end of World War II. The amount of interest a sovereign must pay on its debt each year may thus be a better indicator of debt burden.

Our new database attempts to address these concerns by layering central government revenue, expenditure and interest data on top of the statistics Reinhart and Rogoff previously published.

A Public Resource Requiring Public Input

Unlike many financial data sets, this compilation is being offered free of charge and without a registration requirement. It is offered in the hope that it, too, will advance our understanding of sovereign credit risk.

The database contains a large number of data points and we have made efforts to quality control the information. That said, there are substantial gaps, inconsistencies and inaccuracies in the data we are publishing.

Our goal in releasing the database is to encourage a mass collaboration process directed at enhancing the data. Just as Wikipedia articles asymptotically approach perfection through participation by the crowd, we hope that this database can be cleansed by its user community. There are tens of thousands of economists, historians, fiscal researchers and concerned citizens around the world that are capable of improving this data, and we hope that they will find us.  To encourage participation, we have supplied a comments feature and plan to add more participatory functionality in late January.

Sources and Acknowledgements

Aside from the data set provided by Reinhart and Rogoff, we also relied heavily upon the Center for Financial Stability’s Historical Financial Statistics. The goal of HFS is “to be a source of comprehensive, authoritative, easy-to-use macroeconomic data stretching back several centuries.” This ambitious effort includes data on exchange rates, prices, interest rates, national income accounts and population in addition to government finance statistics. Kurt Schuler, the project leader for HFS, generously offered numerous suggestions about data sources as well as connections to other researchers who gave us advice.

Other key international data sources used in compiling the database were:

• International Monetary Fund’s Government Finance Statistics
• Eurostat
• UN Statistical Yearbook
• League of Nation’s Statistical Yearbook
• B. R. Mitchell’s International Historical Statistics, Various Editions, London: Palgrave Macmillan.
• Almanach de Gotha
• The Statesman’s Year Book
• Corporation of Foreign Bondholders Annual Reports
• Statistical Abstract for the Principal and Other Foreign Countries
  
  

For several countries, we were able to obtain nation-specific time series from finance ministry or national statistical service websites.

We would also like to thank Dr. John Gerring of Boston University and Co-Director of the CLIO World Tables project, for sharing data and providing further leads as well as Dr. Joshua Greene, author of Public Finance: An International Perspective, for alerting us to the IMF Library in Washington, DC.

A number of researchers and developers played valuable roles in compiling the data and placing it on line. We would especially like to thank Charles Tian, T. Wayne Pugh, Amir Muhammed and Anshul Gupta, as well as Karthick Palaniappan and his colleagues at H-Garb Informatix in Chennai, India for their contributions.

Finally, we would like to thank the National University of Singapore’s Risk Management Institute for the generous grant that made this work possible.

The Real Fiscal Cliff

Recent developments in the fiscal cliff negotiations should put to rest any hope that this process will produce a meaningful solution to the nation’s long term fiscal imbalance. For advocates of fiscal sustainability, the negotiation suffers from two serious flaws:

(1)    The fact that the party leaders are still playing to their respective bases, rather than having serious, closed door discussions. Since real long term reform would be very complex and politically painful, it requires time to run the numbers and build support for the sacrifices required on both sides. If these activities are telescoped into the last two weeks of December, they cannot be accomplished effectively. What we are likely to see then is a deal lacking in specifics with numbers that don’t add up.

(2)    Attention is mostly focused on avoiding the immediate emergency posed by the fiscal cliff and on the top two income tax brackets (the adjustment of which can only generate a small part of the solution). To the extent that attention focuses on the Armageddon that awaits us on 1/1/2013 or the morality of tax rates, less space is available to educate the public about the need to address long term sustainability issues.

To the extent that budget impacts are being considered, the discussion has focused on how to achieve $4 trillion of deficit reduction in the next ten years. The debate typically obscures the question of what “base” the $4 trillion in savings will come from. This base scenario is most certainly not current law – since that would include all the spending reductions and tax increases that compose the fiscal cliff. In fact any fiscal cliff compromise is likely to entail higher ten year aggregate deficits than those that would occur under current law.

Moreover, ten year scoring of budget proposals takes attention away from the most important fact. Under current policies or anything approximating them, the US will probably run deficits of several trillion dollars each year during the late 2020s and early 2030s. This is precisely when the greatest burdens will be placed on Social Security and Medicare because the maximum number of baby boomers will be both alive and retired. Since these big deficits will be piled onto an already large stock of debt, they are likely to trigger some form of sovereign debt crisis. Such a crisis would have devastating effects on taxpayers, government employees, beneficiaries and bondholders – as it would be manifest in some combination of sharp tax increases, deep spending cuts, inflation, and possibly an outright default on Treasury obligations. Some of these effects would probably trigger widespread civil unrest similar to the violence we have been seeing in Greece. Unlike today’s fiscal cliff, which can be avoided through simple legislation, this future crisis would be far steeper and far more difficult to side-step:  revenue and expenditure would be forced to immediately converge due to the unaffordability of deficit financing.

Since I am a financial analyst and not a politician, the preceding narrative contains two serious flaws. I have told you that any crisis is 15 to 20 years away and that it is likely rather than certain. I would better command your attention by claiming that there will be an immediate crisis if nothing is done, but that isn’t credible. Since I am writing for a thoughtful audience, I am confident that you will read on.

Due to the existing low interest rate environment, debt service cannot become an unbearable burden anytime soon. Given the amount of global liquidity and the fact that US debt contains a substantial component of long dated bonds, there is no reasonable scenario under which rising interest rates will trigger a crisis in the near term. To say otherwise might make for a great rhetorical flourish on a talk show, but it just has no economic or mathematical basis.

In the longer term, a crisis is only likely rather than certain for a number of reasons. In general, it is fair to say that any long term prediction has to be qualified just because of the sheer weight of accumulated uncertainties. In this specific case, it is possible that we will be saved by some new innovation that sharply increases productivity thereby generating enough incremental revenue to get us over the hump. Another possibility is that interest rates won’t revert to post-World War II historical averages. Perhaps we have entered a new normal in which massive global savings will continue to compete for an insufficient supply of fixed income investments, or one in which large portions of the federal debt can be monetized without price inflation (due to declining monetary velocity).

On the other hand, there are also extreme scenarios that could exacerbate any future fiscal crisis. A medical breakthrough that significantly extends life spans under the current fixed retirement age system would greatly increase dependency ratios. A major war or series of large natural disasters could sharply increase deficits at any time.

Putting all these tail scenarios aside and focusing on outcomes nearer the median, the fact remains that population aging will probably cause a long term fiscal crisis in the absence of major reform. Failure to plan for this eventuality seems to me to be the height of irresponsibility.

Given the size of America’s fiscal gap and the division of power, the only politically feasible plan is one that increases revenues and reduces spending growth in multiple areas, including discretionary spending, Social Security and health care entitlements. Unless the plan distributes the pain across all areas, it will probably be either too small or unable to become law.

If voters demand government services that roughly approximate those now available, it will not be possible to hold spending to 18% of GDP – a limit suggested by Republican leaders in the 111^th Congress. As more and more people draw Social Security and use Medicare services, spending will rise sharply, even if these entitlements are adjusted somewhat. Simply taxing the rich won’t be sufficient to fill the fiscal gap. Higher income taxes at all levels and/or new consumption taxes will be required. As a libertarian, I personally oppose taxes and believe that it would be both morally preferable and economically more efficient to cut spending enough to achieve a primary budget balance without increasing revenues.  But since my party received 1% of the vote in the Presidential election, this plan will not be enacted. Instead, we will either have a plan that includes considerable, broad-based tax increases or one that doesn’t solve the problem.

Prevailing wisdom suggests that domestic, non-discretionary spending programs are individually too small and have too much political support to contribute much to closing the fiscal gap. Cutting them across the board may have adverse unintended negative consequences.  Earlier decades have bequeathed us two ideas that can be used to achieve significant savings in these programs. Zero based budgeting, properly understood, involves a complete reappraisal of all spending items. It is designed to address the question of whether each program remains cost effective or is just continuing due to inertia. Because Congress is too politically conflicted to successfully implement zero based budgeting, it should delegate this responsibility to a bi-partisan commission as it did when base closings were required at the end of the Cold War. A politically neutral zero based budgeting commission could wring substantial savings out of domestic discretionary spending without disrupting truly valued services.

Advocates of military spending often remind us that defense is not a driver of the impending problem because it represents a stable or declining share of GDP – depending upon the base year used. However, if that base year was during the Cold War, the comparison isn’t meaningful. The country no longer needs to stare down the Soviet Union and its network of clients. Rather than exaggerate the threats posed by China, North Korea, Iran and al Qaeda, defense advocates should be supporting the elimination of Cold War oriented weapons programs that are not designed for today’s lesser security issues. Also, since the US represents a far diminished share of world GDP, its relative responsibility for funding alliances like NATO needs to be reconsidered. While it is true that entitlement spending will be the driver of future budget imbalances, there is no reason that offsetting savings cannot be found elsewhere in the budget. A dollar spent on defense has the same budgetary impact as a dollar spent on Medicare. The budget can and should shift away from defense and toward entitlements.

Social security proponents take a similar tack to the defense hawks: “our favorite program is not really the problem so let’s look elsewhere for savings.” Often the argument revolves around the fact that the Social Security trust fund is not expected to be drained for a couple of decades. But since the trust fund is simply money that the government owes to itself, it is not fiscally significant. More important is the annual gap between social security tax revenues and benefits. Until recently, this difference was positive, now it is near zero and by 2030, it will be negative to the tune of half a trillion dollars annually. While incremental reforms cannot eliminate this annual social security deficit, they can reduce it to the extent that added revenue and other budgetary savings can offset it. The most obvious reforms include making the retirement age a factor of life expectancy – as Italy has recently done – and making downward adjustments to benefit formulae.

While everyone agrees that Medicare is a huge budget problem, the solutions offered often fail to miss the fundamental issue this system poses – an issue that also applies in part to Medicaid and future Affordable Care Act benefits. The US health care system is unique in that it largely fails to use either of the two proven methods known to control costs. In a totally free market system under which patients are fully responsible for their own medical bills or insurance, cost growth is limited by the fact that many people will be unwilling or unable to pay for certain medical services. Since this results in richer people getting better care – an outcome that most people find offensive – all advanced countries have some form of government-sponsored third party payment. However, most countries that have government controlled health systems use non-price rationing to control costs. These rationing tools include waiting lists and “death panels” that deny certain types of care. A meaningful solution to Medicare and other health entitlements is going to require some form of rationing – either through greater patient responsibility as advocated in the Ryan budget or through a strengthened version of the Independent Payment Advisory Board (IPAB) included in the Affordable Care Act. A compromise approach might involve some sort of bimodal system in which beneficiaries could choose between a government -managed HMO (akin to the public option discussed during the health reform debate) and a market based option under which patients receive limited premium support.

Reforms of the type discussed here cannot be formulated and sold to the American people during a couple of weeks in the holiday season. They need to be well designed in order to limit adverse unintended consequences and carefully balanced to ensure that enough House and Senate votes can be cobbled together from those closest to the political center. In the absence of evidence that these planning processes are occurring, I am left with the assumption that any end of year package won’t avert the long term fiscal crisis we now face.

A Fair (Value) Solution

Hello readers, and a belated welcome to 2012!

In yesterday's FT Citigroup CEO Vikram Pandit advocates for heightened transparency across the banking system, enabling an apples to apples comparison that “[clears] some of the obscurity that causes people to believe the system is a game rigged against their interests.”

He is not alone. Late last year, Barclays' Group Finance Director Chris Lucas called for greater transparency in the financial reporting of liability valuations. The concept, of course, is that transparency is desired by investors, once bitten, before they can again get comfortable investing in banks.

Pandit proposes a solution that involves creating a benchmark portfolio against which banks can measure their relative risk.

Asset valuation itself has become the number one concern for the SEC in 2011: through mid-December the SEC had, according to the WSJ, issued a total of 874 “comment” letters to 802 distinct companies concerning their fair valuation and estimation of assets and contracts. Meanwhile, audit firms PwC, KPMG, Deloitte and others have been criticized as to their oversight of their clients' valuations and valuation processes (see Contested Pricing List). And so it is not surprising that banks are trying to overcome these substantial hurdles, though understandably in ways that suit them best.

The problem here is akin to the one faced by technology companies: the evaluation of their patent portfolios is no mean feat and is highly subjective – yet it is a crucial component of their stock price, especially in an acquisition or dismantling process.

Pandit’s solution is one solution. Another is more arduous, but overcomes the dual problems of inconsistency and subjectivity. It also combats the material regulatory arbitrage gaming business that has been created to minimize capital reserves. We would be able to say good-bye to a whole business of utility-free resecuritizations, structured solely to game the ratings models to achieve, or manufacture, lower reserves. It would be the end of certain Re-REMICs and perhaps even AAA-rated principal protected notes.

The solution, of course, is to evaluate each and every bond. This is already being done (to an extent) by the NAIC, and would add stability and assurance to our investor base.

Asset valuation may be more art than science, especially in the world of illiquid assets – but at least it's not a game. If well-performed, it can provide the cross-company valuation consistency even our bankers are calling for.

But it won’t be cheap.

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For our Central Pricing Solution, click here.

Complexity is a Cash Cow (but not for you)

“Fortuna's wheel had turned on humanity, crushing its collarbone, smashing its skull, twisting its torso, puncturing its pelvis, sorrowing its soul. Having once been so high, humanity fell so low. What had once been dedicated to the soul was now dedicated to the sale.” – from John Kennedy Toole’s A Confederacy of Dunces

Frank Partnoy, in his recent Financial Times commentary, makes the bold point that while “[most] for-profit companies are run for the benefit of shareholders … banks have been run more for the benefit of employees.”

Partnoy doesn’t delve too deeply into the basis for his claim, but he may well be alluding to the fact that traders were being financially rewarded for executing trades that brought short-term profits at the expense of long-term pain.

We have all heard about the Abacus case, where the bank was accused of siding with one client at the expense of others. (Goldman settled with the SEC for $550mm). In other cases it is argued that banks actually positioned themselves in direct opposition to their clients. Needless to say it doesn’t augur well from a long-term, shareholder value perspective for a bank to be adverse to its clients. Either the bank will suffer or its client will suffer.

From a corporate governance perspective one might argue that senior management failed to the extent its traders were not being compensated based on the long-term quality of their decisions, but rather on their short-term profits. In such a scenario, the traders would not have been incentivized, or forced, to consider the long-term benefits of strong client relationships. They would simply want to execute high margin, million dollar trades.

And hence the layering on of complexity, and the disappearance of transparency.

Complexity

Complex, opaque, private trades afford broker-dealing banks numerous short-term money-making opportunities.

First up, the lack of asset transparency (inability to see through to the asset’s support) and trading transparency (inability, due to the private nature of certain markets, to follow the money or the trading levels) makes it easier for banks to get away with manufacturing prices to their advantage, or taking advantage of comparatively unsophisticated (trusting) clients.

Jim Grant (founder of Grant’s Interest Rate Observer) posited in a recent Bloomberg interview that the world we live in “is a world of fake prices and of manipulated prices.” For liquid, traded securities like municipal bonds or US Treasuries, it is understandably quite difficult to massage the numbers; but for lesser-traded, or illiquid, assets price discovery can be cumbersome if not impossible, making price manipulation all the more feasible.

In Michael Lewis’ The Big Short, Scion Capital’s Michael Burry warns that “[whatever] the banks’ net position was would determine the mark,” and that “I don’t think they were looking to the market for their marks. I think they were looking to their needs.”

The lack of transparency, too, is entirely convenient to banks in the know: it creates numerous opportunities to profit at the expense of those with less information. We call this imbalance an "informational asymmetry." It may be very difficult to sell Apple stock at an above-market price to even the least sophisticated of investors: they can readily tell that the security ought to be valued lower. But when the security is complex and privately traded, and when the comparatively unsophisticated investors do not have the market know-how or savvy to model the deals, it can be much easier for a bank to "pull one over" on them. The Fed ponders the severity of this very advantage in its aptly titled report "Could Asymmetric Information Alone Have Caused the Collapse of Private-Label Securitization?"

Complexity also undermines the potential for investigative journalism (they cannot get access to the data or make a complex deal sound too interesting) and, more importantly, the ability for regulators to oversee the markets they regulate. The IMF in 2006 warned that “[while] structured credit products provide a wealth of market information, there remains a paucity of data available for public authorities to more quantitatively assess the degree of risk reduction among banks and to monitor where credit risk has gone.”

Investors would do well to acknowledge the incongruent incentives banks may have to add their complexity to their products. But as buyers, complex deals can be difficult – and expensive – to analyze, and cumbersome if not impossible to trade (out of) during times of heightened volatility.

Investors can push back when offered complex deals that don’t meet their interests – and they can strive to ensure that their rights to high quality information and transparent disclosures are upheld.

Complexity allows for high margin trades that elicit high profits, but sometimes on terms that are not commercially reasonable. And in times of high volatility, they tend to be accompanied by high bid-offer spreads. As always, it’s buyer beware.

The Data Reside in the Field

In the New York Times' “Needed: A Clearer Crystal Ball” (Sunday Business pg. 4) professor Robert Shiller claims that if we sharpen our risk measurement tools we will better understand the risk of another financial shock. He argues that improved data collection can substantially increase the predictive power of our financial models.

As mathematicians we must agree with his sentiment: more complete data is always useful. But as market participants we wonder if professor Shiller has missed out on a valuable lesson to be learnt from this financial crisis.

One key lesson was that the source of the failure was neither data-driven nor model-driven, but rather a direct result of the expected behavior of poorly incentivized parties.

In fact, one could argue that for the large part the data were comprehensive. The models were highly sophisticated, perhaps too sophisticated. But what caused the crisis was that originating parties were financially rewarded for structuring and selling low quality mortgage loans. The incentive was clear and by mid-2005 the FBI was already commenting on the pervasive and growing nature of mortgage fraud.

Misrepresented financial documentation skews the data and cannot be spotted simply by poring over ever more abundant realms of data: you have to go into the field itself to follow the incentives.

The financial downturn was made worse by financial institutions’ lack of confidence in the creditworthiness of their counterparts. Absent a level of certainty as to the true nature of others’ balance sheets, a lending freeze precipitated an illiquidity crisis. But a more thorough examination of data won’t tell you what resides off-balance sheet: you have to understand the prevailing accounting environment (that led to the mechanical reproduction of the negative basis trade) and the fundamental nature of the opaque shadow banking system.

It is a concern that intellectuals and academics risk being lulled into a false sense of security based on their access to copious amounts of statistical data.

Copious analysis of imperfect data is unlikely, alone, to help our regulators hone in on an inevitable crisis – much less prevent it. Let's not strive to build complex economic models whose success hinges on sensitive data. Let us rather encourage a keener appreciation of the limitations of data, the intentional proliferation of informational asymmetries, and the incentives that can cause a meltdown.

Central Pricing Solution

It continues to worry us that asset prices can be, or are, subject to conflicts of interests and inflationary pressures.

As an independent valuation consultancy we’re naturally disagreeable about market participants seeking valuations from biased counterparties like asset managers or even the broker dealers who sold them the bonds or are funding their holding of the bond. Scion Capital’s Michael Burry explained in The Big Short: “Whatever the banks’ net position was would determine the mark.”

But even aside from potentially conflicted external parties, we’re acutely aware of the inflationary pressures independent parties such as ourselves may face when evaluating a security. Similar to “ratings shopping” opportunistic market participants often seek out the provider willing to give the highest prices.

The incentive is clear: higher asset prices translate into stronger performance. Stronger performance may directly benefit an executive or employee (to the extent performance fees or bonuses are based on returns) or even indirectly improve a fund’s prospects (heightened ability to raise capital or negotiate decreased margin requirements on the back of strong performance).

While prices have been regularly contested problems are starting to crop up more and more regularly, with questions about mutual funds’ municipal bond pricings and Berkshire Hathaway’s pricing and writedown practices finding their way into the news in the last two months.

There’s no easy solution, but one we feel strongly about is the creation of a centralized analytical (read pricing) solution.



The cost of creating such a system could be shared among its users. The advantages are numerous. Here are a few:

• If all holders were required to hold the same security at the same price, the result would be greater balance sheet consistency (across funds, companies)

• Regulators, auditors and examiners would have an easier time analyzing their constituents’ books: they would be able to rely on a single, consistent model that is widely used. (The prevailing, seemingly inefficient alternative is to have each regulator/ auditor/examiner familiarize herself with the methodologies employed by each and every pricing provider used by each company scrutinized. This is no mean feat, especially across different asset classes, and so naturally a lot will slip through the cracks.)

• Pricing consistency helps reduce portfolio-level variability and also helps the market overcome some of the uncertainties that come with informational asymmetries and modeling complexities in today’s market. Consistency and confidence together help promote market liquidity.

Risk - Discombobulated

Investing brings with it many risks. When things go wrong, they often tend to go wrong in concert: credit risk and market risk and illiquidity risk and complexity and legal and operational risks can all be confused and are often indistinguishable, especially when they need to be realized.

Certain rating agencies have specific ratings for these "non-credit risk" measures. One can get a liquidity rating, a market risk rating, even a trustee quality rating or a hedge fund operational quality rating.

But credit risk doesn’t exist and typically isn’t measured in a vacuum – at least not according to recent ratings criteria. When a product is exposed to operational risk, for example, failures in operational quality can bring down the credit rating itself, making it very difficult for an investor to separate the different risks being measured.

For example, Moody’s today announced that its soon-to-be-released operational risk guidelines could result in rating actions (primarily downgrades from the sounds of it) on the senior ratings of up to 200 structured finance ratings.

"The performance of a securitisation transaction depends not only on the creditworthiness of the underlying pool of obligors, i.e. the quality of the collateral, but is also closely linked to the operational performance of various transaction parties such as the servicer, trustee and cash manager"

With investors looking increasingly to non-traditional investments for heightened returns, and with banks pushing risky activities into the opaque shadow banking system (to minimize regulation and oversight), it’s high time we all started to manage our risks out of one centralized division. That way credit risk doesn’t escape the market risk team, and funding risks don’t escape the credit guys.

Corporate Governance for the Shareholders (Part 1)

2010 and the Dodd-Frank Act ("DFA") brought to the fore Say-on-Pay and certain other delights for those investing in shares of financial institutions.

DFA enhances the SEC's enforcement abilities, while creating an additional watchdog (the Consumer Financial Protection Bureau) which has both examination and enforcement capabilities. It also demands that both companies and regulators reduce their dependence on credit ratings: over-reliance on credit ratings served to exacerbate the depth of the financial crisis, as rating downgrades precipitated further pricing pressures.

Indeed, in our experience several regulatory bodies have approached the new regulatory landscape with a zest and energy that was perhaps absent in the years leading up to the crisis.

Having said that, many critics feel that financial reform measures fell short; some are critical of the regulators' enforcement intent (see here and here), especially as they experience budget constraints; others are skeptical of the newly-created FSOC's ability to even define systemic risk, never mind recognize or measure it.

What other improvements, then, can be introduced to protect against large-scale business risks at financial institutions?

Risk Must Have a Voice

We would like to see Risk have a voice. Certainly, many risk managers were very good at measuring risk. But their institutions failed anyway. Why? Often, the objectives of risk management (preservation of capital reserves) run counter to the growth objectives of the CEO, who is incentivized to put capital to work. One could argue that the too-big-to-fail banks are or were long risk, knowing that they had large potential short-term upside and low downside given the (implicit) government guarantee. The government or the taxpayer, in this scenario, is short risk. One option is to ensure that the chief risk officer reports directly to the board, rather than to the CEO. Again, if the CEO is the chairman of the board, risk's voice may be dampened and this may provide a warning sign.

Risk and Compliance Must be Independent

Similarly, it is crucial that risk managers and compliance officers are incentivized, and safe, to voice their concerns. As a cost center with relatively limited bonus potential, shareholders ought to recognize that "at-will" risk and compliance managers -- especially if they are (intentionally) over-paid -- often have little advantage for being right but significant downside for being wrong. (Click here for an example of objections ending poorly for "at will" employees.)

-End Part 1

We will be exploring further avenues for improvement in subsequent pieces of this series, including a discussion of management's communication of its risk appetite. If you have any corporate governance suggestions you would like us to consider or include, feel free to email them to us or leave them in the comments section below this post.

Phantom Pricing

Mario Draghi, head of the Financial Stability Board, is making a splash about the loosely regulated “shadow banking system.” While estimates of the size of the system are tough to come by (the FRBNY report suggests $16 trillion) what makes this system a “shadow” system is not its size, but the location of the assets. Who owns what, where?

The provisions of off-balance-sheet accounting made it very difficult to know the exposures of your counterparties, one of the reasons Mr. Draghi felt the shadow banking system to be a key contributor to the crisis: if you don’t know what else your counterparty’s holding, you won’t lend to it in a time of crisis. The lending freeze, then, only serves to exacerbate the crisis for those parties in need of short-term liquidity. A minor disconnect in a small part of the market can therefore lead to panic, bank runs, and mass deleveraging. The scenario painted exaggerates what happened in our financial downturn, but the elements remain true.

The challenge becomes how best to cure this lack of transparency. Unfortunately there are at least three parts at play in this multidimensional version of Heisenberg’s uncertainty principle: we cannot measure the exposure because we cannot see it (questionable balance sheet transparency), we know not what it is (questionable asset transparency) and we cannot rely on the value being associated with it (questionable pricing transparency).

If we could cure the “balance sheet transparency” element, the difficulty would by definition be removed from the shadow banking system. Enhancing asset transparency practices is a regulatory initiative that has begun. The process toward improving pricing transparency, however, remains in its infancy.

Why the lack of transparency? The answer: a lack of transparency in the market creates a money-making opportunity for those parties in the know. The informational asymmetries in the market allow the better-informed market participants to take advantage of those who are guessing at certain characteristics. From The Big Short:

[Yale professor] Gary Gorton guessed that the piles were no more than 10 percent subprime. [Gene Park] asked a risk analyst in London, who guessed 20 percent. “None of them knew it was 95 percent,” says one trader. “And I’m sure that [AIG’s Joe Cassano] didn’t either.” In retrospect their ignorance seems incredible—but, then, an entire financial system was premised on their not knowing, and paying them for this talent.

Absent the ability to perform due diligence internally, market participants grew increasingly dependent on the soundness of advice being offered to them by their broker-dealers, a situation which has created forum for BD litigation. From Confidence Game:

Meanwhile, [MBIA’s lawsuit against Merrill Lynch alleged that] because MBIA “did not and could not perform a cost-effective loan-level valuation analysis of the ML-series CDOs, it relied on and trusted Merrill Lynch’s statements about the quality of the underlying loans.”

Pricing transparency is similarly powerful and problematic. In the deeply veiled world of broker-dealer intermediation, the buyer and seller seldom know each other. The bidder (for example a regional bank or a hedge fund trader) doesn’t know the offerer, nor the offer itself, nor the number of offerers out there, and vice versa.

In other words, neither party knows the bid-offer spread being made by the broker-dealer and they don’t know whether there are many bids or just a few. Buyers and sellers are guessing at the price and the liquidity.

The larger problem, of course, is that for leveraged funds your margin is being dictated by the seller’s price, and that price is not necessarily an independent, unbiased opinion. Back to The Big Short:

“Whatever the banks’ net position was would determine the mark,” [Scion Capital’s Michael Burry] said. “I don’t think they were looking to the market for their marks. I think they were looking to their needs.”

One solution, thus, is to centralize the pricing operations among one or more independent bodies — perhaps among existing regulatory bodies to the extent we can avoid conflicts of interests between their supervisory agenda and their pricing power. Else, why not create a new agency that creates various economies of scale in promoting pricing transparency and consistency in the name of, wait for it, consumer protection.

Basel Dazzle

“Jean: Don't you know that it is dangerous to play with
fire?
Julie: Not for me. I am insured.”

— from August Strindberg's Miss Julie

Basel III’s newly announced bank capital requirements have received their fair share of criticism from the public media. Many of the opinions shared center on the (expected) limited effectiveness of the increased capital standards.

Indeed it is basic approach to simply bolster the reserve requirement. It has its downsides — stemming growth and lending activities — while also failing to strictly eliminate an eventual default: higher reserves might in certain cases simply allow a troubled bank to linger as a going concern before defaulting, without necessarily staving off the default.

How else to protect against another system-wide financial institution failure?

The first question to answer is whether capital reserves that were in place were being correctly applied and adhered to. If not, it leads one to question whether it is the capital reserves that need increasing or whether it is their application that begs tightening.

Prior capital reserve and accounting requirements encouraged banks to game the system by, among other things:

(1) obscuring their balance sheets and taking as many assets as possible off their balance sheet (see for example the infamous Repo 105; the negative basis trade; Madoff’s supposed year-end movements into Treasuries to thwart auditor supervision; and the various mechanisms uncovered for hiding assets and insurance policies, such as is being alleged in the case of the SEC vs. Sentinel); and

(2) creating, through securitization, phantom diversification benefits that were rewarded by the risk-based capital regimes then in effect.

Thus the converse would be to endorse a system that encourages true diversification on the vanilla asset level — not on complex structured finance and portfolio investment vehicles where diversification is gamed and over-rated (no pun intended). We ought to reward transparency, as well as the usage of up-to-date, reliable, complete and comprehensive data and models, or punish the converse.

To protect against systemic risk concerns, we can further require that the rating agencies, too, remain current on their ratings. This will create a useful buffer against large downgrades, the coup de grâce for many leveraged financial institutions.

From a high-level point of view, one may argue that to avoid a crisis similar to the current one, one has to ensure the incentives that led to our current crisis are adjusted towards promoting active risk management and prudent risk taking. Let’s channel our energies towards fostering an investment environment, a culture of proactive risk, reward and responsibility.

The Carry Trade from Off-Balance-Sheet Heaven

The Citigroup-structured CDO, Adams Square Funding II, Ltd., closed in March 2007 with the $600mm Class A1 Floating Rate Notes (Due 2047) not being offered by Citi; rather the A1 notes were being insured by a swap counterparty by way of the then-convenient-and-now-infamous negative basis trade.

By insuring this A1 tranche trade (Ambac Assurance was reportedly the ultimate swap counterparty), Citi was able to lock in substantial up-front “profits” on the trade in addition to their significant underwriting fee. FASB’s accounting regime (1) enabled the so-called profits on the trade to be recognized immediately, by way of “sale accounting,” and (2) allowed the trade to disappear into off-balance-sheet oblivion, away from Citigroup shareholder verification.

The negative basis trade was perpetuated by several banks for many reasons, as described more comprehensively here. The forthcoming chart provides what we believe to be a thorough breakdown of the minimum estimated up-front profit -- of approximately $9.8mm -- Citigroup would have been able to achieve in having the A1 wrapped by a monoline guarantor.



Indeed UBS’s shareholder report explains that

[UBS’s] CDO desk viewed retaining the Super Senior tranche of CDOs as an attractive source of profit, with the funded positions yielding a positive carry (i.e. return) above the internal UBS funding rate …

and…

Day1 P&L treatment of many of the transactions meant that employee remuneration (including bonuses) was not directly impacted by the longer term development of positions created…

UBS may have made larger sums on the deals they had wrapped: UBS’s cost of credit default swap (CDS) protection was on average as low as 11 bps, or 0.11%.

The ability to lock in such enormous, fictitious, gains (and potentially distribute some of these gains immediately in the form of bonuses to investment bankers) proved to be a major contributor to the financial crisis. With the under-capitalized monolines – such as ACA, AIG, Ambac, CIFG, FGIC, FSA, MBIA, Radian and XL -- struggling or failing to support the credit protection contracts they had over-sold, several of the TBTF banks were forced to rely on the government’s (and taxpayers’) aid to fund the ultimate return to their balance sheets of what we estimate to be $300 billion of off-balance-sheet negative basis trade securities.

Other resources: a diagram describing the trade more generally, in its context relative to the CDO, can be found here.

Credit Ratings vs. Credit Default Swaps

As an alternative to relying overly on ratings produced by credit rating agencies, several ratings reform proposals offer the usage of bond or credit default swap (CDS) prices or spreads as a more plausible option. Some of these proposals are positively suggestive of the fact that market prices are both more accurate and more predictive than credit ratings.

I’m not convinced.

Firstly, with ratings being so deeply embedded throughout our financial structure, the ratings of the assets themselves become an integral component of the market-implied risk assessment. For example, even when analyzing securitized products Vink and Fabozzi (2009) show credit ratings to be a major factor accounting for the movement of primary market spreads. Thus, for any proposal to be convincing it would have to test the accuracy and reliability of CDS spreads on unrated bonds or companies. Alternatively, a study would need to compare the performance of traded securities whose ratings are not publicly known (also known as shadow ratings) to the performance of those shadow ratings.

Secondly, bond yields (or spreads-to-swaps) and credit default swap premiums are largely incomparable to credit ratings for many reasons. These differences will have to be tackled in a separate piece, but at the very least there’s that non-insignificant concept of liquidity. Both CDS premiums and bond yields include the various risks – not just credit risks – that come with investing in, or buying protection on, a security. Credit ratings speak solely to long-term credit risks.

One may argue that the ratings were far less accurate than CDS spreads during the crisis, and that this (i.e., during a market dislocation) is the only time we depend on accurate default projections and we should therefore abolish rating agencies in general. While I don’t wish to complain of these proposals, I fear that they complain unfairly of the rating agencies.

Yes the CDS spreads may better reflect default probability during a crisis. By definition they’re more adaptive to changing market conditions, versus the ratings which are long-term predictors. But would you want ratings to change in as volatile a fashion as CDS spreads? Would you want ratings to depend on headline news, or on audited (or lightly audited) financial data? Also, one shouldn’t forget that CDS spreads on CDOs and RMBS tranches were just as poor reflections of market-perceived asset quality before the crisis. The crisis could only occur, in part, because the banks were able to buy protection so cheaply from the monolines, by way of being long the CDS -- the infamous negative basis trades.

But even if these proposals made sense and even if their hypotheses were correct, they would be missing at least one crucial point: we need ratings. Meaningful ratings are essential – certainly now. Let me explain why, albeit by way of a long-winded explanation.

For financial reform to be successful it needs ultimately to deal with the flaws in our banks’ risk management procedures – and to deal with them in an environment in which the very serious practice of risk mitigation is left by senior management to risk managers, just as the serious business of growing revenues while attending to shareholder pressure is left by risk managers to upper management.

That these two functions are more adversarial than independent in nature is a concept not to be lost on us. Overly cautious risk management might hinder the implementation of growth opportunities, or the extent thereof. At times, indeed, they may be thought by the skeptic to be mutually exclusive.

Indeed the overpowering pressures that come with business initiatives can influence even the most judicious risk manager’s ability to perform her function in an objective manner, even though her function ought to be both separate from and independent of the business strategies. (See for example “Lehman’s Worst Offense: Risk Management.”)

With both traders and management being compensated for revenue generation, and with prudent risk managers acting only as a hindrance to the initiation and exploitation of growth opportunities, there remains little incentive for senior managers to maintain a healthy risk management environment. Instead of cultivating an environment in which risk managers are educated in monitoring the real risks (which requires expensive resources including personnel, data and systems) they are seen rather as a burden and a cost center, and are therefore starved of the resources necessary to question traders, trades, and trading strategies.

In sum, we remain in the infancy of creating a functioning risk control practice in place at our major banks. We are yet to promote adequate business-peer challenge processes and our price verification processes remain immature. Credit ratings, if created and applied properly, can provide a healthy starting point for internal skepticism; they can provide the independent credit risk assessment that supplements an analysis performed by the front-office or by the back-office.

Conclusion

CDS spreads are untested as a predictor of long-term default probability on unrated securities. Perhaps the reliability of CDS spreads depends on the underlying referenced entity being rated. There’s no doubt that CDS spreads are useful indicators – but I seriously doubt that they’re anywhere near as useful as ratings in predicting long-term default probabilities or losses.

I remain convinced there's an important place in our market for one or more independent agencies to provide their objective opinions in the form of a rating. For ratings reform to be successful, however, requires that the necessary measures be put in place to ensure that rating analysts are unfettered by market share concerns, and are incentivized only by ratings quality and accuracy. If we can achieve these objectives, ratings will return to providing a meaningful utility.