Tuesday, November 03, 2009

Financial Regulation: How would you have it work?

Yesterday myself and several other financial bloggers got the chance to meet with several senior Treasury officials, including the Secretary himself. It was a fascinating experience and I have to admit, it was just plain cool to be within the bowels of power like that.

I am also on record as saying that Geithner was a good choice for Treasury secretary. We needed continuity as the bailout process was on-going. Geithner knew exactly where the bodies were buried in a way that other choices, such as Summers or Goolsbee wouldn't have. I have since come to view Geithner as a pragmatist, which I appreciate in anyone elected from the other party. And truth be told, a lot of the Treasury department's plans are working. I can't deny that. I panned the stress tests when they happened, but I can't deny that it worked. It created confidence where there was none. Say what you want about whether or not banks are still in trouble, I'm not terribly confident, but we're sure a lot better off today than January 19.

All that being said, I don't think much of the Administration's attempt at improving bank regulations, and I told them so. I even managed to do it politely without lacing in a Star Wars quote. Here is my main beef. I will explain myself in classic Accrued Interest style: very very long form.

The Administration's new regulatory scheme seems to focus on reducing bank risks. Higher capital requirements, more disclosures, etc. That all seems fine, except that is it really fundamentally different than what we have now? That is isn't it just an expansion of the same basic regulatory scheme that currently exists?

And if it isn't fundamentally different, does increased capital really solve anything? Citigroup had a large percentage of its risks off-balance sheet. Lehman's capital ratios were nominally quite strong on Friday, bankrupt on Monday. Both firms had adequate capital, and both either did or should have failed.

When this was pointed out to certain senior Treasury officials, their response was basically that they won't allow those sorts of games in the future. They were closing the loopholes that Lehman, Citi, and countless others exploited to hide their true leverage. I respond that even if you stop the games that banks were pulling in 2008, won't the banks come up with different games in the future?

The reality is that even if we do nothing, we might not have another financial crisis for many years. Let's say its 2022. Let's say we've just gone through 6 years of tranquility in the financial markets. Let's also say that banks have come up with some new and creative security where they get to keep all the upside with 85x leverage, but by the existing banking regulations it shows as a fully cash funded position against the bank's capital. Will bank regulators be motivated to ban this new security? I doubt it. Why do I doubt it? Because current regulators around the world looked the other way at CDO^2. Regulators aren't going to have the courage to challenge the banking industry during a period when the banking industry seems to have been right.

For the same reason I reject the notion of "regulatory supervision." Not to say that I think regulators are nefarious people, but are they going to understand the risks as well as the bank itself? And if the bank has a good reputation for taking risks, will regulators challenge them? Bear Stearns was known as the best mortgage shop on the street. Let's say you gave regulators dictatorial power, they could do anything they wanted. Would an omnipotent regulator have told Bear they were taking undue risks? Or would Bear have explained their positions, the regulator not understood them and assumed Bear was smart enough to handle it?

Transparency isn't a panacea either. Do you really think you are going to fully understand the risks at Goldman Sachs? As Yves Smith said yesterday, you'll never have Goldman revealing their trading book. And even if you did, it might not tell the whole story. By the time the disclosure, is published, their positions might be different. So what do you do? Put risks into categories? Like what? Credit ratings? We saw how well that worked! More transparency is better than less, but I'm asking the reader to be realistic about how much we're really going to know.

I'm a free market guy. I'd like to see any business be allowed to take whatever risks they can get funded. I don't want to tell what risks banks can take any more than I want to tell Macy's how many stores it should open or what flavor ice cream Coldstone should be selling.

Yes, I know. Coldstone isn't J.P. Morgan. But why not? Only because J.P. Morgan's failure has major consequences for other banks. But in a perfect world, we'd let J.P. take whatever risks it thought would make them money. That is, whatever risks the market would fund by buying J.P.'s debt and equity instruments. And if J.P. failed, then those investors would get burned.

Notice that this world wouldn't require regulators to predict where the next crisis would come from. It wouldn't even require banks to hide their leverage. The relative risk of a bank would be reflected in their cost of capital. If one bank was more aggressive than another, it would have to pay more for capital. I know, it sounds so idyllic, it can't be possible, right?

I argue that the only reason why it isn't possible is because we can't deal with a large bank (or insurance or brokerage) failure in isolation. There is always contagion. But there doesn't have to be. What if government regulation was aimed at limiting contagion post failure? It might be somewhat complicated and it might not completely eliminate all moral hazard, but its doable. Say that the government set up an FDIC-style insurance pool for over-the-counter derivatives and prime brokerage. Think of how radically different the AIG and Lehman failures would have been if no one was worried about having to face a bankrupt firm in a derivatives contract!

Like deposit insurance, I'd argue that such a regime wouldn't necessarily be costly to the government. Just like deposits, its likely that any firm's derivatives book could be sold to another firm, maybe at a loss, sure. It would be all the more easy so set up such a system if the more plain-vanilla derivatives, like interest rate swaps and most CDS were exchange-traded.

I know what you are thinking. Basically I'm saying to forget about preventative medicine and treat all patients only once they are in the ER. The problem is that regulation has done an absolutely horrendous job of preventing every crisis to date. Why do we think it will work this time? In fact, Yves Smith argued with me last night that the Basel II regulations, which are heavily credit rating oriented, helped to fuel the rise of the CDO. I agree completely. Where I disagree is the notion that a different regulatory scheme will somehow produce different results. I expect banks to do what they are incented to do.

We're seeing it already. Banks are loading up on Treasury bonds anticipating that those will get more favorable regulatory treatment in the future. Are we fueling a bubble in Treasuries? Maybe not, but the point is that regulation is inherently distortive. Replacing the old regs with new regs isn't going to change that simple fact.

So yes. I'd rather the government get out of the prevention business and get better at unwinding complex and systemically important financial institutions. It was really cool that I got the chance to tell Treasury just that. I don't know that its actually going to make a difference. But it was cool anyway.


Viper said...

The movement in the gold market today tells me that the Treasury hasn't a clue as to what needs to be done to "fix" our nation's, and by extension, the world's economic problems.

The answer is simple and painful, but the longer the Treasury waits to implement the answer, the more painful it becomes for all of us.

We NEED A DEPRESSION to wipe out bad debt, plain and simple. We rebuild from there. The law of exponents (eighth grade, remember?) says we CAN'T continue down this path of debt growth relative to GDP; it's mathematically impossible. Those at the Treasury know this, and you should to, but you were too busy licking their boots to speak up.

Grow a pair. Type the truth.

ndk said...

This is an absolutely revolting pile of idolatry. I can't believe you're defending so many short-sighted actions and sing the praises of obfuscation, even when admitting that the longer-term strategy may not be entirely sound.

I agree with Viper. We absolutely cannot continue layering on additional debt with this economy. The Fed can't just keep absorbing bad loans forever. This is just a stupid way to run an economy, and no, it doesn't solve anything.

I do very much appreciate your candor. It's particularly enlightening to see how much your perspective changes when you've seen just plain cool to be within the bowels of power like that.

I'm very sorry to be so unpleasant here, but I've had plenty of my own meetings with power. I've seen some individuals who could stay detached and wise and some people who were awestruck by the smooth language and seeming brilliance of the navigators, even if the ship is bound straight to hell. Now I know which you are.

EconomicDisconnect said...

between all the discussions of those at the meeting it seems at least like the Treasury folks got some outside the box views. How much this will help things I am not sure, but I think it was a great opportunity for those involved to try and make a difference.

I am more of the line of thought of the two previous commenters in the end. Whatever confidence has been restored is both paper thin and totally dependent on government props (too many to list) and it is here that the failure has occured. Too big to fail has now become policy as the major banks have swelled in size and now must view attaining the TBTF threshold as a core business policy.

Also, I am not a stalker, but I had seen a blurb over at Across the Curve and that was how I knew you had been invited.

Cate Long said...

That's an interesting opportunity that you had to query our public officials on financial reform.

Your might want to check out Riski, the open source platform for financial markets reform. It's mainly for Hill staff and the media but it might be useful to you.


Kind regards, Cate Long

Anonymous said...

You must be kidding... ?

FDIC insurance only works because the FDIC monitors the banks' books very, very closely and intervenes early when dangerous risks appear. Ever heard the phrases "prompt corrective action" and "resurrection risk taking"?

A similar system for derivatives contracts would require vastly more stringent regulations than exist today. Otherwise the bad bets will just find their way onto the government's balance sheet. Again.

Accrued Interest said...

In fairness to me, what I've written here is 180 degrees from what the Treasury is doing. So I don't know where you get off saying I'm awestruck. Besides, I don't discuss the problem of debt accumulation in the post. So your point, while valid, isn't on topic.

Also in fairness to me, I wrote in the past that I thought the stress tests worked. I wrote in the past that I thought Geithner was a good choice for Tsy. I didn't garner these opinions yesterday.

While at the Tsy we did talk a bit about debt accumulation but the problem is that they just tell you "we're working on it." That wasn't a very interesting conversation, so I didn't bother writing about it.

To cede a point or two to someone doesn't indicate a lack of "balls" it indicates the courage to admit when you are wrong.

Accrued Interest said...


So you are saying that we shouldn't try to achieve meaningful reform because its difficult? You are saying the FDIC was watching WaMu so closely as to protect government interests? You are saying that a system where the government might have to take some assets onto its balance sheet is somehow worse than our current system where the government had to take all bank assets onto its balance sheet in the form of contingent liabilities!

Sorry. I think it can work. Its never going to happen, but it can work.

Accrued Interest said...

Let me add that in general, every one there thought it was cool. No one there was intimidated to speak their mind. And no one agreed with the Treasury on much. We might have disagreed among ourselves but we all were highly critical of Treasury on a number of fronts.

Accrued Interest said...

And another thing! We (the bloggers) specifically came after the Treasury on this whole "prompt corrective action" concept. Its a complete joke. IndyMac, WaMu, Wachovia... there is a very long list of banks where action was no where near "prompt" or "corrective." But what we did have is a way to work out the Bank's positions. It didn't just go into some destructive bankruptcy proceedings. That's a better system even when the regulators don't see any problems coming before its on top of us.

1 said...

The thing I don't get is this: What was the point of having this ragtag band of bloggers meet with the treasury officials? They are seeking policy advice?

I note that they did not invite Mish to the party. Those treasury guys have no sense of humor.

Anonymous said...

Well, I admit that I am in the "just break them up" camp... Smaller banks would not be a panacea, but they would certainly help. Especially with the capture of our regulatory and legislative systems.

At the point where the government is back-stopping all of the banks' liabilities -- which is essentially what you are proposing, I think -- it seems to me that it makes a lot more sense simply to nationalize them.

I am a lifelong free market apologist. Borderline religious about it, in fact. But the events of the past two years have convinced me that any organization that is "too big to fail" must be state owned. I am not a fan of state ownership, so my vote is to break them up. But I would settle for seizing them.

Frankly, I still find it hard to believe that private companies received government bailouts and still remained private companies. Two years ago I would have thought that impossible...

kristof said...

I agree regarding regulation. It seems like banks have been blowing themselves up since the beginning of time and changing some rules isn't going to help that. In fact, the situation is a bit like preventing forest fires... you want occasional small fires to keep the undergrowth down and people cautious.

Limiting the collateral damage seems like the best option. The dot-com boom was a perfect example of a well-isolated bubble. It was over quickly, with unencumbered assets, where even the walking wounded like Amazon were able to quickly bounce back. More conservative companies were rewarded by being able to buy assets at deep discounts.

Bond Girl said...

It seems to me that even with an FDIC model, we'd still have the problem of exposure to non-domestic counterparties.

Accrued Interest said...

Just to be clear, I don't want to back stop all bank liabilities. Just select counter-party transactions. Not, for example, senior bonds. That's the distinction between the bailout model and what I'm discussing.

Anonymous said...

Well, Lehman was allowed to fail because its derivatives book was not that large. Less than 1/3 the size of Bear Stearns when it failed (https://self-evident.org/?p=222).

As I recall, the first nasty follow-on from the Lehman BK was that money market fund "breaking the buck". That happened because they were invested in Lehman's senior bonds.

Moreover, according to Philip Swagel (https://self-evident.org/?p=522), Treasury gave Lehman and others "abundant warning" that no help was in the offing. So counterparties had a lot of time to adjust their exposure.

For these reasons -- especially the Reserve Fund breaking the buck -- I would argue that even if Lehman's counterparties were protected, its failure would still have been a systemic event.

So I think for your proposal to actually work, it would have to cover all liabilities. This is not a crazy proposal; Warren Buffett made it himself at the height of the crisis (although perhaps he only meant it as a temporary measure).

I myself still believe that any TBTF firm should either be seized by the state or broken up.

cp said...

Hi AI,
I very much enjoy your blog - keep up the good work! Your post inspired me to put together my thoughts on the subject:


Accrued Interest said...

Self: I don't disagree with the facts as you describe them and I think its fair to say that any significant financial firm failing would have some fall out. That's ok. We survived Drexel. But its also fair to say that if Lehman's PB customers weren't so scared that they would have had more time to work out a sale of the firm. Also I think Dick Fuld thought there would be a bailout and therefore he would be able to sell the firm at a reasonable price. If it were known that there was no bailout (instead some sort of resolution process) then all circumstances would have played out differently.

Salmo Trutta said...

There are 10,000 better qualified Treasury Secretaries before the tax cheat Geithner.

There are also at least 10,000 better qualified employees at all of the companies the tax payers bailed out.

The "good ol boys", or the "big boys", or the dollar connected, etc. can't be counted on to "run a tight ship". The problem with the banks is the bankers and their political constituents (that will always be the case). We don't have capitalism, we have regulated capitalism. We also, paradoxically, live in a predatory society. There is no "solution".

Viper is right. However it is better expressed by saying that a healthy economy requires both upward and downward price flexibility, which all pre-depression economies historically had. I.e., recessions were self-correcting.

For intractable reasons, I favor nationalizing some of our lending institutions. And stress testing should be applied to bank personnel, not financial statements. I.e., if "you" studied economics all of your life, and you can't explain monetary flows (MVt) your arrogance and ignorance has no place in management at the FED.

csissoko said...

AI, what do you think with this theory?

The problem with the current system is collateralized derivatives that allow Goldman and other aggressive markers to be big winners in the event of large bank failures. That is, exposure to AIG was excessive, because it was collateralized.

Your plan of building up a bailout fund would have the same problem as the FDIC: premiums would be cut in the early years of a bubble, leaving it underfunded when needed. I don't see it as a solution.

I think the only way to deal with the banking system we have is to prohibit too big to fail institutions from posting collateral on derivatives (existing contracts can be grandfathered). By forcing each bank to be the unsecured creditor of the other banks we go back to a world where regulators are making use of the fact that the banks are better than the regulators at evalutating each other's risks best.

Accrued Interest said...


Interesting point. How would you answer this? Every one used AIG because it was AAA rated. But when AIG lost their rating, it wasn't like you could exit out of your exotic derivatives contract. You were stuck there. So banks were incented to go with the strongest firm, but by the time that firm became weak it was too late.

leftback said...

Do not become captured. Remember who you are.

csissoko said...

"banks were incented to go with the strongest firm"

I think the whole problem is that banks weren't incented to go with the strongest firm. Because exposures were collateralized, incentives pushed them to go with firms that appeared strong, but that they knew in fact were not strong.

Goldman has argued that because it's CDS on AIG were collateralized, they could have survived the collapse of AIG. It is at least theoretically possible given the derivative infrastructure we have that if you let a sequence of banks fail, there will be one or two banks that end up holding a large chunk of the other banks' assets (via collateral posting) and "surviving" -- in the balance sheet sense -- complete financial collapse.

Accrued Interest said...

I'd rather see the collateral requirements kept but without triggers to increase collateral. I hate triggers as it just seems to cause problem firms to jump to insolvency.

I'd then have the collateral ceded to the government in the event of a take over.

DougT said...

Treasury officials: heh. Policy input: hah. A Jedi craves not these things! Never your mind on Where You Are. Hm? What You Are Doing.

Remember the training. Help you it can.

Seems to me massively more capital would have helped. The problem was in the definition of assets, and failure to market to market in real time. Lehman failed because it went insovent and couldn't get funding. CIT failed because it is insolvent and can't get funding. AIG almost failed because it was near insolvent and couldn't.... you see a pattern here?

Increased capital *would* solve the problem. Having banks "transparently" self fund with self-reported capital ratios would encourage just as much fraud and abuse as having regulatory capital ratios. Seems to me we need more simplicity and more capital.

That means deleveraging. Painful, but necessary. At least for the larger banks. I made the case in my blog for higher capital ratios for bigger institutions because of their systemic implications.

o. nate said...

The government already guarantees a large source of bank funding, ie., deposits. As long as this is the case, the government has to be a prudent regulator - since it's potentially on the hook for those losses. If you want a pure free-market system, the answer is obvious - get rid of the FDIC. But that's not going to happen, for lots of good reasons, so I think we have to live with the reality that we are not going to have a pure free-market banking system, and we are going to need regulation to try and ensure that banks are adequately capitalized and don't take excessive risks.

Anonymous said...

1) Financial firms highly compensated employees or consultants are to be prohibited from campaign contributions - They are in a special class of government contractors as taking in government paper and selling it to investors

2) Financial firms should be limited to strict lines of business (Glass Segal act reinstated)

3) Financial firms should be under strict review for trust-like behavior and broken apart if they are too big to fail

4) Financial products sold to investors should have a public accessible bid book before IPO or the bond is sold listing bid amount, bid date, price, all or none, and importantly if the bidder is a regulated investment firm, insurance company, individual, or foreign entity

5) Bids for IPO/Bonds should be filled on the order of highest bid to lowest bid and not based on allotment system

6) Treasury note/bond bidding should be an open bid book as well

7) OTC products should be publically listed, meet standardized listing requirements (size, amount, terms, etc) and be available via the web

8) Firms should not be able to front run their own accounts either on the exchange itself or via off-exchange proprietary trading platforms

9) Thinly traded OTC bonds should be public listed with a public viewable bid book and be tradable electronically by street level investors

10) Credit ratings should not be able to be used in listing, selling, or reporting information about a financial product if that rating is over 3 years old

11) Public/muni debt issuing entities must file their financial statements no later than 60 days after the end of the financial year and provide an estimate of their finances every 6 months

12) Debt issuing entities will have a unique identifer so that debt they acquire from another entitiy (corporate takeover, muni annexation) will be listed under the true party responsible for the debt.

Anonymous said...

"it was just plain cool to be within the bowels of power like that"

Did you get to play video games and ride your bikes. Geez, Beaver that would be cool. Whatever credibility you had prior to this remark, it is gone now. Isn't that cool!

mannfm11 said...

This system isn't goign to last 13 years. We are walking a gang plank of debt. No one except the debtors want to change the status quo and there isn't any way around this but bankruptcy. The government is going to end up broke or causing a total financial collapse. The leveraging of credit, the self trading most of these firms engaged in and the total fiddling while Rome was being set afire in the NY Fed is substantially behind this. Banking is living on borrowed time and those on the inside are looting as fast as they can.

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