Stress Testing

Banks do stress tests all the time, you can’t plan for what you don’t understand or measure. And banking supervision is a full-time job. Balance sheets change in value daily, new assets come on the books daily, and the economy is fluid. Banks have full-time examiners who are continuously measuring their loan levels, estimating the potential loss exposure, and then requiring loss reserves accordingly. So the idea that these stress tests were rolled out as a big bold new policy, and then so publicly announced, seems off-base and represents an unnecessary policy risk.

One, the necessity of these “new" tests just show that the regulators failed to begin with, that they didn’t even know the basic exposure of the banks in the first place, and still didn’t. And two, the whole basis for the test is to prepare for contingencies, things that haven’t and very well may not happen. Like a “stress” case and a “worst” case. Chairman Bernanke characterized these cases as “unlikely”, yet they are the basis for requiring firms to raise more capital, either by selling off potentially valuable assets (like Citi did with its Japan brokerage), diluting existing shareholders by converting government loans to common stock, or by taking on more debt. All things that shouldn't be done simply because of unlikely assumptions. In addition, the tests created significant anxiety and hurtful market expectations for weeks preceding the tests. Once the results were leaked and it was clear the banks already had the ability to close the so called gap, the market cheered accordingly. But what if the gap was much larger, then this policy would have created a panic of sorts, causing many funds and investors to dump financials further- tangibly hurting the bank’s ability to raise capital, all because of hypothetical and “unlikely” assumptions about capital they might need should the situation deteriorate. Except that the reason for the deterioration could have been the anxiety created from the tests themselves. Thank goodness the banks had been stockpiling money for months anticipating this- if the gap had been larger this stress test would have just set back a huge rally by throwing its full weight behind assumptions and creating a self-fulfilling prophecy. To minimize this risk, the tests should have been called simulations and been completely internal between the supervisors and banks, so regulators could know exactly how much capital to inject under worsening conditions, and the banks could come up with a plan to execute in such an event. Instead, by forcing the banks to raise the money automatically, and practically broadcasting every discussion with the world, it was akin to evacuating a theatre full of people just as the curtain starts to rise because, well there’s no fire- but there could be.

This policy was a big roll of the dice and continues to show the youth of Treasury Secretary Geithner. These sorts of tests should not be confused with reality, and should be routine functions of the supervisors, not spectacles we all hold our breath for. Additionally, why they used tangible common equity as the definition of capital and not Tier I has yet to be answered. The big banks have 10%+ of capital they could access, but only about a third of it is common stock (considered a safe liquid asset). So, these tests probably understated their true capital level by about 70%. I’m glad this turned out as well as it did. But it’s only because we lucked out and didn’t have a full stampede out the door when the government yelled “fire!” in a crowded room.

A Simmer Down Now

Nobel winning economist and liberal zeitgeist Paul Krugman suggested today with a straight face that we return to a financial system, as he put it “like the 60s” - pure depository institutions saving and lending with little to no securitization or hedging. He also seemed to half-heartedly pick a fight with Larry Summers. I hope Larry will put down his 17th diet Coke of the day for a moment and take 20 minutes to draft a response for next week’s Financial Times. It would be a debate we would all benefit from. But then again maybe Summers thinks Krugman’s argument is too much of a straw man, too weak and unthreatening to solicit a response.

Krugman’s general sentiment is dead on, in that the financial system of the future cannot replicate the one we’ve just had. But this does not mean we have to roll back all financial innovation in extremus. This doesn’t mean we need to purge Wall Street or banks of anything that is a little complicated. I think more than anything else it means we just need more checks and balances, or in some places the creation of them, like over the counter trading. And it means we need to “keep it simple stupid.” The experiences of the last 6 months are not so much about the creation of new or wildly complicated financial products, as it is a reminder that firms need at least 5% or so cash on hand and need to verify the information their loans are based on (e.g. mortgage applicants). If these two things had been in place we wouldn’t be here today, and Krugman would not have the bully pulpit to adopt his pseudo neo-Ludite financial perspective.

Look at it from the perspective of a newly graduated college student with a decent job, who wants to buy her first house. The ability of this person to get a loan, and the interest charged on it is directly related to the willingness of banks to provide it. A typical bank will have 90% of their portfolio seeking a return in some respect. A good deal of these will be wrapped in recourse debt instruments to provide diversity, and often produce a margin via selling. This diversity represents more risk control for the banks and thus confidence to lend, and this margin represents more money the bank can lend, and thus more favorable credit terms for our post-collegiate house owning aspirant. And the security is only unsustainable, only contributes to a bubble, if the face value is below the current value of the future cash flows – e.g. if significant numbers of those who borrowed the consumer debt that stands behind the security will not actually pay up. This risk can be prevented quite easily with accurate information about the borrowers. This is widely applied today in the government’s new housing plan, which won’t deal with potential borrowers above a 38% debt/income ratio. Of course, to determine this you have to actually record this information. A greasy-haired condo pusher in El Paso wasn’t always accurately reporting this information to banks, surprise surprise! and banks were eager to make the deal anyway to push it up the chain. But this little scheme does not mean securities cannot be properly valued. In fact it just means the Fed needs to require actual records of income to be reported, as they did in February. So, securities can actually be worth more than their market price, and it’s good for the investor who sees a profit, good for the banks who generate more financing, and good for our college grad who can afford a slightly better house on better terms. Krugman would have us, in one radical fell swoop, nix this whole concept. Dangerous idea.

The other part of his argument attacks the big spooky market of derivates, e.g. futures, options and swaps- concepts that have only been around for hundreds of years- from farmers wanting to protect their crops from future unpredictable weather to British spice traders who didn’t want their global deals to be subject to the volatility of foreign exchange currencies. Derivatives just allow risk control, and if you happen to control this risk yourself, an incentive to do so in the form of profit. And yes, rules need to be in place. Like the degree of leveraging and collateral, or who’s trading where- tracking all this is in the works. Yet high finance is not the only place where Lord of the Flies will play out if there aren’t basic rules, and this caveat is no reason to pick on Wall Street. The credit default swaps (you will swap money for my asset if it turns out to totally suck) fiasco with AIG was not a result of the derivatives or futures system, but because they invested in a bubble (quite happily) and didn’t have nearly enough cash on hand to meet their obligations. Options and swaps are banks’ insurance, and without them they will understandably lend a lot less. Which means Krugman’s argument hurts just about everyone who wants to ever use money for anything. We require insurance for a $2,000 Datsun with 270,000 miles, it's the law, why would we not have insurance on $1 billion in mortgage loans? Or 20 million barrels a day of crude that we import? Or pensions? Or… Risk control is paramount and lowers the costs of financing and increases the availability of productivity enhancing capital. Keep it simple stupid.

Executive Compromise: The Contrarian View

There has been much populist celebration over President Obama’s recent freezing of bank executives’ salaries who receive federal money, and before that the freezing of his senior staff’s salaries. I’m not adamantly against this, but I don’t see how it accomplishes much of anything. So I’ll take the contrarian view – the usually more fun view. Firms already have every reason to avoid taking government money - because they’re not getting “bailed out” at all. They’re giving up huge stakes in their companies and the future profits that go with it, and assuming new debt to pay the government back. AIG gave up nearly 80% of its assets in the form of preferred stock and warrants. This means everyone who has parked money with them is now in the back of the line behind the federal government for dividends or shareholder privileges, experienced huge price dilution, and will likely see the government slowly and painfully liquidate their holdings. The shareholders don’t want that, the executives don’t want that, employees don’t want that, no one wants that – it’s a last resort. So the notion that they’re willing to basically give up the entire company so they can get their hands on public money just so they can get their holiday bonuses seems implausible. Also, Wall Street bonuses typically make up about a third of the NYC tax base in a given year. Without these bonuses, the city faces an even bigger budget gap, has to cut more services in a time where government purchases are needed to create demand, and ironically some of the very funds being loaned to banks in the first place.

And then there’s the whole issue of incentives. There are very few people who have the experience or capacity to run large financial institutions, let alone fix them when they are awash in problems, and it’s not like they have nothing better to do. The Jamie Dimons or Lloyd Blankfeins are not short on job opportunities. Cutting compensation 95%+ isn’t exactly the recipe for recruiting the best managers and thinkers in a time when they are most needed to sort through a menagerie of problems. The financial downturn was precipitated by a phenomenal disregard for basic due diligence. Most people put more effort into buying a used car than Citi did buying $100 billion of bonds, as Robert Rubin put it – “it was an afterthought.” Jamie Dimon largely protected JP Morgan in the summer of ’07 just by realizing he couldn’t really explain the slight uptick in defaults, and once they realized that they also realized they had no idea why the bonds were rated so high, so they divested. And diligence, as the word suggests, is not easy or particularly enjoyable. These firms will avoid further trouble only when they have executive committees that take their time and scrutinize their every step. If they’re not rewarded, if incentives are muted, it becomes less clear that they have a motivation to perform this diligence. Misaligned incentives (like in securities bundling or rumor-fueled short selling) got us into this situation; a system capable of preventing it will not emerge until these basic incentives are realigned. And last, the success or failure of these firms does not hinge on the value of their relatively meager salaries. President Obama has about 300 senior staff that earn about $180,000 a year and usually get a 5% annual pay increase. Assuming Obama keeps this freeze in place for 8 years this amounts to $24m in savings. The economic system is facing challenges on the order of millions of jobs and trillions of dollars. And during this time, good policy, and the hard-working men and women behind developing it, are more important than ever. Saving a few million bucks and cutting pay to the people you most rely on doesn’t seem to accomplish much.

What people really care about is “are they doing a good job”. People care about good decisions, good investments and good profits. If the firms were above water today, no one would raise a peep about their compensation. Targeting annual bonuses confuses the issue, which is ultimately one of bottom line performance, something that usually requires more compensation, not less.

MLS to Portland and Some Econ

After Adrian Hanauer’s brilliant orchestration of bringing MLS to Seattle (in ’09 baby!) I think it’s Portland’s turn. Check it out - http://www.mlstoportland.com/ With an estimated cost to the city of $85m and annual benefit of $30m it would be a big win all around. Bring MLS to Ptown baby!!

And here are 10 macroeconomic prescriptions that might be good now that everyone’s talking about economic policy in DC.

10) Independent World Class Regulators for all Large Financial Firms – Independent Meaning they set their budget and world class meaning they follow GAAP, this wasn’t the case for GSEs or I-banks – this includes 10% reserve ratios, not 2.5% say like Fannie and Freddie, e.g. better leveraging

9) Housing PITI – Principal Interest Taxes Insurance – Documented and verified. This only became a rule in July 2008 when Bernanke pushed it though at a Fed meeting! (And it won't take effect until Feb '09) Why did it take so long to require borrowers to check a box at the end of their mortgage docs releasing their tax records? Then Standard and Poor's or Moody's would have had actual data to base their bond ratings on. The FDIC has been restructuring loans at or below a 30% debt/income ratio to much success (but it can only do it to assets it has acquired, which is basically IndyMac) - this would be a good threshold for lenders to loosely base restructuring (after all they will take a bit of an interest rate hit, but it's better than losing the whole loan). There's also a new study which estimates a million mortgage defaults could be prevented via utilizing $10b of TARP to increase the fees HUD provides private mortgage securitizors (source of over 50% of current defaults) get for restructuring a loan. Right now there is little incentive for them to make the effort to restructure versus just write off or auction off.

8) Global Exchange Harmony – If you trade in a market you are subject to its rules, for instance European/London traders in NYMEX are often exempt as they are considered to be regulated from abroad, not good, e.g. close loopholes. If a satellite trading shop for a European firm opens in Atlanta it should be fully regulated by the U.S.

7) Fix Entitlements – Non-discretionary spending is 65% of federal spending today and will continue to spur deficit spending and eat up the budget, which crowds out private investments – either a Greenspan style fix by say indexing benefits to the CPI rather than wage and bumping up the retirement age, or more innovative (and promising) approaches like volunteer personal savings accounts (the market has never had less than 7% returns over a decade, ever)

6) Infrastructure stimulus – Largely in the form of revolving loans to states and localities, including national direct current electricity grid (particularly applied in so called 'solar parks' which establish all the prerequisites for solar permitting and transmission in government land leased by private firms, removing the uncertainty that currently inhibits at scale development along with #5) and water infrastructure

5) Embrace the clean economy – less taxes on labor and income and more on pollution. The marginal social cost of carbon according to the Stern Report, the International Academy of Sciences and the U.N. is about $30/ton CO2, conveniently about the exact amount needed to make renewables and sequestration cheaper than coal, tar sands, oil shale etc. The IRS could oversee this program with existing authorities at the point carbon enters the economy, either the ground or port, and then recycle all revenues back via tax cuts.

4) 50% margin call (collateral) for paper (non-deliverable) hedging and speculating, today it’s often 2-5% which encourages speculating and thus bubbles

3) Warranty on bond ratings – If collateral backed bonds get a rating from one of the big agencies that proves grossly inaccurate they should take big haircuts in their contracts

2) Successful WTO Doha round – Trade needs to be opened up, and this means new negotiations with more flexibility on easing subsidies and accepting developing economy safeguards (this was the big sticking point)

1) Relax – Expectations and anxiety are self-fulfilling, losses are only realized if you sell, most of the big banks had balance sheets that were OK, it was the market cap losses that did them in. Citigroup for instance has lost $2b each of the last couple quarters, on a balance sheet of nearly $2 trillion and with tons of cash on hand (and $25b more thanks to TARP). And yet they have a current market cap of $21b, grossly undervalued in my opinion, traders would benefit from some perspective - any company, even very strong ones, can be undone by 90%+ market cap losses (which all that have gone under have sufferred). If bovine mass hysteria dictates market positions, any company can be victim - and valuation models are powerless in the face of this. If Wall Street focuses on creating wealth rather than manufacturing it (creating wealth includes products, services, consulting, insurance, liquidity/risk management, and manufacturing it includes things like arbitraging bond rates with SIVs (structured investment vehicles) or backing capital raises with deteriorating underwriting standards, like subprime backed collateralized debt obligations or massive paper speculation/derivative bets). Wealth production beyond wealth creation is the root of bubbles, and they will always burst.

Also, I think the Big Three should get their additional $25b, which is far far less than it would cost the economy if they failed. But they need to realize this is a bridge loan in two senses: 1) getting on a sustainable cash flow trajectory and 2) finally innovating. The top reason they are in this position is not because of events of the last few months but because they have been making the same vehicle since Carter was in the White House, and actually have gone backwards in fuel efficiency. As a result they've had their shirt handed to them by Japan and German automakers. Maybe with the Chevy Volt the Big Three can finally be out front on the innovation curve instead of three decades behind.