Category: Interesting External Papers

On April 23, the OSC announced:

Today the Ontario Securities Commission (OSC) published The Canadian Fixed Income Market Report and OSC Staff Notice 21-708 – OSC Staff Report on the Canadian Fixed Income Market and Next Steps to Enhance Regulation and Transparency of Fixed Income Markets. Together, these materials summarize the OSC’s study of the fixed income markets and set out the steps the OSC will take to enhance the transparency and regulation of fixed income markets.
…
“With this report, we have compiled research that confirms our focus on enhanced post-trade transparency and regulation of the fixed income markets in Canada,” said Howard Wetston, Q.C., Chair and CEO of the OSC. “Our priority now is to develop regulation that will promote more informed decision-making for market participants regardless of size, improve market integrity and ensure that the market is fair and equitable to all investors.”

The Staff Notice stated:

In light of the observations in the Report, Staff considered steps that could be taken at this time to enhance fixed income regulation to achieve the following objectives:

• 1. Facilitate more informed decision making among all market participants, irrespective of their size;
• 2. Improve market integrity; and
• 3. Ensure that the market is fair and equitable for all investors

…
In the coming year, we will take additional steps to facilitate more informed decision making by market participants for all fixed income securities, specifically:

• a. Monitoring the implementation of new CSA cost and performance reporting rules in National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations, which will help retail investors better understand the cost of their fixed income transactions, and which will be fully implemented by July 2016; and
• b. Working with the CSA to make it easier for investors to find relevant documents for fixed income offerings, especially trust indentures and credit agreements, in the SEDAR system.

Subject to determining exactly what they mean, I don’t have a huge amount of problems with their second intention, to make more information available on SEDAR (although I suspect that they will not address my perennial complaint regarding their prohibition on linking directly to these public documents). As a caveat to that, however, I’ll say that I suspect it won’t make an atom’s worth of difference: it became apparent to me about ten years ago that nobody other than the lawyers ever read bond prospectuses; if there was any information anywhere other than on Bloomberg, it didn’t really exist. And Bloomberg’s information was grossly circumscribed; the summary omitted a lot of interesting stuff, like call schedules.

I will note that my direct experience of the institutional bond market is getting pretty rusty, but I was managing a small – but still institutionally sized – corporate bond portfolio in 2007/8; things were not much different than they were in the ’90’s; the big difference was that all the dealer crap came by eMail rather than fax and snail-mail. They could improve access to information quite easily by clarifying the rules about offering memoranda; on at least one occasion, I refused to consider buying an offered bond that fit the portfolio needs quite admirably, according to the basic information available, because the only documentation the dealer had (and this dealer was the original underwriter of the deal) was the offering memorandum and they refused to send me a copy on the grounds that OSC rules forbid the dissemination of the document.

All that being said, it is a pity that the report itself was written with the purpose of providing a veneer of respectability for the next OSC implementation of mission creep. For all that the report, titled The Canadian Fixed Income Market: 2014, is quite a good collection of references.

Furthermore, a significant number of bonds, ranging from 23-47%, are privately placed and only available to accredited investors.[Footnote]

Footnote reads: Based on an analysis of FP Infomart data from 2010-2013. These securities can only be traded and held by accredited investors.

Many of these private placements will be small issues, issued to institutions like pension funds and insurance companies on a bespoke basis, but it is a great pity that this characteristic was not followed up in an effort to determine why issuers choose to issue bonds privately. For example, on September 23, 2014 I noted:

However, as has been pointed out by Ron Mendel of Hartford Investment Management in his admirable essay Private Placement Debt: Diversification, yield potential in a complementary IG asset:

Private placement investors require additional yield relative to comparable public bond issues, as lenders demand greater yield to compensate for increased liquidity risk as well as the underwriting and monitoring costs. This premium is variable over time and is a function of technical, supply and demand characteristics, credit fundamentals and insurance liability requirements. The typical liquidity premium historically ranges between 25 – 45 basis points.

For those wanting some more opinion regarding private placements, the nomenclature in the states is “144a bonds” (or 144(a)), after the rule by which our wise masters graciously permit money to be borrowed and lent privately.

So why are there private placements? One answer is the price of underwriting a public issue, as a (now rather dated) paper by Oya Altınkılıç  and Robert S. Hansen, titled Are There Economies of Scale in Underwriting Fees? Evidence of Rising External Financing Costs reports:

That’s not the end of it, as they show with some data for Chilean issues listed in the US market, taken from a paper by Sara Zervos titled The Transactions Costs of Primary Market Issuance: The Case of Brazil, Chile, and Mexico:

Wow! Issuance costs of nearly 5% on a small issue is something fierce! While Canadian issuers will not have to deal with such an obscene amount of taxes on a bond issue, I suspect that the legal cost quoted …:

While legal fees can range according to any complications that arise, most parties quoted an approximate $50,000 for completing a straightforward deal.

… is absurdly low in today’s environment, particularly for smaller issuers that do not have a shelf prospectus in place. If we look at the recent Split Share offering by Brompton (a cookie-cutter SplitShare Corporation), found on SEDAR at “Brompton Oil Split Corp. Jan 30 2015 15:09:40 ET Final long form prospectus – English PDF 991 K” (not allowed to link!) we find:

The Company will pay the expenses incurred in connection with the offering of Preferred Shares and Class A Shares by the Company, estimated to be $725,000.

That was before selling fees of 3% (preferred) and 6% (Capital Units). An old buddy of mine blew his brains out with an ETF … spent about $750,000 and couldn’t sell the issue. So basically I think this report suffers by not examining issuance costs more – and yes, I know that legal fees aren’t public information and are therefore beyond the scope of this report. I don’t care. If they’re going to talk about costs of issue, they should have at least highlighted the fact that the cost information presented is both non-Canadian and dated.

I will also note that the information presented in the report does not differentiate by term; if we look at the information presented on SEDAR as “TELUS Corporation Mar 24 2015 17:34:26 ET Underwriting or agency agreements (or amendment thereto) PDF 275 K ” (not allowed to link!) we find:

(i) up to Cdn.$250,000,000 principal amount of Series CS Notes at a price of Cdn.$999.62 per Cdn.$1,000 principal amount of 1.50% Notes, Series CS due March 27, 2018 (the “Series CS Notes”) plus accrued interest, if any, from March 27, 2015 to the date of delivery, (ii) up to Cdn.$1,000,000,000 principal amount of Series CT Notes at a price of Cdn.$997.31 per Cdn.$1,000 principal amount of 2.35% Notes, Series CT due March 28, 2022 (the “Series CT Notes”) plus accrued interest, if any, from March 27, 2015 to the date of delivery, and (iii) up to Cdn.$500,000,000 principal amount of Series CU Notes at a price of Cdn.$999.72 per Cdn.$1,000 principal amount of 4.40% Notes, Series CU due January 29, 2046 (the “Series CU Notes”)
…
the Company agrees to pay to the Agents, at the Closing Date a fee of (i) Cdn. $2.50 per Cdn. $1,000 principal amount of Series CS Notes actually sold, (ii) Cdn. $3.70 per Cdn. $1,000 principal amount of Series CT Notes actually sold, and (iii) Cdn. $5.00 per Cdn. $1,000 principal amount of Series CU Notes actually sold, in each case exclusive of any applicable goods and services tax or any similar applicable tax.

So the underwriting costs in this case were 25bp for the Short-Term notes, 37bp for the Medium-Term notes and 50bp for the Long-Term notes.

But anyway, the main thrust of the report is to detail the difficulties retail investors have in building a portfolio of directly held bonds, e.g.:

In a 2010 study of US corporate bond trades, researchers observed that transaction costs were ten to twenty times lower for trades of $500,000 or more than for trades up to $100,000.[Footnotes]

[Footnotes read]: Transactions under $100,000 are considered to be retail transactions. See Appendix I: Additional Background, “Table 4: Spreads by Trade Size – Corporate Bonds (November 2008-April 2010)”.

Equivalent Canadian data is not available; however, we would expect to see a large disparity in Canada as well.

They do acknowledge concerns about transparency:

Negotiated Markets

In the fixed income market, there are many differentiated securities that do not trade very frequently. This leads to high search costs for each transaction since the market for individual securities tends to be concentrated among a small number of participants (fragmented liquidity).

This is one of the reasons the fixed income market operates as a negotiated market, where buyers and sellers negotiate the price of each transaction.

To facilitate the matching of buyers and sellers, dealers (or market makers) can help facilitate a transaction by serving as the trade counterparty. The market maker then assumes inventory risk while it looks for a seller (or buyer) to net out its position.

Complete transparency can deter market makers from participating for a number of reasons. One concern is that buyers or sellers can gain bargaining power over market makers. This could allow them to determine a market maker’s position and cost information, which drastically reduces the market maker’s potential profit.

The other concern is the free-rider effect: in a negotiated market, the initial search costs are high, but the marginal cost of disseminating and using this information is (or close to) zero. Full transparency can reduce bid-ask spreads but also reduces the incentive for market makers to participate because they rely on these spreads to compensate for their search efforts. While spreads in the fixed income market appear high relative to those in the equity market, one could argue that it is more appropriate to compare the fixed income market to other negotiated markets such as those for real estate and private equity, where both search and transaction costs can be significantly higher.

They acknowledge disputes about the effects of TRACE, without actually defining what they mean by liquidity:

A consensus on lower transaction costs with a continuing debate on liquidity Empirical evidence, gathered after the rollout of the TRACE system, showed that post-trade transparency lowered transaction costs in the fixed income market without decreasing liquidity.[Footnotes] As a corollary, these findings indicate that greater price transparency, leads to less information asymmetry and lower economic rents,[Footnote] which makes the market more efficient.[Footnote] However, in a more recent study, researchers argue that while post-trade transparency has reduced transaction costs in the fixed income market, it has had a negative impact on liquidity, particularly for less frequently traded bonds.[Footnote]

Footnotes read:

See Edwards, Amy K., Lawrence E. Harris, and Michael S. Piwowar. “Corporate Bond Market Transaction Costs and Transparency.” The Journal of Finance 62.3 (2007): 1421-451. Web. 24 July 2014. <[LINK]>; Learner, Heidi. “An Examination of Transparency in European Bond Markets.” An Examination of Transparency in European Bond Markets. CFA Institute, Oct. 2011. Web. 06 Apr. 2015. <[LINK}>;and M. Goldstein, E. Hotchkiss, and E. Sirri, “Transparency and Liquidity: A Controlled Experiment on Corporate Bonds,” Babson College working paper, 2005, <[LINK]>.

See International Comparisons, “Comparing Transparency” for additional details related to TRACE.

Economic rent represents the return on an asset in excess of the amount needed to keep it productive in a competitive market. Alternatively economic rent is the return that can be eliminated by competition. Rent-seeking actors are those that enter a market to capture economic rents.

Large traders can obtain a proprietary advantage by keeping the traded prices of bonds hidden. See United States. Library of Congress. Congressional Research Service. Does Price Transparency Improve Market Efficiency? Implications of Empirical Evidence in Other Markets for the Health Sector. By D. Andrew Austin and Jane G. Gravelle. United States Congress, 24 July 2007. Web. 31 July 2014. <[LINK]>.

Asquith, Paul, Thomas R. Covert, and Parag Pathak. The Effects of Mandatory Transparency in Financial Market Design: Evidence from the Corporate Bond Market. Working paper. SSRN, 5 Sept. 2013. Web. 25 Nov. 2014. <[LINK]>

I reviewed the last of these papers in the post TRACE and the Bond Market. And I’m pretty upset that they did not include the observations of Bessembinder and Maxwell (which I reviewed in the post TRACE and Corporate Bond Market Transparency) in this section, although they’re clearly aware of this paper since they cited it twice. One observation is critical and was conveniently ignored; it was:

Market participants with whom we spoke, including both dealers and the traders at investment firms who are their customers, were nearly unanimous in the view that trading is more difficult after the introduction of TRACE. Whereas it may have previously been possible to complete a sizeable bond purchase with a single phone call to a dealer who held sufficient quantities of the bond in inventory, the post-TRACE environment may involve communications with multiple dealers, and delays as the dealers search for counterparties. A bond trader with a major insurance company told us that there is less liquidity, in that market makers carried less “product,” and it has become more difficult to locate bonds for purchase in the post-TRACE environment. A bond trader for a major investment company responded to the publication of Bessembinder, Maxwell, and Venkataraman (2006) by sending the authors an unsolicited e-mail stating: “I want to be able to execute a trade even if a bond dealer does not have a simultaneous counterparty lined up…. [T]oo much price transparency reduces dealers’ willingness to commit capital…. [T]he focus on the bid-ask spread is too narrow, and a case of being penny-wise and pound-foolish.”

However, having acknowledged (however imperfectly) a debate about liquidity, the authors of the OSC paper immediately start advocating for greater transparency:

Why is price transparency important?

Markets can operate more efficiently when pricing is transparent for both buyers and sellers. Price transparency helps to ensure the buyer can make a more informed purchase, especially in financial markets that involve an intermediary, and helps sellers by making it easier to gauge demand. Price transparency also helps to prevent price discrimination in the market, where different people pay different prices for otherwise identical goods or services.

Why are prices in some markets less transparent than others?
1. Search costs. There are opportunity, including time, and monetary costs to acquire information; and
2. Privacy. Some participants are concerned that any increase in transparency might have a negative effect on their ability to manage their positions. However, it is not clear if these privacy concerns should dominate if most participants do not intend to trade the securities.

What are some of the arguments for greater transparency in the fixed income market?
1. The internet has significantly reduced search costs for consumers across many industries ranging from consumer retail to stock markets by reducing the marginal cost of information dissemination close to zero; and
2. Given that fixed income markets are generally not liquid, many participants in the market are buy-and-hold investors, so it is not clear if the privacy concerns are valid for investors that do not intend to trade these bonds.

And then there’s the usual whining:

Transparency depends on the investor’s level of sophistication … The market is relatively transparent to institutional investors … There is limited information available to retail investors … COSTS TO INVESTORS ARE NOT TRANSPARENT

In short, as I stated at the beginning of this post, the report itself was written with the purpose of providing a veneer of respectability for the next OSC implementation of mission creep. There is very little attempt to address the issue of ‘what is the corporate bond market for’ and an overarching bias towards the idea that greater transparency is always good. Well, maybe it’s good for retail investors, but is it good for the capital markets? Is it good for issuers who seek to raise funds to invest in fixed assets? As Assiduous Readers know, I take the view that it ain’t. Retail investors are well served by ETFs and, to a lesser extent (because of the fees!), by mutual funds; I have explained in the past Why only millionaires should invest in bonds directly. I have advocated for a version of Treasury Direct to be established in Canada, but those are for Canada bonds; and it’s in the context of creating something more useful than CSBs for small retail investors.

All in all, if the OSC really wants to know how investors get abused in the bond marketplace, they would be better advised to investigate manipulation of the bond indices.

But my prediction is that increased transparency will in fact come to the Canadian corporate bond market and quote spreads will in fact tighten and all the morons will be very, very happy. As a corollary to this, the market will become thinner, therefore more volatile and less liquid (when we define liquidity along the lines of ‘the ability to perform a 1-million pv transaction in a reasonable time without significant market impact); therefore investors will want higher spreads, therefore more issuers will head to the States and build fewer factories. We might also see an increase in the bespoke market, where issuers do more financing by with tiny issues sold in their entirety to insurance companies and pension plans. But the allegedly good part is a headline and the bad parts are only statistics, so who cares?

Morningstar had an article on the paper, titled Regulators: Retail investors deserve true bond transparency, which makes it clear that facts don’t matter; increased transparency and the degradation of Canada’s tiny corporate bond market is a foregone conclusion:

”We believe there is a need for additional transparency, both to regulators and to market participants, as well as enhanced regulation,” says Susan Greenglass, director of market regulation at the OSC.

In the Bank of Canada’s December 2003 Financial System Review, Tran-Minh Vu wrote Transparency in the Canadian Fixed-Income Market: Opportunities and Constraints which included a very peculiar assertion:

In Canada, because of the decentralized nature of the fixed-income market, customers typically contact several dealers to obtain the best price.[Footnote]

Footnote reads: Because they are primarily institutional investors, customers usually have a fiduciary duty to obtain at least three quotes from different dealers.

Let’s just say I’d like to see some supporting documentation for both parts of that quotation!

Itay Goldstein, Hao Jiang and David T. Ng have released a preliminary paper titled Investor Flows and Fragility in Corporate Bond Funds:

Investment in bond mutual funds has grown rapidly in recent years. With it, there is a growing concern that they are a new source of potential fragility. While there is a vast literature on flows in equity mutual funds, relatively little research has been done on bond mutual funds. In this paper, we explore flow patterns in corporate-bond mutual funds. We show that their flows behave very differently than those of equity mutual funds. While we confirm the well-known convex shape for equity funds’ flow-to-performance over the period of our study (1992-2014), we show that during the same time, corporate bond funds exhibit a very clear concave shape: their outflows are sensitive to bad performance much more than their inflows are sensitive to good performance. Funds have more concave flow-performance relationships when they have more illiquid assets and when the overall market illiquidity is high. Overall, our empirical results suggest that corporate bond funds are prone to fragility. The illiquidity of their assets seems to create strategic complementarities that amplify the response of investors to bad performance or other bad news.

So that’s interesting, and echoes the old stockbroker adage that people hate losing money on bonds. In fact, the “concave shape” they refer to in the abstract suggests that the market might be imposing a sort of ‘negative convexity’ on bond yields.

Observing this trend [of increasing flows to bond funds], several commentators have argued that bond funds pose a new threat to financial stability. What will happen when the current trend of loose monetary policy changes? Will massive flows out of bond funds and massive sales of assets by these funds destabilize debt markets with potential adverse consequences for the real economy? Feroli, Kashyap, Schoenholtz, and Shin (2014) use evidence from the dynamics of bond funds to show that flows into and out of funds seem to aggravate and be aggravated by changes in bond prices. They conclude that this suggests the potential for instability to come out of this industry. They analyze the market “tantrum” around the announcement of the possible tightening of monetary policy in 2013, and suggest that events like this can put the bond market under stress due to amplification coming from bond mutual funds.

Further, the nature of funds can cause bad returns to accelerate:

Indeed, corporate bond funds are in many cases illiquid. Unlike equity, which typically trades many times throughout the day, corporate bonds may not trade for weeks and trading costs in them can be very large. Despite the illiquidity of their holdings, corporate bond funds quote their net asset values and prices to investors on a daily basis. As a result, there is a mismatch between the illiquidity of the fund’s holdings and the liquidity that investors holding the fund get: they are able to redeem their shares at any moment and get the quoted net asset value. This implies that investors’ outflows may lead to costly liquidation by the funds, where the costs could be borne by remaining investors. This creates a ‘run’ dynamic which amplifies the reaction of outflows to bad performance, suggesting that the potential for fragility indeed exists in bond funds.

So does this self-destructive behaviour apply to retail or institutional investors, or both?

Third, following the model and empirical results in Chen, Goldstein, and Jiang (2010), we expect that strategic complementarities will be less important in determining fund outflows if the fund ownership is mostly composed of institutional investors. This is because institutional investors are large and so are more likely to internalize the negative externalities generated by their outflows. Indeed, consistent with this hypothesis, we find that the effect of illiquidity on the sensitivity of outflow to bad performance diminishes when the fund is held mostly by institutional investors.

My first thought on reading the above was ‘so what about the run on Money Market Funds following the Lehman bankruptcy?’ They’ve thought about it too:

These ‘run’ dynamics are very familiar from the banking context, and recently were on display in the run on money market mutual funds following the collapse of Lehmann Brothers.[Footnote] Attempts to prevent such runs are at the core of long-standing government intervention and regulation in the banking sector and now also in the money-market funds industry. It is likely that the surge in activity in corporate bond funds is a response to the restrictions in these sectors, and so the run problem can shift into the corporate bond funds arena. Hence, regulators should be on the alert and consider steps to achieve the value from intermediation by corporate bond funds while minimizing the damage from fragility.

[Footnote reads:]For an empirical study of the run on money market funds, see Schmidt, Timmerman, and Wermers (2014).

The hint that regulators should ‘consider steps’ scares me, since in general investors need protection from regulators!

But, bless their hearts, they acknowledge the argument that MMFs require a capital buffer:

Indeed, many argue that imposing a floating net asset value is not a perfect fix to the problems in money market funds, but other solutions such as holding a capital buffer or putting restrictions on redemptions are likely more appropriate.[Footnote]

[Footnote reads]See, for example, Hanson, Scharfstein, and Sunderam (2014).

In discussing their hypotheses, they make an interesting claim:

As Moneta (2015) documents, the average turnover rate of corporate bond funds is much higher than that of equity funds. For instance, from 1996 to 2007 the average turnover rate of general corporate bond funds is approximately twice as large as that of equity funds, which suggests more active trading and relatively shorter investment horizons of corporate bond funds. Considering the relatively low liquidity in corporate bond markets, the high trading activities of corporate bond funds are likely to generate substantial market impact.

I’ll have to look at that Moneta paper! In a world of long-term value investors who have no particular need to tell a story to potential investors, one would expect higher turnover in a bond fund, since income receipts will generally be higher and the portfolio is directly affected by the passage of time; but I confess I would have thought that turnover would be higher with the equity cowboys.

They also make a more serious charge:

Indeed, Cici, Gibson and Merrick (2011) document substantial dispersions of month-end valuations placed on identical corporate bonds by different mutual funds. Their tests reveal that such dispersion of valuations is consistent with returns smoothing behavior by managers, which involves marking positions such that the net asset value is set above or below the true value of fund shares, resulting in wealth transfers across existing, new, and redeeming fund investors. They find that the returns smoothing is particularly serious for corporate bond funds with hard-to-mark assets and not as much for Treasury bond funds; furthermore, when a fund’s return is low, the fund is more likely to mark the bond positions higher than the true value. Under this situation, existing shareholders would have particularly high incentives to withdraw their money while the mark is good.

Naughty, naughty! This usually becomes known only when such behaviour is egregious – see the market post of June 22, 2011 for one example.

The authors are clearly not fans of behavioural economics!

Why do bond funds experience much higher outflows during negative performance compared to stock funds? Our leading explanation is the presence of strategic complementarities. Corporate bond funds invest in more illiquid assets. Investors’ outflows may lead to costly liquidation by bond funds, where the costs would be borne by the remaining investors. This creates a ‘run’ dynamic which amplifies the reaction of outflows to bad performance. Under this explanation, outflows should be much more sensitive to bad performance among bond funds that are more illiquid.

I think this hypothesis is simply too sophisticated for the market to bear. I would be more interested in an explanation based on risk aversion of the investors, where “risk” is defined as “absolute performance over the past M months”, which refers back to the ‘investors hate losing money on bonds’ adage noted above. This would apply to funds, rather than direct bond holdings by retail, since there is also a persistent belief that a portfolio of bonds held directly is somehow fundamentally different from a fund since direct holdings can be held until they mature at par.

After disaggregating their data to distinguish institutional from retail behaviour, they conclude:

From a policy perspective, it is good news that institutional-oriented funds face less runlike behavior at low performance times. Such funds tend to be larger; and weaker run tendency implies more stability during low performance periods. The retail-oriented funds can still create big problems, as retail investors engage in run-like behavior.

Sadly, their concluding paragraph is a plea for increased employment of box-tickers:

This suggests that bond funds are prone to fragility. Bad events may lead to amplified outflows and these may have adverse consequences for bond prices and ultimately for firms’ financing and real activities. These issues have to be taken into account in the broad scheme of regulation of the financial sector. While it is well understood that banks, and now money-market funds, are prone to such run dynamics, these usually are not associated with bond funds, but our empirical results show that similar forces operate for them as well.

Hat tip for bringing this paper to my attention: Lisa Abramowicz, Bloomberg, You call this a bond rout? Wait until the real selling starts.

The FINRA page titled “Independent TRACE Studies” leads me to some studies that have come out of mandatory TRACE reporting for Structured Credit. The data collected are not made public in raw form, but aggregate data is made available on a daily and monthly basis.

Structured Credit is a little far from my bailiwick, but some of the statistics cited are so entertaining I just had to highlight them here.

A 2013 paper by Hendrik Bessembinder, William F. Maxwell and Kumar Venkataraman is titled Trading Activity and Transaction Costs in Structured Credit Products:

After conducting the first study of secondary trading in structured credit products, the authors report that the majority of products did not trade even once during the 21-month sample. Execution costs averaged 24 bps when trades occurred and were considerably higher for products with a greater proportion of retail-size trades. The authors estimate that the introduction of public trade reporting would decrease trading costs in retail-oriented products by 5-7 bps.

An acknowledgement in this paper, by the way, introduced me to the Montreal Institute of Structured Finance and Derivatives, which appears to be funded by agencies of the Province of Quebec and provides modest funding to genuine research – only $300,000 p.a., but that’s not bad when compared to their 10-year total budget of $15-million (meanwhile, here in Ontari-ari-ari-owe, we fund ex-regulators and lawyers at FAIR Canada. Gag.) You learn something new every day!

Anyway, back to Bessembinder et al. and the amazing statistics:

Notably, less than twenty percent of the SCP universe trades at all during the twenty-one month sample period. One-way trade execution costs for SCPs average about 24 basis points. However, trade execution costs vary substantially across SCP categories, from 92 basis points for CBOs to just 1 basis point for TBAs. We show that trading costs depend in particular on what we term the product’s “customer profile,” which depends on issue size and the proportion of Retail- versus Institutional-size trades. Sub-products with an Institutional Profile tend to have lower costs. The highest average trading costs are observed for Agency CMOs (74 basis points) and CBOs (92 basis points), each of which has a low (22% or less) proportion of large trades. The lowest average trading cost estimates are observed for TBA securities (1 basis point), CMBS (12 basis points), and ABS secured by auto loans and equipment (7 basis points), each of which has a large (54% or greater) percentage of large trades.
…
Structured Products (SCPs), including asset-backed (ABS) and mortgage-backed (MBS) securities, comprise one of the largest but least-studied segments of the financial services industry. As of the end of 2012, there was $8.6 trillion outstanding in mortgage-backed securities and $1.7 trillion outstanding in asset-backed securities, implying that the SCPs markets are comparable in size to the $11 trillion U.S. Treasury Security market
…
Increased transparency has the potential to reduce the dealer mark-ups or bid-ask spreads, provide more information on the fair price of the security, and improve regulators and customers’ ability to control and evaluate trade execution costs. These ideas have been emphasized by Rick Ketchum, Chairman and CEO of the Finance Industry Regulatory Authority (FINRA):

“From the standpoint of investor protection, which is and always will be FINRA’s top priority, we simply must shed more light on the darker areas of the fixed income market.

That last quote from Rick Ketchum illustrates the big problem with securities regulation nowadays. They have swung so far over to the ‘consumer protection’ objective that they have – at least to some degree – lost sight of why capital markets exist in the first place: to get money from savers to those who want to invest in their businesses. I will certainly agree that investor protection is a worthy objective; and I will agree that it is related reasonably closely to the objective of having a well functioning capital market; but for it to be called the “top priority” shows very strange priorities.

So the first amazing statistic is:

The MBS database provided to us by FINRA contains almost 1.1 million distinct securities. The large number of securities reflects that a basic pool of assets may have more than a hundred tranches, each with a unique payoff structure, and assets can be re-securitized (By comparison, less than 5,000 companies were listed on the U.S. equity exchanges at the end of 2012). However, as Panel A of Table 1 shows, many of these issues are very small, as the 25th percentile issue size is less than $2MM. The median issue size is less than $5MM. However, the distribution is positively skewed, as the mean issue size is $22.8MM. The MBS securities are of long average maturity, as shown on Panel B, with a mean maturity close to 19 years.

Holy smokes! I knew there were lots, but I would have guessed ‘under a million’. Hundred-tranche structured products sound pretty amazing, too.

Table 2 reports on trading activity for MBS. Notably, only 17.8% of the issues traded at all during the twenty one month period studied. The mean dollar volume traded across the full sample of MBS securities is $106MM, with an average of only 4.1 trades in each security. Fannie’s issues average six trades during the sample, and the average trading volume for Fannie issues is almost three times as large as for the next most frequently traded issue (Ginnie). Freddie’s issues are traded significantly less than either of the other agencies. Non-Agency issues trade an average of only 1.8 times each, but surprisingly have the largest proportion of issues (23%) that trade at all. Non-Agency issues have an average of 3.5 dealers at issuance, compared to slightly over four dealers for each Agency issue
…
Table 3 contains information regarding the ABS data, which contains slightly over 300,000 issues (compared to 1.1 million issues in the MBS universe).5 The ABS issues are larger than MBS issues, with the mean ($114MM) and median ($29MM) issue size each close to five times larger than for ABS. Still, some ABS issues are very small; the 5th percentile of the issue size distribution is only $100,000 for ABS, compared to over $1MM for MBS. ABS issues have an average maturity of 23.2 years, about 5 years longer than MBS products.

Panel B of Table 3 reports on trading activity in the ABS market. Like MBS, ABS trade infrequently, but the percentage of issues that trade at all is almost 30%, considerably higher than MBS at 18%. The average number of trades per security is 4.97, but the trades are on average smaller for ABS; the mean cumulative trading volume for ABS is $16.3MM, compared to the $106MM for MBS issues. The likelihood of trading and mean number of trades is surprisingly homogenous across issue size terciles. However, average trade size and cumulative dollar volume is larger for ABS of greater issue size.

And what are these trades?

Table 5 reports on the distribution of trade sizes in SCPs. We consider a trade to be small if it is for less than $100,000 and large if it is for more than $1MM.
…
For comparison purposes, we examine the distribution of trade sizes for corporate bonds during the six months before and after the introduction of public transaction dissemination. Our analysis includes 1.9 Million trades in 10,108 corporate bonds phased into TRACE dissemination between January 2003 and March 2011.8 We find that 72% of corporate bond trades are small (less than $100,000), both before and after trades were publicly disseminated. We conclude that, on average, the market for corporate bonds is more similar to the retail-oriented markets for SCPs, including CMOs and MBSs, and is more distinct from the institutionally-oriented markets for CMBS and TBA securities.

And the cost?

The resulting estimates of customer trade execution costs are reported on Table 6. For the full
sample, the estimated average one-way trade execution cost is 24 basis points. Consistent with results previously reported for corporate and municipal bonds, trade execution costs for SCPs decline with trade size, averaging 83 basis points for small trades, 24 basis points for medium-sized trades, and only five basis points for large trades. Trade execution costs also vary depending on trading frequencies. Average costs for the least-heavily-traded tercile of securities are 31 basis points, compared to 28 basis points for the second tercile and 24 basis points for the most frequently traded tercile. The finding that trade execution costs for SCPs decline with trade size mirrors the findings reported for corporate bonds by Edwards, Harris and Piwowar (2007) and Goldstein, Hotchkiss and Sirri (2007) and for municipal bonds by Harris and Piwowar (2006) and Green, Hollifield, and Schurhoff (2007). The overall level of estimated trading costs for SCP is in line with estimates for corporate bonds.

Bessembinder, Maxwell and Venkataraman (2006) study institutional trades in corporate bonds, and report average one-way trade execution costs (prior to transaction dissemination) that average 10 to 20 basis points. Schultz (2001) also studies institutional trades in corporate bonds and estimates that trading costs average 27 basis points. Edwards, Harris and Piwowar (2007) study a broader cross-section that includes retail trades, and estimate that one-way trade execution costs for corporate bonds range from 75 basis points for very small trades to 4 basis points for very large trades.

And the effect of TRACE?

We first implement expression (2) for the full set of corporate bonds that became TRACE-eligible in March of 2003, including in the analysis trades executed six months before to six months after the initiation of public trade dissemination. We find that trading costs for corporate bonds were reduced after the introduction of price dissemination by 9 basis points for small trades, 6 basis points for medium trades, and 3 basis points for large trades. These results are quite similar to those reported by Edwards, Harris, and Piwowar (2006), who study the same sample but rely on more complex estimation techniques.

I take issue with the authors when they claim:

These estimates of lower trading costs for SCPs have important implications for security issuers, investors in these products and broker-dealers who supply liquidity. Improved liquidity that is attributable to post-trade price transparency has the potential to affect the valuation of the bonds themselves and lower yield spreads (see Chen, Lesmond and Wei (2007) for evidence from corporate bonds) for SCP issues. Additionally, the cumulative dollar impact of these trading cost reductions is potentially large. In the case of the transparency experiment for corporate bonds, Bessembinder, Maxwell and Venkataraman (2006) estimate annual trading cost reductions of about $1 billion for the full corporate bond market. In addition, they document the existence of “liquidity externalities”, by which improved transparency for some products can lead to improved valuation and lower trade execution costs for related securities.

As I pointed out in an earlier post, a tighter spread between the dealer buy price and dealer sell price does not necessarily indicate “fairer” prices, since the dealer may well quote only stink bids on customer sales so that a profitable re-sale can be executed quickly. This mechanism, if correct, would actually mean that the liquidity-seeker in the chain of trades is paying more for liquidity under TRACE and that both the interim and ultimate liquidity providers are making excess profits (I refer to this as the Shitty Price Hypothesis). The authors do not examine how the execution prices in the secondary market compare with new-issue prices, which renders their conclusion regarding the “improvement” in liquidity dubious.

In addition to this, the putative benefits of TRACE, estimated as “annual trading cost reductions of about $1 billion for the full corporate bond market”, does not make any attempt to compare this with the cost of the programme. And I don’t mean direct costs, either. If the Shitty Price Hypothesis is correct – and it is consistent with the finding of lower trading levels in the Asquith, Covert and Pathak paper, then actual liquidity has decreased, which means issuers will have to pay more for funds, which means that some bricks-and-mortar projects will be abandoned (this link in the chain is the entire basis for central banking policy rates) … and how much does that cost? Huh?

Anyway, the authors told us to “see Chen, Lesmond and Wei (2007) for evidence from corporate bonds”, so let’s look at Chen, Lesmond and Wei (2007) and see what they have to say.

The paper by Long Chen, David A. Lesmond & Jason Wei is titled Corporate Yield Spreads and Bond Liquidity and it turns out that the last named author is from our very own Rotman School of Management at UofT:

We examine whether liquidity is priced in corporate yield spreads. Using a battery of liquidity measures covering over 4000 corporate bonds and spanning investment grade and speculative categories, we find that more illiquid bonds earn higher yield spreads; and that an improvement of liquidity causes a significant reduction in yield spreads. These results hold after controlling for common bond-specific, firm-specific, and macroeconomic variables, and are robust to issuers’ fixed effect and potential endogeneity bias. Our finding mitigates the concern in the default risk literature that neither the level nor the dynamic of yield spreads can be fully explained by default risk determinants, and suggests that liquidity plays an important role in corporate bond valuation.
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The notion that investors demand a liquidity premium for illiquid securities dates back to Amihud and Mendelson (1986). Lo, Mamaysky, and Wang (2004) further argue that liquidity costs inhibit the frequency of trading. Because investors cannot continuously hedge their risk, they demand an ex-ante risk premium by lowering security prices. Therefore, for the same promised cash flows, less liquid bonds will be traded less frequently, have lower prices, and exhibit higher yield spreads. Thus, the theoretical prior is that liquidity is expected to be priced in yield spreads. We investigate bond-specific liquidity effects on the yield spread using three separate liquidity measures. These include the bid-ask spread, the liquidity proxy of zero returns, and a liquidity estimator based on a model variant of Lesmond, Ogden, and Trzcinka (1999). We find that liquidity is indeed priced in both levels and changes of the yield spread.

Contemporaneous studies by Longstaff et al. (2004) and Ericsson and Renault (2002) also relate corporate bond liquidity to yield spreads.
…
Historically, the lack of credible information on spread prices or bond quotes has been a major impediment in the analysis of liquidity (Goodhart and O’Hara, 1997) and liquidity’s impact on yield spreads. We employ Bloomberg and Datastream to provide our three liquidity estimates. Among them, the bid-ask spread is arguably the most demonstrable measure of liquidity costs, while the percentage of zero returns is increasingly used as a liquidity proxy in a host of empirical studies.2 Despite the clear intuition surrounding the zero return proxy, it is a noisy measure of liquidity, since it is the combination of a zero return and the simultaneous movement of bond price determinants that more properly estimates liquidity costs, not the lack of price changes per se.
…
We find a significant association between corporate bond liquidity and the yield spread with each of the three liquidity measures. Depending on the liquidity measure, liquidity alone can explain as much as 7% of the cross-sectional variation in bond yields for investment grade bonds, and 22% for speculative grade bonds. Using the bid-ask spread as the measure, we find that one basis point increase in bid-ask spread is related to 0.42 basis point increase in the yield spread for investment grade bonds, and 2.30 basis point increase for speculative grade bonds.

So I don’t find anything objectionable in the conclusion; I’ve argued in this blog for a long time that liquidity is a major factor in corporate bond yields, far outweighing credit quality considerations. I will, however, point out that their primary liquidity estimator is at least a little suspect:

Data on the quarterly bid-ask quotes are hand-collected from the Bloomberg Terminals. Most quotes are available only from 2000 to 2003. For each quarter, we calculate the proportional spread as the ask minus the bid divided by the average bid and ask price. The bond-year’s proportional bid-ask spread is then calculated as the average of the quarterly proportional spreads. To include as many bonds as possible, we compute the annual proportional spread as long as there is at least one quarterly quote for the year. The bid-ask quotes recorded are the Bloomberg Generic Quote which reflects the consensus quotes among market participants.

I have to point out that Bloomberg quotes are suspect according to the Jankowitsch, Nashikkar and Subrahmanyam paper referenced in an earlier post, with almost half of actual trades executed outside the quote. This doesn’t necessarily mean that the Bloomberg quotation spreads are useless as a liquidity estimator, but it does mean that somebody has to do some work to show that Bloomberg spreads do in fact have a solid relationship to real life (e.g., that if the bid on bond A is less than the bid on bond B, then you can in fact sell B at a higher price than A).

So what it comes down to is that I agree with Bessembinder, Maxwell and Venkataraman that if TRACE does improve liquidity, then this is a good thing, but I will claim that you cannot measure liquidity in a practical way by comparing dealer sell prices with dealer buy prices if the Shitty Price Hypothesis holds.

As it happens, there is a paper by Nils Friewald, Rainer Jankowitschy and Marti G. Subrahmanyamz which seeks to validate the round-trip trading cost as a measure of liquidity, titled Transparency and Liquidity in the Structured Product Market:

We use a unique data set from the Trade Reporting and Compliance Engine (TRACE) to study liquidity effects in the US structured product market. Our main contribution is the analysis of the relation between the accuracy in measuring liquidity and the potential degree of disclosure. We provide evidence that transaction cost measures that use dealer-specic information can be eciently proxied by measures that use less detailed information. In addition, we analyze liquidity, in general, and show that securities that are mainly institutionally traded, guaranteed by a federal authority, or have low credit risk, tend to be more liquid.
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For example, measuring liquidity based on the round-trip cost uses the most detailed information, i.e., each transaction needs to be linked to a particular dealer, on each side of the trade. Other liquidity metrics, such as the effective bid-ask spread, do not need such detailed trade information for their computation; but, transactions need to be flagged as buy or sell trades. Many alternative liquidity measures rely on trading data as well: However, they use only information regarding the price and/or volume of each transaction. On the other hand, product characteristics or trading activity variables represent simpler proxies, using either static or aggregated data.
…
Exploring the various liquidity metrics and focusing on the predictive power of transaction data, we show that simple product characteristics and trading activity variables, by themselves, may not be sufficient statistics for measuring market liquidity. In particular, when regressing state-of-the-art liquidity measures on product characteristics and trading activity variables, we find that the various liquidity measures over significant idiosyncratic information. Thus, dissemination of detailed transaction data, necessary for the estimation of liquidity measures, is of importance in the fixed-income structured product market. However, there is evidence that liquidity measures based on price and volume information alone (e.g., the imputed round-trip cost measure) can explain most of the variation observed in the benchmark measure, which uses significantly more information and certainly runs the risk of compromising the confidentiality of trader identity. In a second set of regressions, we explain the observed yield spreads using various combinations of liquidity variables and nd similar results: Liquidity measures provide higher explanatory power than product characteristics and trading activity variables alone. However, this result is mostly driven by price and volume information. Thus, details regarding the identities of the specific dealers involved with a particular trade or the direction of the trade are not an absolute necessity in terms of their informational value to market participants: Reasonable estimates of liquidity can be calculated based on prices and volumes of individual trades, without divulging dealer-specific information. This is an important result for all market participants, as it provides valuable insights concerning the information content of reported transaction data.

They acknowledge the Bessembinder paper and discuss the differences:

However, our paper is different from Bessembinder et al. (2013) for at least five important reasons, relating to various aspects of liquidity effects in the structure product market: First, while their analysis is based only on one single estimate of liquidity, we, in contrast, rely on a much broader set of liquidity proxies, which allows us to discuss the information contained in measures employing reported data at different levels of detail. Second, while Bessembinder et al. (2013) use a regression based estimate of liquidity, our round-trip cost measure (which serves as our benchmark) reflects the cost of trading more accurately, since it is based on detailed dealer-specific transaction costs, which are straightforward to compute, and does not depend, in any way, on modeling assumptions. Third, in their analysis, they focus solely on customer-to-dealer trades which constitute only a rather small fraction of all trades in the structured product market, whereas our analysis is based on all customer-to-dealer and dealer-to-dealer transactions. Fourth, unlike their study, we analyze different sub-segments (e.g., tranche seniority, issuing authority, credit rating) of the overall market in much more detail. These sub-segments have either turned out to be important in other fixed income markets, or are unique to the structured product market. Finally, a novel contribution of our paper is that we also analyze which of the liquidity measures best serves to explain yield spreads in the securitized product market.

So more particularly:

Thus, we ask how much information should be disseminated to allow for the accurate measurement of liquidity, compared to our benchmark measure using the most detailed information, in particular trader identity and trade direction, which certainly runs the risk of compromising the identities of individual traders or their trading strategies. Therefore, we measure the efficacy of liquidity metrics that require different levels of detail in terms of the information used to compute them. We analyze two aspects of this question, using different sets of regressions: First, we explore to what extent product characteristics, trading activity variables and liquidity measures using less information can proxy for the benchmark measure which is based on all available information. Second, we study which liquidity measures can best explain the cross-sectional differences in yield spreads for our sample.
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Product characteristics are rather crude proxies of liquidity that rely on the lowest level of informational detail of all the categories.13 Thus, product characteristics are typically used as liquidity metrics when there is a limitation on the level of detail in the transaction data. In particular, we use the amount issued of a security measured in millions of US dollars. We presume securities with a larger amount issued to be more liquid, in general. Another important product characteristic is the time-to-maturity, which corresponds to the time, in years, between the trading date and the maturity date of the security. We expect securities with longer maturities (over ten years) to be generally less liquid, since they are often bought by “buy-and-hold” investors, who trade infrequently. We also consider the instrument’s average coupon as a relevant proxy. Despite the ambiguity of the relationship between the coupon and both liquidity and credit risk, we expect that instruments with larger coupons are generally less liquid.

Trading activity variables such as the number of trades observed for a product on a given day represent the aggregate market activity.15 Other similar variables that we calculate on a daily basis, for each product, are the number of dealers involved in trading a specific product, and the trading volume measured in millions of US dollars. We expect these variables to be larger, the more liquid the product. On the contrary, the longer the trading interval, which refers to the time elapsed between two consecutive trades in a particular product (measured in days), the less liquid we would expect the product to be.

Note that the Shitty Price Hypothesis negates this last assumption: dealers will set prices so they can exit their positions quickly.

Liquidity measures are conceptually based, and hence, more direct proxies for measuring liquidity, and require transaction information for their computation. However, the level of detail concerning the required information set varies considerably across measures. The liquidity measure that uses the most detailed information and, thus, serves as our benchmark measure, is the round-trip cost measure, which can be computed only if the traded prices and volumes can be linked to the individual dealer; see, e.g., Goldstein et al. (2007). It is defined as the price difference, for a given dealer, between buying (selling) a certain amount of a security and selling (buying) the same amount of this security, within a particular time period, e.g., one day. Thus, it is assumed that in a “round-trip” trade, the price is not affected by changes in the fundamentals during this period. Following the literature, the round-trip trade may either consist of a single trade or a sequence of trades, which are of equal size in aggregate, on each side. The effective bid-ask spread, proposed by Hong and Warga (2000), can be computed when there is information about trade direction available. The effective bid-ask spread is then defined as the difference between the daily average sell and buy prices (relative to the mid-price).

Many other liquidity measures use only the price and/or volume of each transaction, without relying on dealer-specific or buy/sell-side information. A well-known metric proposed by Amihud (2002), and conceptually based on Kyle (1985), is the Amihud measure. It was originally designed for exchange-traded equity markets, but has also become popular for measuring liquidity in OTC markets. It measures the price impact of trades on a particular day, i.e., it is the ratio of the absolute
price change measured as a return, to the trade volume given in US dollars. A larger Amihud measure implies that trading a financial instrument causes its price to move more in response to a given volume of trading and, in turn, reflects lower liquidity. An alternative method for measuring the bid-ask spread is the imputed round-trip cost, introduced by Feldhutter (2012). The idea here is to identify round-trip trades, which are assumed to consist of two or three trades on a given day with exactly the same traded volume. This likely represents the sale and purchase of an asset via one or more dealers to others in smaller trades. Thus, the dealer identity is not employed in this matching procedure; rather, differences between the prices paid for small trades, and those paid for large trades, based on overall identical volumes, are used as the measure. The price dispersion measure is a new liquidity metric recently introduced for the OTC market by Jankowitsch et al. (2011). This measure is based on the dispersion of traded prices around the market-wide consensus valuation, and is derived from a market microstructure model with inventory and search costs. A low dispersion around this valuation indicates that the nancial instrument can be bought for a price close to its fair value and, therefore, represents low trading costs and high liquidity, whereas a high dispersion implies high transaction costs and hence low liquidity. The price dispersion measure is defined as the root mean squared difference between the traded prices and the average price, the latter being a proxy for the respective market valuation.

The Roll measure, developed by Roll (1984) and applied by Bao et al. (2011) and Friewald et al. (2012), for example, in the context of OTC markets, is a transaction cost measure that is simply based on observed prices. Under certain assumptions, adjacent price movements can be interpreted as a “bid-ask bounce”, resulting in transitory price movements that are serially negatively correlated. The strength of this covariation is a proxy for the round-trip transaction costs for a particular nancial instrument, and hence, a measure of its liquidity. This measure requires the lowest level of detail as only traded prices, and not trading volume or dealer-specific information, are used in the computation.

Whoosh! That’s a lot of liquidity measures! And I thought I was obsessive!

The descriptive statistics and correlations presented in Section 5.1 provide initial indications of the informational value of the various liquidity measures. When analyzing the liquidity of the different markets and their sub-segments, the liquidity measures offer additional insights compared to the product characteristics and trading activity variables. For example, when comparing the different market segments, higher trading activity is not always associated with lower transaction costs. The correlation analysis hints in the same direction: There is low correlation between the product characteristics and the liquidity measures (the highest correlation coefficient is 0.26 in absolute terms) and between trading activity variables and liquidity measures (less than 0.20 in absolute terms). Thus, it seems that liquidity measures that rely on more detailed transaction data can provide important additional information, based on this perspective.
…
Table 10 shows the results for this analysis, presenting the six specifications. In regressions
(1) to (5), we use each of the liquidity measures in turn, plus all trading activity variables and product characteristics, to explain the round-trip costs. When we add just one individual proxy to the regression analysis, we find that the imputed round-trip cost, the effective bid-ask spread and the price dispersion measure are the best proxies, with R2 values of around 50% to 60%, whereas the Amihud and Roll measures slightly increase the R2 to around 40% compared to regressions without liquidity measures. When adding all the liquidity measures to the regression equation, in regression (6), we obtain an R2 of 67%, i.e., the explanatory power increases considerably when we include all these proxies. We consider this level of explanatory power quite high, given the rather diverse instruments with potentially different liquidity characteristics and the low number of trades per security and day, in general. We get similar results (not reported here) when explaining the effective bid-ask spread with liquidity measures using less information. Thus, we find evidence that liquidity measures using more detailed data can be proxied reasonably well by similar measures using less data. We further discuss this issue in the next section and analyze the importance of the disclosure in the context of pricing.

And correlation with yields?

Analyzing the effect of the trading activity variables in the full model, we find economically significant results only for the trading interval: An increase in the trading interval by one standard deviation is associated with an increase in the yield spread of 15 bp. The information contained in the other trading activity variables, e.g., traded volume, seems to be adequately represented by the liquidity measures. However, more important are the results for the product characteristics. The most relevant variable in the full model turns out to be the coupon. A one-standard-deviation higher coupon results in an increase of 137 bp in the yield spread. Thus, the coupon rate has the highest explanatory power of all the variables, indicating that a higher coupon is also associated with higher credit risk for certain products, in particular when there is no credit rating available. The amount issued shows important effects as well, where a one-standard-deviation increase leads to an 19 bp decrease in the yield spread: Larger issues have lower yield spreads. The maturity of a structured product is related to the yield spread as well, indicating that longer maturities are associated with somewhat lower spreads. However, compared with the other product characteristics, the maturity is of minor importance. Overall, the full model has an R2 of 69.9% with significant incremental explanatory power shown by the liquidity measures. Thus, liquidity is an important driver of yield spreads in the structured product market; therefore, the dissemination of trading activity information is important, given the size and complexity of this market.

And they conclude:

Exploring the relation between the various liquidity proxies and the depth of disseminated information, we find that product characteristics or variables based on aggregated trading activity, by themselves, are not sucient proxies for market liquidity. The dissemination of the price and volume of each individual trade is important for the quantification of liquidity effects, particularly for explaining yield spreads. However, we also provide evidence that liquidity measures that use additional dealer-specific information (i.e., trader identity and sell/buy-side categorization) can be efficiently proxied by measures using less information. In our regression analysis, we find that liquidity effects cover around 10% of the explained variation in yield spreads. Thus, the dissemination of trading activity is essential, given the trade volume and complexity of this market. These results are important for all market participants in the context of OTC markets, as it allows establishing an understanding of the information content contained in the disclosure of trading data.

Paul Asquith, Thomas R. Covert and Parag Pathak have written a paper titled The Effects of Mandatory Transparency in Financial Market Design: Evidence from the Corporate Bond Market:

Many financial markets have recently become subject to new regulations requiring transparency. This paper studies how mandatory transparency affects trading in the corporate bond market. In July 2002, TRACE began requiring the public dissemination of post-trade price and volume information for corporate bonds. Dissemination took place in Phases, with actively traded, investment grade bonds becoming transparent before thinly traded, high-yield bonds. Using new data and a differences-in-differences research design, we find that transparency causes a significant decrease in price dispersion for all bonds and a significant decrease in trading activity for some categories of bonds. The largest decrease in daily price standard deviation, 24.7%, and the largest decrease in trading activity, 41.3%, occurs for bonds in the final Phase, which consisted primarily of high-yield bonds. These results indicate that mandated transparency may help some investors and dealers through a decline in price dispersion, while harming others through a reduction in trading activity.
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Proponents of TRACE argue that transparency makes the corporate bond market accessible to retail clients, enhances market integrity and stability, and provides regulators greater ability to monitor the market. They reason that with the introduction of transparency, price discovery and the bargaining power of previously uninformed participants should improve (NASD 2005). This in turn should be reflected in a decrease in bond price dispersion and, if more stable prices attract additional participants, an increase in trading activity (Levitt 1999).

Opponents of TRACE object to mandatory transparency, saying that is unnecessary and potentially harmful. They argue that “transparency would add little or no value” to highly liquid and investment grade bonds since these issues often trade based on widely known US Treasury benchmarks (NASD 2006). They further argue that if additional information about trades was indeed valuable, then third‐party participants would already collect and provide it, a view that dates back to Stigler (1963). Opponents also forecast adverse consequences for investors since, if price transparency reduces dealer margins, dealers would be less willing to commit capital to hold certain securities in inventory making it more difficult to trade in these securities. The Bond Market Association argued that the adverse effects of transparency may be exacerbated for lower‐rated and less frequently traded bonds (Mullen 2004). Lastly, opponents saw TRACE as imposing heavy compliance costs, particularly for small firms who do not self‐clear (Jamieson 2006). Thus, opponents argue that market transparency reduces overall trading activity and the depth of the market. Not surprisingly, similar arguments for and against transparency have resurfaced in response to the recent introduction of the Dodd‐Frank’s post‐trade transparency requirements for swaps (Economist 2011).

With all respect to the various debaters, and while recognizing that the above is an extremely quick summary of their thoughts, I have to say that all the quoted arguments miss the mark. The fundamental question is: what is the corporate bond market for? I claim that the purpose of the corporate bond market is to allow issuers to access capital at as little cost as possible; therefore, all regulation related to the bond market should be first examined through the lens of ‘what will this do to new issue spreads?’. While this is not the only thing to be addressed, it is the most important thing and it is something I rarely see addressed.

It was addressed, however, in a 2012 comment letter to FINRA from SIFMA:

Issuers face the ultimate risk from decreases to market liquidity since the public dissemination of trade information, as a general matter, makes broker-dealers less willing to take risk on large size trades. A reduction in liquidity will cause institutional investors to demand greater yield from issuers (to compensate for the reduced liquidity), or to simply refuse to buy new issues in meaningful size. Therefore, a careful balance between transparency and the preservation of liquidity must be struck. Data shows that dealers have recently chosen to (or been forced to, in the case of rules like the Volcker Rule) put capital to work elsewhere. This means that institutional investors will face greater difficulty selling a larger sized amount of an issue. Pre-TRACE, and pre-financial crisis, dealers provided a much larger outlet where they would take the risk temporarily while they worked to uncover a buyer. This outlet has been much reduced in recent years, due to a combination of regulation and other market structure issues. The real liquidity differential for larger vs. smaller “on the run” amounts has been meaningfully amplified, and eliminating caps on disseminated volumes would exacerbate this problem. At a much more specific level, it is more difficult to issue securities in smaller sizes when participant’s transactions are immediately made public and expose exact amounts taken down by particular investors. An increase in the dissemination caps will increase the threshold where these securities issuances are somewhat more challenging, and disproportionately harm smaller issuers. In each case, the macro and the granular, the result is a higher cost of capital for issuers.

Letting that issue slide for a moment and returning to Asquith, Covert and Pathak:

FINRA implemented TRACE in Phases because of concerns about the possible negative impact of transparency on thinly traded, small issue and low‐credit rated bonds. Examining issue size across all Phases, we find that trading activity decreases more for large issue size bonds, but that the reduction in price dispersion is uncorrelated with issue size. Credit ratings, however, matter for both trading activity and price dispersion. High‐yield bonds experience a large and significant reduction in trading activity, while the results are mixed for investment grade bonds. High‐yield bonds also experience the largest decrease in price dispersion, but price dispersion significantly falls across all credit qualities. Therefore, the introduction of transparency in the corporate bond market has heterogeneous effects across sizes and rating classes.
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Price dispersion also decreases due to TRACE. This decrease is significant across bonds that change dissemination in Phases 2, 3A, and 3B, but is largest, 24.7%, for Phase 3B bonds. This finding is also robust across different measures of price dispersion and alternative regression specifications. Moreover, event studies show that the fall in price dispersion occurs immediately after the start of dissemination. It is important to note, if the transparency introduced in Phase 1 affects bonds that become transparent in subsequent Phases, our estimates are probably lower bounds on TRACE’s overall impact.
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There are several welfare implications of increased transparency in the corporate bond market. One consequence is that it may change the relative bargaining positions of investors and dealers, allowing investors to obtain fairer prices at the expense of dealers. The reduction in price dispersion should allow investors and dealers to base their capital allocation and inventory holding decisions on more stable prices. Therefore, the reduction of price dispersion likely benefits customers and possibly, but not necessarily, dealers.

The implications of a reduction in trading activity are not as clear. Whether a reduction in trading activity is desirable depends on why market participants trade. A decrease in trading activity may be beneficial if much of the trading in a bond is unnecessary “noise” trading. On the other hand, if most trading is information‐based, a decrease in trading activity may slow down how quickly prices reflect new information. In addition, if the decrease in trading activity is the result of dealers’ unwillingness to hold inventory, transparency will have caused a reduction in the range of investing opportunities. That is, even if a decline in price dispersion reflects a decrease in transaction costs, the concomitant decrease in trading activity could reflect an increased cost of transacting due to the inability to complete trades.

Our results on the corporate bond market have two major implications for the current and planned expansions of mandated market transparency. The implicit assumption underlying the proposed TRACE extensions and the use of TRACE as a template for regulations such as Dodd‐Frank is that transparency is universally beneficial. First, it is not clear that transparency for all instruments is necessarily beneficial. Overall, trading in the corporate bond market is large and active, although, as seen, not comparable across all types of bonds. Many over‐the‐counter securities are similar to the bonds FINRA placed in Phase 3B. That is, they are infrequently traded, subject to dealer inventory availability, and trading in these securities is motivated by idiosyncratic, firm‐specific information. Therefore, the expansion of TRACE‐inspired regulations, such as those for 144a bonds, asset‐ and mortgage‐backed securities, and the swap market, may have adverse consequences on trading activity and may not, on net, be beneficial.

Second, our results indicate that transparency affects different segments of the same market in different ways. As a consequence, our results provide empirical support for the view that not every segment of each security market should be subject to the same degree of mandated transparency. Both academic commentators (French et al., (2010), Acharya et al. (2009)) and leading industry associations (e.g., Financial Services Forum, et al., (2011)) have articulated this position. Despite these recommendations, the expansion of transparency by the Commodity Futures Trading Commission (CFTC) in various swap markets, i.e. interest rate, credit index, equity, foreign exchange and commodities, in December 2012 and February 2013 was immediate for all swaps in those markets. This stands in sharp contrast to FINRA’s cautious implementation of TRACE in Phases. The fact that the effect of transparency varies significantly across categories of bonds within the corporate bond market suggests that additional research will be required to evaluate the tradeoffs associated universal transparency in other over‐the‐counter securities.

There is one assertion in the above with which I take particular issue: One consequence is that it may change the relative bargaining positions of investors and dealers, allowing investors to obtain fairer prices at the expense of dealers. Long time Assiduous Readers will probably be snickering to themselves, having determined that I am probably going to complain about the use of the word “fairer”, since I don’t know what “fair” means, and they’re quite right.

By “fair”, I assume the authors mean “at a price closer to the dealers’ cost than otherwise”, but that is not necessarily “fair” when examined in a broader context.

Suppose, for instance, that you are a bond dealer – horns, pitchfork, cloven hooves and all – and somebody asks you to bid on something. OK, so you do – but why do you? The answer, of course, is to make a profit and as a rational economic actor you seek to maximize your profit. But you’re not seeking to maximize your profit on every possible transaction or even to maximize your gross profit; you’re seeking to maximize the annual profit of your desk expressed as a fraction of your capital. This has a number of implications; for instance, you might give regular customers who deal exclusively with you slightly better prices than the other ones, simply to ensure that these guys never have any reason to consider going anywhere else.

But the most important consideration for purposes of this discussion is the question of maximizing profitability as a fraction of capital. That’s what determines the firm’s capital allocation and that’s what determines your bonus. And for a single given transaction, we can write the following equation:

Desirability = (Sell – Buy) / (Capital * Days)

Where the gross profitability is the Sell price less the Buy price, Capital is the amount of capital used when financing the position and Days is the number of days you have to hold the thing in inventory until it’s sold (or bought, if the position was initiated with a short sale). In this equation I am ignoring the Carry (the difference between the yield of the bond and the cost of financing it); I’m also ignoring default risk and lots of other considerations, with the objective of keeping this simple.

Under the pre-TRACE regime, one way to maximize trade desirability was, obviously, to maximize the difference between your Sell and Buy prices, but TRACE makes that a lot more difficult; after all, that’s the whole point of TRACE and Asquith, Covert and Pathak have made a solid argument that it is not happening to the same extent under TRACE as it was in the good old days. So for practical purposes, when the dealer is putting a price on taking a position, he is doing so with the knowledge that gross profit is capped.

The “Capital” term in the simplified equation is set by regulation and the bond desk has no control over it. As far as they’re concerned, it’s a constant.

Therefore, in order to increase the Desirability of the trade, the only avenue left open to the dealer is Days, which is inversely related. If they can make their $0.50 per bond profit in one day, that’s a whole lot better than if it takes a month! Therefore, when taking a position, they will concentrate their energies on how they will flatten their position. This will, of course, be much easier if they offer their position to a potential buyer at an attractive price. Therefore, I claim, TRACE will lead to the initial seller getting a really lousy price for his bond, which is turned over in short order to the ultimate buyer who gets a really good price.

There is evidence for this in the secondary GIC market, which has to be one of the most ridiculously infinitesimal markets in the world, but which exists at the major dealers not so much as a money-maker, but as a service to clients. Some GICs are transferrable and the dealer will buy them from the owner at a really, really lousy price – I think the bid yield is about 150bp over the market rate, but I confess I’m not too sure of that. I have a major dealer’s offering sheet from 2012 on hand, which is headed by the statement: “ALL Secondary GICS offered at approximately +50bps over today’s Best GIC Rates (on the [Redacted] System”

This is a great deal for buyers, and I have often recommended to clients that they open accounts at a major dealer for the purpose of access to new issues and access to secondary GICs. And why I am I saying this? Because I think the buyer will get a “fair” price, just like teacher talked about in kindergarten? Hell, no! It’s because I think the buyer will get a really good price, courtesy of the really, really shitty price that was offered to the poor sucker who needed to cash his GIC early.

Now this example comes from a market that barely exists, but I claim that it shows in sharp relief the problem with TRACE – which is that it encourages prices that are not “fair”, but prices that really stick it to the liquidity seeker in order to reward both the interim and the ultimate liquidity supplier.

And I will claim that this cannot be considered a Good Thing. This is an increase in the cost of liquidity, which leads to a decline in liquidity, which leads to an increase in the liquidity premium demanded for holding a position, which leads to higher coupons required from the issuer at issue time. And I claim that this is a Bad Thing because the purpose of the corporate bond market is to allow issuers to source cheap capital.

Note that none of these assertions has been tested, but for now we’ll call it the Shitty Price Hypothesis. It has the advantage of actually providing a causal mechanism for the reduction of trading experienced under TRACE: say you’re a portfolio manager and there’s a wave of redemptions. You have to raise cash. In the old days, you could utilize the opportunity to rebalance and improve your portfolio slightly. Got too much junk in the portfolio? Fine, raise the cash by selling it. But if all you see is stink-bids, you’re almost forced to move up the credit quality ladder and sell something more liquid. Thus, TRACE has made it more difficult for you to do your job.

To be fair, the authors make what might be an indirect allusion to this at the end of their Section 6:

In addition, the bond market is a dealer market, so dealer inventory will affect trading levels and the potential impacts of TRACE. Dealers only hold inventory in those bonds with sufficient trading activity to cover their carry cost. Thinly traded bonds may require dealers to have higher spreads to cover their holding costs. Since TRACE reduces price dispersion significantly, the benefit of holding bonds in inventory decreases. TRACE reduces price dispersion the most for high‐yield bonds, so the incentive to reduce inventory is strongest for those bonds. Thus, lower trading activity in high‐yield bonds post‐TRACE may be the result of a supply‐side response of dealers.

Another paper I found while updating myself on academic commentary about TRACE was by Rainer Jankowitsch, Amrut J. Nashikkar and Marti G. Subrahmanyam, titled Price Dispersion in OTC Markets: A New Measure of Liquidity:

In this paper, we model price dispersion effects in over-the-counter (OTC) markets to show that in the presence of inventory risk for dealers and search costs for investors, traded prices may deviate from the expected market valuation of an asset. We interpret this deviation as a liquidity effect and develop a new liquidity measure quantifying the price dispersion in the context of the US corporate bond market. This market offers a unique opportunity to study liquidity effects since, from October 2004 onwards, all OTC transactions in this market have to be reported to a common database known as the Trade Reporting and Compliance Engine (TRACE). Furthermore, market-wide average price quotes are available from Markit Group Limited, a financial information provider. Thus, it is possible, for the first time, to directly observe deviations between transaction prices and the expected market valuation of securities. We quantify and analyze our new liquidity measure for this market and find significant price dispersion effects that cannot be simply captured by bid-ask spreads. We show that our new measure is indeed related to liquidity by regressing it on commonly-used liquidity proxies and find a strong relation between our proposed liquidity measure and bond characteristics, as well as trading activity variables. Furthermore, we evaluate the reliability of end-of-day marks that traders use to value their positions. Our evidence suggests that the price deviations are significantly larger and more volatile than previously assumed. Overall, the results presented here improve our understanding of the drivers of liquidity and are important for many applications in OTC markets, in general.
…
Using a volume-weighted hit-rate analysis, we find that only 51.12% of the TRACE prices and 58.59% of the Markit quotations lie within the bid and ask range quoted on Bloomberg. These numbers are far smaller than previously assumed. Since these marks are widely used in the financial services industry, our findings may be of interest to financial institutions and their regulators.

The evidence that so many actual prices are outside the pre-trade quote is supportive of the Shitty Price Hypothesis, but more detail is needed!

And now 144a (exempt) bonds are being TRACEd:

Corporate-bond brokers may face a squeeze on profits as regulators start publishing prices for almost $1 trillion of privately sold debt, if the past is any guide.

The Financial Industry Regulatory Authority, seeking to “foster more competitive pricing,” plans to start disseminating trading levels for securities issued under a rule known as 144a on its 11-year-old Trace system within the next year. That means the notes, sold only to institutional investors, will face the same price transparency as publicly registered corporate bonds for which buyers demand half a percentage point less in yield spreads. Brokers typically are paid larger fees from higher-yielding debt.

Firms from Knight Capital Group Inc. to Gleacher & Co. and Pierpont Securities LLC sold or shuttered credit units this year as corporate-bond trading volumes fell to the lowest proportion of the market on record and smaller price swings shrink potential profit margins.
…
Stamford, Connecticut-based Pierpont, one of the dealers started after the 2008 collapse of Lehman Brothers Holdings Inc. decided to exit the high-yield bond and loan business this month. New York-based Gleacher said in April that it was exiting fixed-income trading and sales. Knight in Jersey City, New Jersey, sold its credit-brokerage unit to Stifel Financial Corp., according to a July 1 statement.

Jefferies Group LLC, the investment bank owned by Leucadia National Corp., said profit plunged 83 percent in the three months ended Aug. 31 as trading revenue fell to the lowest since the depths of the financial crisis.

OSFI has published Remarks by Superintendent Julie Dickson to the 58th Annual Canadian Reinsurance Conference, Toronto, Ontario, April 2, 2014:

We were recently subject to an IMF financial sector assessment (i.e. FSAP). The FSAP process determines a country’s compliance with international standards and provides an overview of the economic health of a country as well as regulatory effectiveness. The assessors were asked to look for any signs of complacency at OSFI. I am happy to say that they did not find any. They have concluded that we continue to be effective with a high level of compliance with international standards. [Footnoted link]
…
OSFI tends to strongly support global standards and practices, versus entering into endless debates about whether we need them.
…
I was very happy to see the December 2013 report of the U.S. Department of Treasury, on modernizing insurance regulation. It did not mince words in advocating group capital adequacy and consolidated supervision in the U.S., something that has been debated for a long, long time. [Footnoted link]
…
The IAIS [International Association of Insurance Supervisors ] is developing backstop capital requirements, as well as higher loss absorbency requirements for designated Global Systemically Important Insurers (G-SIIs), as well as global Insurance Capital Standards for all internationally active insurance groups (or IAIGs).

Harmonization of insurance capital requirements globally is an important development. It is premature to determine the impact these will have on Canadian capital requirements. Therefore, as expected, OSFI intends to continue development of our internal set of rules, given the international global standard might initially act as only a minimum requirement until sufficient time has been allowed to develop and test a robust enough capital test.

The first footnoted link is to the IMF’s Canada page, which is headed by a link to CANADA – FINANCIAL SECTOR ASSESSMENT PROGRAM – CRISIS MANAGEMENT AND BANK RESOLUTION – FRAMEWORK—TECHNICAL NOTE:

The ex-ante funding of CDIC should continue to be bolstered. To achieve the targeted 100 basis points coverage of the insured deposits (from the current 39 basis points), an increase of the premiums paid by financial institutions will be necessary. Enhanced data collection on depositors would ensure that the coverage limit and the target ex-ante financing strike the right balance between depositor protection, financial stability, and market discipline. The proposed simplification of the rules for eligibility for deposit insurance of complex deposit products is welcome.
…
The Canadian financial system is large, relatively complex, and concentrated. The financial system accounts for almost 500 percent of the GDP and is composed of a large spectrum of federally and provincially regulated institutions. The six domestic systemically important banks (D-SIBs) and one large provincially incorporated credit cooperative network hold almost half of the financial sector assets. The financial system was exceptionally resilient during the global financial crisis and no financial institution had to be closed or rescued.
…
A number of legal provisions create room for “constructive tensions” between the
OSFI and CDIC, at which point their actions should be closely coordinated. For example, CDIC can terminate deposit insurance, even if the institution is still solvent (Section 30 of the CDIC Act). In the past, the CDIC has terminated deposit insurance as an enforcement action against two solvent members. Such powers were used by the CDIC when it was responsible for the administration of the Standards of Sound Financial and Business Practices. The CDIC has to be concerned about minimizing the exposure of the insurance fund to loss from failing institutions. This could create an incentive to resolve an institution sooner rather than later—for instance, to lean against perceived regulatory forbearance—but may conflict with supervisory interests. Such risks call for close bilateral coordination between the OSFI and CDIC, as well as though the FISC cooperation.
…
The authorities should consider introducing some form of depositor preference. Depositor preference not only mitigates the risk of depositor runs, it can also improve recoveries for depositors, the deposit insurance agencies, and the government in the case of a bank’s failure. In the context of the proposal to introduce bail-in powers, the introduction of depositor preference is all the more important as unsecured creditors will need to be written-down or have their debts converted into equity. If depositors are ranked equally with unsecured creditors, a bail-in cannot be effected without discriminating within the class of creditors. Depositor preference could be tailored to take different forms (although national depositor preference should be avoided as it could hamper cross-border resolution), based on a rigorous analysis of the desired impact and interaction with other features of the existing bank operating and resolution framework (Appendix II).
…
The CDIC is ex-ante funded and reviews its target funding level regularly.CDIC currently has funding of Can$2.6 billion representing an estimated 39 basis points of insured deposits. The existing resources are sufficient to repay insured deposits in all small banks individually, or concurrently in a number of small banks, but would not be sufficient to cover insured deposits in a medium-sized institution. The relatively low level of ex-ante coverage reflects a long period of time in which the corporation had to recover from substantial losses incurred in the mid eighties and early nineties. The CDIC plans to achieve a minimum target ex ante funding of 100 basis points of insured deposits (currently equivalent to Can$6.5 billion), over the coming ten years.
…
In addition, CDIC can terminate deposit insurance (as per Section 30 Report). The basis for termination can be evidence of unsound standards of prudent business financial practices (e.g. unsound capital management). The issuance of a Section 30 report is typically preceded by the conduct of a special examination, following which the institution has to rectify the situation. A copy of the Section 30 report shall be provided to the MOF (or provincial Minister if provincial member) and indicates that a failure to remedy the situation could lead to the termination of the deposit insurance policy. The MOF has the power to override such decision based on public interest grounds.

76. The termination of deposit insurance triggers the taking control of the supervised institution by OSFI. The existing eligible deposits would continue to be insured for two years from the termination date (or for term deposits with a longer term, until the maturity date of the term deposit). Alternatively, CDIC has the discretionary authority to make an immediate deposit insurance payment for all eligible deposits. In its history, CDIC has terminated the deposit insurance policy of three member institutions through the Section 30 process and has immediately reimbursed deposits in all the three cases.
…
The NVCC is a gone-concern contingent instrument. The NVCC aims to ensure that investors in non-common Tier 1 and Tier 2 regulatory capital instruments bear losses before taxpayers where the government determines it is in the public interest to rescue a non-viable bank, based on clearly specified trigger events. The NVCC triggers are very late and very remote and the Canadian authorities confirm that they would only elect to trigger the NVCC where there is a high level of confidence that the conversion accompanied by additional measures (i.e. liquidity assistance provided by BOC, liquidity assistance provided by CDIC, change in management, change in business plan, public or private capital injection) would restore the viability of the failed financial institution. The NVCC instruments are not contingent convertible instruments (Co-Cos), the key distinction being the timing and nature of the NVCC triggers, which can be exercised only at the discretion of the authorities at the point of non-viability.
…

The NVCC is just an option in the resolution toolkit. The decision to maintain an institution as a going concern where it would otherwise become non-viable will be informed by OSFI’s interaction with the FISC and on the CDIC Board of Directors. However, the Canadian authorities will retain full discretion to choose not to trigger NVCC notwithstanding a determination by the Superintendent that an institution ceased, or is about to cease, to be viable. Therefore, other resolution options, including the creation of a bridge bank, could be used to resolve a failing institution either as an alternative to NVCC or in conjunction with or following an NVCC conversion, and could also subject capital providers to loss.
…
To the date when the FSAP was conducted, none of the major banks had issued a de novo NVCC instrument, although the first issuance was expected soon. CIBC did, however, amend via a deed poll the terms of three series of its preferred shares to make them NVCCcompliant. A number of smaller, closely-held banks have issued NVCC or modified instruments to make them NVCC-compliant. For these banks, OSFI has permitted alternatives to the market-based conversion required under the CAR Guideline to accommodate the unlisted nature of their common shares or intercompany issuances where all of the capital has been issued to the parent or affiliates. Under the CAR Guideline, each instrument must have a formula governing the conversion mechanism that references the market value of equity when OSFI determines the institution is no longer available. OSFI expects good demand from institutional fixed income and other investors for NVCC.
…
Furthermore, the bail-in regime needs to be consistent with other financial stability objectives. Several long-term aspects will need to be carefully taken into consideration when introducing the new regime. The introduction of bail-in could increase the funding costs for unsecured debt and which may, in turn, trigger shifts in banks’ liability structure towards other forms of funding (i.e. secured) which are outside the scope of the bail-in regime. Such arbitrage incentives would be countered, however, by other regulatory measures including the Basel III Net Stable Funding Ratio which will incentivize banks to hold higher levels of stable, long-term funding; and asset encumbrance limits that restrain banks’ reliance on secured debt funding. It would be also useful to consider requiring the D-SIBs to hold a minimum amount of capital instruments and senior, unsecured debt in conjunction with the bail-in regime to ensure a minimum amount of gone-concern loss-absorption capacity. Last, when deploying bail-in, authorities should be mindful of cross-sector contagion in crisis times, as for example insurance companies are major investors in banks’ debt instruments.

The second footnote of Dickson’s speech references the Reports & Notices page of the US Treasury; the first link there is to How to Modernize and Improve the System of Insurance Regulation in the United States:

By drawing attention to the supervision of diversified complex financial institutions such as American International Group, Inc. (AIG), the financial crisis added another dimension to the debate on regulating the insurance industry. The crisis demonstrated that insurers, many of which are large, complex, and global in reach, are integrated into the broader U.S. financial system and that insurers operating within a group may engage in practices that can cause or transmit severe distress to and through the financial system. AIG’s near-collapse revealed that, despite having several functional regulators, a single regulator did not exercise the responsibility for understanding and supervising the enterprise as a whole. The damage to the broader economy and to the financial system caused by the financial crisis underscored the need to supervise firms on a consolidated basis, to improve safety and soundness standards so as to make firms less susceptible to financial shocks, and to better understand and regulate interconnections between financial companies.
…
If an insurer is to receive credit against a capital or reserve requirement because of risk transferred to an insurance captive, the rules governing the quality and quantum of assets offered in support of the captive should be uniform across states and sufficiently robust and transparent in order to prevent arbitrage by insurers. The matter is one that must be assessed within the rubric of the capital adequacy of an insurance group as a whole. Under the current state-based capital adequacy regime, group capital assessments rely on CRA ratings or on a firm-produced ORSA to evaluate a group’s capital position and the strength of intra-group guarantees. Neither of these measures of group capital adequacy, however, is a substitute for group capital standards that are established and supervised by regulators.

An article in the Globe and Mail brought to my attention a paper by the eponymous Will Dunning Inc. titled How to Dissect a Housing Bubble which seems highly worthy of close attention:

This report begins (in section 2.0) by looking at one of the key pieces of evidence that is brandished by those who believe a housing bubble exists in Canada: data on the ratio of house prices to rents, which has been created by the Organization for Economic Co-operation and Development (“OECD”). To be blunt, while the OECD has relied on data that it might consider the best available for the purpose, the data in reality is badly flawed and results in wildly inaccurate estimates.

The subsequent section (3.0 A Better Dataset) utilizes an alternative dataset, from the Royal LePage House Price Survey2. This analysis finds that the price to rent ratio in Canada has indeed increased, although the rise in the ratio is much less than was estimated by the OECD.
…
Section 4.0 (Housing Affordability Indicators) takes a slightly different approach, looking at evolving mortgage costs in relation to incomes. Several organizations publish housing affordability indexes. These generally indicate that housing affordability has deteriorated in Canada, and this has become an important part of the discussion. In this author’s opinion, these indexes share a major flaw: they rely on a measure of interest rates (“posted rates”) that exists only for administrative purposes and is divorced from the interest rates that can be found in the marketplace.

Well! That’s provocative enough, but I’ll grant him more credibility than the usual purveyors of shadow-statistics. The mortgage and GIC rates posted by the Bank of Canada are nonsensical (perhaps the legacy of some plan hatched by the Feds and executed by Lapdog Carney) – a five year mortgage is listed as costing 5.24% for the last three weeks of February and 4.99% for the first two weeks of March. Give me a break. Those are the posted rates – the banks have found that by having a posted rate and applying a discount, they can issue mortgages at the discounted price, but force buy-backs at the posted price when mortgagors exit early. Nice work, if you can get it, but why is the BoC participating in this charade? They’ve been reporting 5-Year GICs at 1.63% for the past five weeks, which will surprise anybody with access to the Financial Post web page or any of the myriad web sites which are able to report financial data more accurately than Parakeet Poluz and his fellow lackeys.

Actually, it’s even worse than it looks – Dunning claims:

Posted rates exist for administrative purposes only: lenders must use them in the calculation of debt service costs for some mortgages that receive federally guaranteed mortgage insurance. In mortgage contracts, interest rates and options for future interest rates are sometimes expressed as the posted rate minus a discount. In addition, when lenders calculate the penalties that borrowers pay for repaying early, posted rates (minus a pre-determined discount) are often in input into the calculations.

Dunning charges that:

The OECD calculates the Canadian house price to rent ratio using:

• • For house prices – the Teranet/National Bank National Composite House Price Index from 1999Q2. Prior to that date, data are from the Canadian Department of Finance.
• • For rents, the rent component of the Consumer Price Index (“CPI”)

…
For the years prior to 1999 (during which it appears that the CREA average national resale price is used), the rates of price growth have likely been distorted upwards by changes in the quality of the housing inventory.
…
Looking at the rent data used in the calculation (the rent component of Statistics Canada’s Consumer Price Index), rates of rent growth are badly under-estimated.

Data from rental surveys conducted by Canada Mortgage and Housing Corporation (“CMHC”) hint at the degree to which rent increases have been under-estimated in the Statistics Canada data that has been used by the OECD. It is clear in this data that the methodology change made in 2009 did not fully cure the data quality issues, and that the CPI rent index remains highly inaccurate.

The chart to the right presents CMHC data on average rents for apartments (units with two bedrooms) in Canada. To permit comparison to the rent component of the Consumer Price Index, the author has converted both datasets to indexes that equal 100 in 1992. Over the entire period covered, the CMHC data shows a total increase of 57.4% (2.2% per year); the CPI data shows a total rise of 32.7% (1.4% per year). Even for the period subsequent to the 2009 methodology revision, the CPI data shows a significantly slower rate of rent growth (1.3% per year) compared to the CMHC data (2.4% per year).

It can be argued that the CMHC data is not “constant quality” (because of additions to the inventory through new construction as well as due to renovations) and therefore the CMHC data might be distorted compared to the CPI (which attempts to measure rent change for constant quality accommodation). However, it should be noted that there are few additions to the inventory that is covered by the CMHC rental market survey – during the time period covered in the chart most growth of rental inventory has been in rented condominiums and other housing forms that are not included in the survey. Therefore, the degree of distortion from new supply is likely to be very small.

Interesting, indeed! This indicated long-term underestimation of rental growth is given credence by the OECD figures that are so fraught with interest:

Now, I’m reserving judgement on whether we’re in a housing bubble or not. I won’t even express a view as to whether houses are currently either rich or cheap. But I will not believe, not for one New York minute, that the Price-to-Rent ratio has quintupled since 1970. And, while I realize that Toronto is not actually equivalent to Canada (there are still a few unfortunate districts in the country), I will not believe, not for one New York minute, that the Price-to-Rent ratio has doubled since the bubble I remember of the late eighties, when one of my fellow clerks – making a clerical salary and not blessed with independent wealth – owned four houses, each of them mortgaged to hell ‘n’ gone (she got wiped out).

Of particular interest is his comparison of CMHC figures and the rent component of inflation:

This may well give the conspiracy theorists some live ammunition about CPI underestimation, at long last, but there’s more too it than simply academic discussions of price-rent ratios – the CPI is used to increment rent-control limits. One does not need to be a rabid partisan of Mike Harris to believe that rent control destroyed traditional rental housing in Toronto; a long term underestimate of rent increases just makes it more obvious.

That’s the meat of the report I found most interesting … I’ll just reproduce two more charts:

The current calculated cap rate of 4-5% looks right to me. In one building with which I am familiar, two-bedrooms sell for about $140,000, or can be rented for about $1,200 monthly – and this is roughly average for the area according to the CMHC. There’s a $600 maintenance fee, so the landlord’s cap rate is … just under 5%.

Anyway, this report is fraught with interest, what with us being told daily that we’re in imminent danger of a crash. The OECD and its fellow travellers need to address these issues and explain why they believe their figures to be accurate indicators of the Canadian housing market.

DBRS has announced that it:

has today published updated versions of two Canadian structured finance methodologies:
— Stability Ratings for Canadian Structured Income Funds
— Rating Canadian Split Share Companies and Trusts

Neither of the methodology updates resulted in any meaningful changes and as such, neither publication has resulted in any rating changes or rating actions.

DBRS’s criteria and methodologies are publicly available on its website, www.dbrs.com, under Methodologies. DBRS’s rating definitions and the terms of use of such ratings are available at www.dbrs.com.

Of interest in the methodology is the explicit nature of their rating categories (I have added the Asset Coverage Ratio, calculated from the Downside Protection):

and

Also noteworthy is:

The importance of credit quality in a portfolio increases as the diversification of the portfolio decreases. To be included as a single name in a split share portfolio, a company should be diversified in its business operations by product and by geography. The rating on preferred shares with exposure to single-name portfolios will generally not exceed the rating on the preferred shares of the underlying company since the downside protection is dependent entirely on the value of the common shares of that company.

They are, quite reasonably, unimpressed by call writing strategies:

DBRS views the strategy of writing covered calls as an additional element of risk for preferred shareholders because of the potential to give up unrealized capital gains that would increase the downside protection available to cover future portfolio losses. Furthermore, an option-writing strategy relies on the ability of the investment manager. The investment manager has a large amount of discretion to implement its desired strategy, and the resulting trading activity is not monitored as easily as the performance of a static portfolio. Relying partially on the ability of the investment manager rather than the strength of a split share structure is a negative rating factor.

They even have a table for the effect of cash grind (which is a special case of Sequence of Return Risk):

I consider their VaR methodology highly suspect:

The steps in the VaR analysis completed by DBRS are as follows:
(1) Gather daily historical performance data for a defined period.
(2) Annualize each daily return by multiplying it by the square root of the number of trading days in a year.
(3) Sort the annualized returns from lowest to highest.
(4) Using the initial amount of downside protection available to the preferred shares, determine the appropriate dollar loss required for the preferred shares to be in a loss position (i.e., asset coverage ratio is less than 1.0)
(5) Solve for the probability that will yield a one-year VaR at the appropriate dollar-loss amount for the transaction.
(6) Determine the implied long-term bond rating by comparing the probability of default with the DBRS corporate cumulative default probability table.
(7) Link the implied bond rating to the appropriate preferred share rating using an assumption that the preferred shares of a company should be rated two notches below the company’s issuer rating.

As stated, it’s nonsensical. Whatever one’s views on long-term mean reversion of equity returns, there is definitely short-term mean reversion, so annualizing a single day’s return is far too pessimistic. Using the square root of the days in the year to annualize the results implies that each day’s returns are independent.

There’s a big table titled “Maximum Preferred Share Ratings Based on Portfolio Credit Quality and Correlation”, which I won’t reproduce here simply because it’s too big.

I am not a big fan of this “base case plus adjustments” methodology and (not surprisingly) continue to prefer my own stochastic model, which is used in every edition of PrefLetter. Implications of my methodology have been discussed in my articles It’s all about Sequence and Split Share Credit Quality.

An article in the Globe and Mail by Grant Bishop titled Canadian Banks: Bigger is better highlighted views regarding Canadian banking regulation that differ from my own:

A recently published paper by Columbia University’s Charles Calomiris argues that banking crises have political foundations. He contends that anti-populist political structures guard against the capture of the banking system by voters seeking easy credit. But parts of Mr. Calomiris’ thesis have raised eyebrows: he implies that the British aim of oppressing French Canada is the indirect root of Canada’s long-term banking stability.
…
What policy-makers should take away from Calomiris’ account is the importance of keeping politics away from banking regulation. As Anita Anand and Andrew Green of the University of Toronto also argue in a recent paper, the independence of financial regulation from politics in Canada is a cornerstone of the integrity of our system.

It is, of course, my argument that both OSFI and the Bank of Canada have become intensely politicized in over the recent past, with both Carney and Dickson acting as stalking horses for politically inspired regulatory ideas (mostly to do with contingent capital and the Ban The Bond movement).

In another recent paper, UBC’s Angela Redish and her colleagues ask “Why didn’t Canada have a banking crisis in 2008 (or in 1930, or 1907, or…)?” They conclude that, in contrast with the fragmented U.S. system, Canadian banking stability owed to the single overarching regulator and the high concentration of the sector.

A cross-country study by World Bank researchers reaches a similar conclusion: more concentrated banking systems appear to be more stable.

The paper by Anita Anand & Andrew Green titled REGULATING FINANCIAL INSTITUTIONS: THE VALUE OF OPACITY has the abstract:

In this article, we explore a question of institutional design: What characteristics make a regulatory agency effective? We build on the growing body of administrative law literature that rigorously examines the impacts of transparency, insulation, and related administrative processes. We argue that there are certain benefits associated with an opaque and insulated structure, including the ability to regulate unfettered by partisan politics and majoritarian preferences. We examine Canada’s financial institution regulator, the Office of the Superintendent of Financial Institutions (OSFI), whose efficacy in part explains the resilience of Canada’s banking sector throughout the financial crisis of 2008. In particular, OSFI operates in a “black box”, keeping information about the formation of policy and its enforcement of this policy confidential. With its informational advantage, it is able to undermine the possibility that banks will collude or rent-seek. Our conclusions regarding the value of opacity cut against generally held views about the benefits of transparency in regulatory bodies.

Huh. I wonder if they’re also in favour of re-establishing the Star Chamber, which worked very well until it didn’t.

The body of this paper commences with the startling claim:

Canada’s financial institutions weathered the crisis well relative to their international peers, an outcome that has been attributed at least in part to the presence of an effective regulator.[Footnote]

Footnote reads: See Canadian Securities Institute, Canadian Best Practices Take Centre Stage at Financial Conference in China (25 February 2009), online: Focus Communications Inc ; Financial Services Authority, Bank of England & Treasury, Financial Stability and Depositor Protection: Further Consultation (London: HM Treasury, 2008), online: HM Treasury

The Canadian Securities Institute is not something I consider an authoritative, or even credible, source, so I looked for the paper HM Treasury: Financial stability and depositor protection: further consultation, July 2008 which contains four instances of the word Canada (in each case, grouped with other countries as a participant or example), no instances of “OSFI”, one instance of “Superintendent” (the “Superintendents’ Association of Northern Ireland”, which responded to an earlier consultation), and two instances of “effective regulat”, both of which referred to the UK bodies aspirations.

Ratnovski and Huang, for example, examine the performance of the seventy-two largest commercial banks in OECD countries during the financial crisis, analyzing the factors behind Canadian banks’ relative resilience at this time.[Footnote 4] They identify two main causes, one of which is regulatory factors that reduced banks’ incentives to take excessive risks.[Footnote 5]

Footnote 4 reads: Lev Ratnovski & Rocco Huang, “Why Are Canadian Banks More Resilient?” (2009) IMF Working Paper No 152, online: Social Science Research Network .

Footnote 5 reads: Ibid. Other factors included a higher degree of retail depository funding, and to a lesser extent, sufficient capital and liquidity.

The Ratnovski & Huang paper was reviewed in my post Why Have Canadian Banks Been More Resilient?. The paper is available from the IMF

Specifically, Ratnovski & Huang say:

The second part of this paper (Section 3) reviews regulatory and structural factors that may have reduced Canadian banks’ incentives to take risks and contributed to their relative resilience during the turmoil. We identify a number of them: stringent capital regulation with higher-than-Basel minimal requirements, limited involvement of Canadian banks in foreign and wholesale activities, valuable franchises, and a conservative mortgage product market.

Returning to the Anand & Green paper, the guts of the argument is:

OSFI’s efficacy may at first be surprising. It is the primary regulator of Canada’s five big banks (which account for approximately 85 percent of Canada’s banking sector).10 Its power to overcome the possibility for rent seeking or capture by these institutions depends on its rule making and enforcement processes, and forms of accountability for its actions. That is, if not sufficiently independent, regulated institutions might seek rules that favour their profitability at the expense of consumers. Yet on many important issues, including capital adequacy requirements, OSFI relies on guidelines rather than regulations. OSFI creates these guidelines through a largely opaque process in which the regulated parties have early input. Other parties (such as consumers) not only face considerable collective action problems but are limited to a stunted notice and comment process. The comment process thereby potentially privileges the views of regulated institutions. Further, in addressing compliance with regulations or guidelines, OSFI attempts to work informally with regulated parties, ultimately rendering it unnecessary for it to take formal enforcement action. This structure seems to point more towards capture by the large (albeit regulated) players. To aid in the discussion of the appropriate institutional structure for banks, we examine whether Canada’s financial institutions—and banks in particular—have been successful because of, or despite, the presence of OSFI.

Later comes a real howler:

Despite its insulation and opacity, however, OSFI is almost universally viewed to be an effective regulator.[Footnote 17]

[Footnote 17 reads] The Strategic Counsel, Qualitative Research: Deposit-Taking Institutions Sector Consultation,
(Toronto: 2010) at 2-6, online: OSFI < http://www.osfi-bsif.gc.ca/app/DocRepository/ 1/eng/reports/osfi/DTISC_e.pdf >

So lets have a look at the OSFI document that says OSFI is doing a great job. It’s a survey. Who is surveyed, you may ask. So I will tell you:

A total of 49 one-on-one interviews were conducted among Chief Executive Officers (CEOs), Chief Financial Officers (CFOs), Chief Risk Officers (CROs), Chief Compliance Officers (CCOs), other senior executives, auditors and lawyers of deposit-taking institutions regulated by OSFI.

The use of the phrase “almost universally” seems … a little strained.

The paper’s arguments are founded upon the premise that OSFI is doing a great job, therefore the way it does it must also be great. Unfortunately, the premises do not support the conclusions.