Archive for the ‘Miscellaneous News’ Category

US Fed & Negative Non-Borrowed Reserves

Monday, February 11th, 2008

Frankly, I thought this was over since even Naked Capitalism no longer considers this an issue. But I see that there is a new post at Mish’s Global Economic Trend Analysis that is keeping the flame alive.

I was going to ignore it, when I saw that it has attracted no less than 124 comments, but I can’t bear discussing the matter any further in the daily commentary. So here it is, a post dedicated to this issue, which will be updated if, as and when necessary (hopefully never).

The story so far:

January 29, 2008:

Naked Capitalism is very concerned about a precipituous decline in non-borrowed reserves at the Fed, but I’m not convinced there’s a story here. In the current H3 release, it is disclosed that, of $41,475-million in reserves, only $199-million are non-borrowed. Usually, non-borrowed reserves will be roughly equal to total reserves – implying that net free reserves is about zero. The chart tells the story:

So … what are reserves? The Fed has the answer:

  • Reserve requirements, a tool of monetary policy, are computed as percentages of deposits that banks must hold as vault cash or on deposit at a Federal Reserve Bank.
  • Reserve requirements represent a cost to the banking system. Bank reserves, meanwhile, are used in the day-to-day implementation of monetary policy by the Federal Reserve.
  • As of December 2006, the reserve requirement was 10% on transaction deposits, and there were zero reserves required for time deposits.

There are two things to note here: first, Canada does not have a fractional reserve requirement and second, banks get ZERO interest on their reserves:

The Fed has long advocated the payment of interest on the reserves that banks maintain at Federal Reserve Banks. Such a step would have to be approved by Congress, which traditionally has been opposed because of the revenue loss that would result to the U.S. Treasury. Each year the Treasury receives the Fed’s revenue that is in excess of its expenses. The payment of interest on reserves would, of course, be an additional expense to the Fed.

Thus, all banks will attempt to keep their reserves as close to their requirements as possible. If they have any excess in the system, they will either try to lend them on the Fed Funds market – at the infamous Fed Funds Rate – or withdraw them, to invest the money in … basically anything. Even a one-week T-bill, even now, pays more than ZERO.

Now, along comes the Term Auction Facility. Its value of $40,000-million is – surely not fortuitously! – roughly equal to the total US bank reserve requirement … and it’s available cheap – 3.123%, as pointed out by Naked Capitalism.

If these borrowed term funds were to be left at the Fed – on top of the reserve balances that had been held there previously – then the banks would be borrowing at 3.123% and lending at ZERO. It is my understanding that this sort of negative margin on loans is not considered the road to riches at banking school. But an American stockbroker heard about this, got all excited and appears to have stampeded Naked Capitalism into unnecessary worry.

February 8, 2008:

I discussed the effect of the TAF on bank reserves – and hysterical reactions thereof – on January 29. Naked Capitalism is now republishing a UBS research note that, frankly, I don’t understand at all:

What if the Fed’s rate cuts aren’t motivated by the desire to stave off recession, rather they’re to prevent a major banking crisis. Not one of escalating subprime losses or monoline downgrades, but actually a sheer lack of cash. The Fed’s not telling anyone what it’s up to because it doesn’t want to cause panic, but the evidence is actually there in its own data…

Ok, so things might not be quite as bad as that, but the situation isn’t far off. That’s because of the TAF. ….a savvy bank can put down lesser quality paper that it can’t generally do very much with (and certainly no one else really wants it), raise funds through the TAF, then use those funds to put down as reserves, and then conveniently gets paid a modest rate of interest against those reserves (which acts as a partial offset against the TAF). While there’s a small net cost to the banks, the real loser here is the Fed, what it gets stuck with is an ever growing pile of collateral.

Now consider this – that collateral is actually what’s backing the entire US banking system by way of its conversion to dollars and then the flow of those same dollars back to the Fed….

All this changes the complex of the US banking system somewhat. From the gold standard to the subprime standard perhaps?

In the first place, there is no interest paid on reserve balances. In the second place, the monetary effect of the TAF was neutralized by the Fed’s sale of T-Bills. I note Caroline Baum’s column and say: one may take a view on the advisability of the TAF, one may take a view on capital adequacy, and one may take a view on inter-bank lending; but any hullaballoo over “negative non-borrowed reserves” is hysterical nonsense:

The writer of the e-mail directs his readers to the most recent H.3 report, which shows total reserves ($41.6 billion) less TAF credit ($50 billion) less discount window borrowings ($390 million) equals non-borrowed reserves (minus $8.8 billion). The negative number is really an accounting quirk: If banks borrow more than they need, non-borrowed reserves are a negative number.

This gentleman is overlooking the fact that the Fed is “a monopoly provider of reserves,” said Jim Glassman, senior U.S. economist at JPMorgan Chase & Co. “This is a non-starter. There is no such thing as a banking system short of reserves. The Fed has absolute control over the supply.”

[Update: See also Felix Salmon at Why Non-borrowed Reserves Don’t Matter]

As mentioned above, Mr. Shedlock has now posted another treatise under the title Borrowed Reserves and Tin-Foil Hats. In this post he makes a vast array of points regarding stress on the US banking system – none of them relevant to his previous thesis that the reported Negative Non-Borrowed Reserves was in and of itself an indicator of carnage to come in the sector – on which I will comment as best I can:

Banks participating in the Term Auction Facility (TAF) have to put up collateral for the amounts they borrow.

Clearly, the Fed does not hand out reserves willy-nilly. It lends them, but only if banks have sufficient collateral. Furthermore lending is not “printing”. Thus Glassman, the senior U.S. economist at JPMorgan Chase & Co. really needs an education here.

It is indeed true that the Fed is not currently handing out under- or badly-collateralized reserves, but this is not always the case – I have previously highlighted a paper by Anna J. Schwartz, which argued that the discount window be eliminated due to fears that it might be used to prop up insolvent institutions. Additionally, Mish’s point that the current loans are well-collateralized seems to run counter to his purported thesis.

And, in fact, lending is printing – a colloquialism, to be sure, but the Fed does not have to print dollar bills to inflate the currency. All they have to do is say ‘Hey, presto! You’ve got $50-billion on deposit with us’ to achieve that goal. It is for this reason that when the TAF was implemented, it was simultaneously neutralized in monetary terms by their sale of bills … they deposited $50-billion in various accounts as TAF loans, they withdrew $50-billion from various accounts as payment for the bills. Monetary effect zero.

The Fed does not have “control” over supply of reserves because it does not have control over assets held and loans made by member banks. If Glassman’s thinking is representative of bank thinking in general, it’s no wonder banks balance sheets are so $#@%’d up.

“Assets held and loans made by member banks” represent the demand for reserves. The Fed controls the supply of reserves by virtue of their ability to loan anybody anything on any collateral.

A shortage of reserves comes into play when banks no longer have sufficient collateral to exchange for temporary reserves. Banks that do not have sufficient collateral, do not get loans from the discount window or the TAF. Period. End of Story. The Fed does NOT simply “print money” and hand it out to capital impaired banks. Bankruptcies result.

Fair enough, although as stated above the Fed does indeed have the ability to print money and hand it out to capital impaired banks to avert bankruptcy. Again, I fail to see the relevance to the “negative non-borrowed reserves” issue.

If Citigroup could have borrowed reserves from the Fed at 3-4% wouldn’t it had done so instead of raising $7.5 billion from Abu Dhabi at an interest rates of 11%? See Petrodollars Return Home and Abu Dhabi Deal Raises Questions About Citigroup’s Health for more on Abu Dhabi.

Citigroup went back to the well a second time under even more onerous terms as discussed in Cost of Capital “Ratchets Up” at Citigroup and Merrill.

Umm … the Citigroup / Abu Dhabi deal propped up Citigroup’s capital. They raised Tier One Capital through their deal with Abu Dhabi, not reserves. One would naturally expect a higher rate to be paid on Tier One Capital – to the extent that one can compare rates of expected return on equity vs. debt.

Read this again and again until it sinks in:

Over a third of the nation’s community banks have commercial real estate concentrations exceeding 300 percent of their capital, and almost 30 percent have construction and development loans exceeding 100 percent of capital.There will be more criticized assets; increases to loan loss reserves; and more problem banks. And yes, there will be an increase in bank failures.

No objections here! I can’t help but wonder, though, whether Mish is confounding loan loss reserves with fractional reserves … and wonder what relevance this has with the specific point regarding “negative non-borrowed reserves”.

Why Will Banks Fail?

  • Banks will fail because they do not have sufficient reserves.
  • Banks cannot borrow those reserves because they do not have sufficient collateral.
  • The Fed’s collateral requirements do not permit printing money and handing that money over to failing banks.
  • The Fed will not change those requirements and start printing money because of the “checkmate” scenario discussed below.

Well … let’s see:

  • Lack of reserves is indeed one trigger that could lead to bank failure
  • The banks certainly could borrow these reserves, if the Fed (or anybody else) felt like lending them the money on any collateral they wished. It should be noted that Overnight Fed Funds are explicitly uncollateralized … the problem is getting somebody to lend them to you on such a basis! See also a post on knzn.
  • The Fed’s current collateral requirements do not permit “printing money and handing that money over to failing banks”, but there is no reason why this cannot change
  • Whether or not they may change their collateral requirements in the future is a matter of conjecture and opinion
  • Not a single one of these points is relevant to the topic at hand of “negative non-borrowed reserves”!

Bank reserves are net borrowed. This comes at a time when commercial real estate is about to plunge and bank balance sheets are loaded to the gills with them.

This also comes at a time when social attitudes towards debt are going to impair Bernanke’s ability to inflate. For more on social attitudes, please see 60 Minutes Legitimizes Walking Away, Changing Social Attitudes About Debt, and a Crash Course For Bernanke.

Finally, banks will not be going deeper to the “TAF well” as long as the rules state “All advances must be fully collateralized.” Once collateral runs out, it’s the end of the line.

If the Fed is not concerned about this situation, they soon will be.

Of course there are those who believe the Fed will break the rules and eliminate all collateral requirements. So far anyway, they have not done so. Let’s assume however, when push comes to shove, the Fed acting under duress does just what Glassman says, and provides permanent capital for free.

Finally … a mention of Bank Reserves and “net borrowed” in the same sentence! Unfortunately for Mish, this is criticism of the TAF, not criticism of Negative Non-Borrowed Reserves, which are simply a mathematical result of the TAF.

I will note that Glassman said nothing whatsoever about the Fed providing permanent capital (by which I mean Tier 1 Capital …. I’m not sure what Mish means!) for free. Glassman was not asked about permanent capital – he was asked about reserves.

***************************************************

All in all, Mish’s post reveals more ignorance than analysis. But he certainly seems to have struck a chord with his readers – many of whom are, presumably, clients.

Update: The story has been picked up by the WSJ:

A number of people on Wall Street have noticed a recent plunge in non-borrowed reserves in the banking system and wondered it is a sign of distress in the banking system or of unusually stringent monetary policy. They dropped from $42 billion last November to negative $2 billion at the end of January.

It’s probably a false alarm, though. The drop is purely technical, a function of how the Fed has chosen to classify the money lent through its new Term Auction Facility.

As it happens, in the last week of January
TAF credit reached $50 billion. The amount of bank reserves the same week was only $48 billion. So, by definition, nonborrowed reserves, the difference, fell to negative $2 billion.


Update, 2008-4-29: The Fed has seen fit to comment:

The H.3 statistical release indicates that nonborrowed reserves of depository institutions have declined substantially since mid-December to a level that is now negative. This development reflects the provision of a large volume of reserves through the Term Auction Facility (TAF) and has no adverse implications for the availability of reserves to the banking system.

By definition, nonborrowed reserves are equal to total reserves minus borrowed reserves. Borrowed reserves are equal to credit extended through the Federal Reserve’s regular discount window programs as well as credit extended through the TAF. To maintain a level of total reserves consistent with the Federal Open Market Committee’s target federal funds rate, increases in borrowed reserves must generally be met by a commensurate decrease in nonborrowed reserves, which is accomplished through a reduction in the Federal Reserve’s holdings of securities and other assets. The negative level of nonborrowed reserves is an arithmetic result of the fact that TAF borrowings are larger than total reserves.

Remember … you read it first on PrefBlog!

Intermittent Database Problems

Tuesday, January 15th, 2008

There have problems connecting with PrefBlog!

These are due to intermittent database connectivity problems. My hosting service assures me that their engineers are hard at work, sweating to bring PrefBlog to the huddled masses.

They are unable to tell me when it will actually be fixed. Sorry, people! You’d think that for all the money I spend on a brand-name host, there would be better reliability!

 

S&P/TSX Preferred Share Index Changes Announced

Tuesday, January 8th, 2008

As I noted in November, split shares will shortly be disappearing from the S&P/TSX Preferred Share Index – a change I whole-heartedly endorse, because it will make the index easier to beat.

The semi-annual review has now been completed and a full list of changes is available from S&P.

Readers will remember that this index is the benchmark for the Claymore Preferred Share ETF. Contact any doctrinaire index investors you know, and ask them why they’re dumping their splits!

Update, 2008-3-19: The previous semi-annual review was previously reported on PrefBlog.

Welcome, Omega Preferred Equity!

Tuesday, December 11th, 2007

I issued a press release today:

Hymas Investment Management Welcomes a Preferred Share Competitor

TORONTO, Dec. 11 /CNW/ – James Hymas, president of Hymas Investment Management Inc., welcomed the announcement of Canada’s second actively managed mutual fund concentrated on preferred shares.

“Malachite Aggressive Preferred Fund has, since its inception in March, 2001, shown the value of active management in the preferred share marketplace. While the new Omega Preferred Equity Fund has a mandate allowing for investment in a wide variety of asset classes, the fund sponsor has announced the intention to concentrate on preferred shares. I will be watching them build their performance track-record with keen interest,” he said.

Mr. Hymas commenced his fixed income portfolio management career in 1992, with Greydanus, Boeckh & Associates Inc. At the time of the firm’s sale in 1999, he was Chief Operating Officer, with portfolio management responsibilities for the firm’s $1.7-billion under management. Since founding Hymas Investment Management Inc. in 2000, he has devoted himself to developing analytical frameworks for the analysis of Canadian preferred shares; he writes a daily blog providing news of interest to preferred share investors at http://www.prefblog.com/.

Malachite Aggressive Preferred Fund is available to accredited investors across Canada. Full documentation is available through the Hymas Investment Management website at http://www.himivest.com/.

The statements and analyses in this press release are based on material believed by Hymas Investment Management Inc. (“HIMI”) to be reliable, but cannot be guaranteed to be accurate or complete. The views expressed herein should not be construed as constituting investment, legal or tax advice to any investor, nor as an offer or solicitation of an offer to buy or sell any of the securities mentioned herein. Such views are provided for information purposes only, and neither HIMI nor any of its directors, officers or shareholders accept any liability for investment decisions which are based upon the information contained or views expressed herein. Particular investments and investing strategies should be evaluated relative to each investor’s individual financial situation, investment objectives and risk tolerances, among other factors, and this evaluation should be made by the investor in conjunction with his or her investment and other appropriate advisors. HIMI and its directors, officers and shareholders may from time to time hold long or short positions in the securities discussed in this press release, either on their own behalf or on behalf or individual client accounts or investment funds managed by HIMI.

For further information: James Hymas, (416) 604-4204, jiHymas@himivest.com

It’s always nice to have some company! Hopefully, National Bank’s massive publicity budget will grow the space a little!

S&P/TSX Preferred Share Index to Remove SplitShares

Tuesday, November 27th, 2007

Well – they added them in July … and now it looks like they’re coming out.

I am advised by an Assiduous Reader that:

Standard & Poor’s Canadian Index Services announces that, effective with the December, 2007, semi-annual review of the S&P/TSX Preferred Share Index, there will be a change to the universe of eligible securities for this index. Split preferred shares, which are packaged securities linked to baskets of stocks (or single stocks), will no longer be eligible for inclusion in the index. Split preferred shares that are current constituents of the index will be removed in the upcoming index review, which will become effective after the close of Friday, January 18, 2008.Spit Shares affected: ALB.PR.A, BNA.PR.C, DFN.PR.A, FBS.PR.B, FIG.PR.A, LBS.PR.A, PIC.PR.A, RPA.PR.A, RPB.PR.A, WFS.PR.A

I am advised that this is due to liquidity concerns. I will post a link to a proper press release as soon as I find one … but S&P/TSX just hates giving anything useful away for free!

Update: The press release is on S&P’s site – I missed it earlier because I thought it was entirely about the equity indices. The title is Standard & Poor’s Announces Changes in S&P/TSX Canadian Indices, dated 2007-11-26. The list of split shares affected appears to have been appended by my correspondent; I have checked it against the constituent list and agree.

Update, 2007-11-28: I have spoken to a very pleasant and patient woman at S&P, who confirms my correspondent’s indication that split shares are being removed due to liquidity issues. From the published methodology:

Volume. The preferred stocks must have a minimum trailing three-month average daily value traded of C$100,000 at the time of the rebalancing.

As of November 27, HIMIPref™ calculates the average daily value as:

Split Share
Average Trading Value
Issue A T V
ALB.PR.A 121,670
BNA.PR.C 159,859
DFN.PR.A 105,638
FBS.PR.B 134,628
FIG.PR.A 117,981
LBS.PR.A 107,586
PIC.PR.A 155,473
RPA.PR.A Not Tracked
RPB.PR.A Not Tracked
WFS.PR.A 127,613

Click the link for the HIMIPref™ definition of Average Trading Value; it’s not a “trailing three month average”, but will almost always be less than this figure, due to the imposition of caps on the daily change in the average, put in place to prevent a one-day spike in volume (somebody unloading a million shares, for example) distorting a simulation’s estimate of how much one can reasonably expect to do.

So, it looks like the liquidity constraint as published is not the issue; S&P told me they had also talked to some institutional traders and listened to their liquidity concerns. This makes more sense; the split shares have a decent enough daily volume, but they rarely trade in blocks because very few holders actually have a block to trade. Such traders could accumulate enough shares to make up their trades, but it would be spread out, perhaps over several days, and increase the execution risk on the trade.

We may conclude that the change has been made due to the paucity of block-trading in the split-share market. Fair enough! The elimination of split shares will simply make the index easier to beat and I’m fine with that.

David Berry Hearing Set for December 10

Monday, November 19th, 2007

The hearing into David Berry’s preferred share trading practices originally set for October 29, then postponed has now been rescheduled for December 10 after a rather cryptic ruling on disclosure.

Readers will remember that this case revolves around some fairly minor rule violations that Mr. Berry is alleged to have committed during the course of his employment. Following a contract dispute, Scotia was shocked shocked to discover that rule violations took place.

Mr. Berry’s assistant has settled with RS.

Mr. Berry is suing Scotia for $100-million for unjust dismissal; he is seeking to show that any rule violations are due to inadequate training and supervision. If he can prove this, his case for $100-million becomes a lot stronger; if he can’t prove this, Scotia’s case that firing is an appropriate remedy for the shocking shocking behaviour becomes a lot stronger.

RS is just being used as a pawn here. It’s disgraceful and brings the regulatory system into disrepute. In this particular case, it’s clear from the picayune nature of the allegations that regulation is not being used to protect the marketplace; it’s being used to ensure that everybody is guilty of something.

Irresponsible Accolades by Canadian Business Online

Saturday, November 17th, 2007

Canadian Business Online has a series profiling “Canada’s Best Small Investors” and on October 26 they profiled Rob Morrison.

Now, as it happens, I know Mr. Morrison slightly. He was an active chess player when I was active; he was always much, much better than me (he was a master at the time I was a mere “C Class” player) and our difference in age (he’s about 5 years older) was much more significant at the time, so we never did much more than exchange nods – in fact, I would be flattered if he remembered me.

Anyway, he is profiled in the Canadian Business series. The article has an adulatory tone; there is no actual returns analysis presented in the piece, which is really just a highlights reel of Mr. Morrison’s most stunning investments.

As I’ve mentioned before, this is a warning sign. Yes, you want to know how people achieved their returns; but that’s after you have their track record in hand so you have a better idea of what questions to ask.

I have no complaints about Mr. Morrison’s security analysis, which is not too surprising since the article’s tone is so upbeat. He appears to specialize in distressed – or seemingly distressed – companies that are being beat up by the market even more than they should be. It’s an extreme form of value investing and to some extent might be pigeonholed as ‘special situations’. There’s nothing wrong with that! There’s a lot of money to be made by kindly offering to take investments off the hands of someone who’s panicking.

My ire is aroused by the concentration so blithely applauded in the article:

Morrison started buying in 2000. Jo-Ann’s stock continued to swoon. It hit bottom at about $3 in early 2001, and Morrison invested all the way down. By mid-2001 Morrison was seeing signs of recovery, and in August that year he bet the farm on Jo-Ann.

It was a gutsy move—and a masterstroke. Toward the end of 2001, as Jo-Ann Stores sorted out its inventory problems and secured new financing, its shares rose from $3 to $6. By late summer 2002, they were in the mid-$20s. Later that year, when Jo-Ann hit the high $20s, Morrison began to sell. At that point he had 94% of his holdings invested in the stock.

How could he bet nearly everything on a single distressed company? Morrison says he protected himself the best way he knew how—by paying much less for a good company than he knew it was worth. He had researched every aspect of Jo-Ann Stores. He had even driven to the U.S. with a friend to check out a dozen locations and chat with the sales staff.

Nothing wrong with the analysis.

Everything wrong with the execution.

Putting 94% of your portfolio into a single company is reckless – there’s really no other word for it.

As I have so often emphasized in this blog, the world is a chaotic place. The best analysis in the world relies on things that have already happened … new things can, and do, happen all the time, with unforseen and unforseeable effects.

The only way to guard against such random chance is through diversification. If you make a lot of small bets – and they really are diversified – then the effects of random chance will be mitigated and you will be left with the incremental returns you deserve as the fruits of your analytical labour.

If Mr. Morrison’s investment in Jo-Ann Stores had been limited to, say, 10% of his portfolio, I would be the first to applaud – assuming, of course, that his long term track record, when analyzed properly, is as good as implied in the article.

But in holding up for admiration an investor who put 94% of his portfolio into a single bet, Canadian Business has done small, perhaps impressionable, investors a disservice.

30! 30! 30!

Tuesday, November 13th, 2007

The Montreal Exchange is is launching a futures contract on 30-year Canada bonds.

This is good news for pref-holders; it will increase liquidity at the long end of the market and make perpetuals easier to hedge. It might not have a HUGE effect, but any effect that it does have on the pref market will be positive.

Toronto Star : Preferreds may hold bargains

Tuesday, November 13th, 2007

The Toronto Star published an article today on preferreds, pointing out:

Banks’ preferred shares at current prices are now yielding close to 6 per cent – much more than one can earn on bank deposits. The tax credit on dividend income makes yield even more attractive.

That extra yield does not come without risk, of course. Prices of preferred shares could fall, as happened in May when there was a sudden rise in long-term interest rates.

There wasn’t really a lot of meat on the bones of this story – but I will admit I’m pleased to see media exposure for the asset class! I have to say, though, that “close to 6 per cent” for banks’ preferreds is a little overly enthusiastic.

I should also point out that comparing the yield on bank prefs to bank deposits is a little fishy – bank deposits are not just senior to prefs, they’re insured; and there’s a certain amount of term extension involved when withrawing deposited money to buy a discounted perpetual! Nitpicking, perhaps, but I always get worried when comparisons of this sort are made … there are many retail investors who will figure that if 20% exposure is good, then 40% must be better and 100% is best of all!

Hat tip: Financial Webring Forum.

S&P to Time the Markets?

Friday, November 9th, 2007

It’s a short line in a short presentation … but it carries a lot of implications:

First, what can we do differently in the future? Self-reflection is the key. It is now clear that some of the assumptions we made with respect to rating U.S. RMBS backed by subprime mortgages were insufficient to stand up to what actually happened. In addition, some have questioned whether our detailed analytical processes led us to wait too long to react to data that suggested a deviation from the expected trends. So we are focusing on getting in place the data, analytics, and processes to enhance our ability to anticipate future trends and process information even more quickly. [emphasis added – JH]

This is a little bit scary. I’ve done a lot of quantitative modelling – my entire professional career has been spent doing quantitative modelling – and I can tell you two things:

  • Quantitative models do not do well when there is a trend change. This is because there is a lot more noise than signal in the market-place; a quant system will pick up the first one, two, three standard deviations as an exception that will revert before it changes the figure it takes as a base.
  • Ain’t nobody can predict a trend change with reproducible accuracy. At best, you can pick up on the stress on the system implied by your data and assign a probability to the idea that it’s a trend change … e.g., when housing prices decline by 2% in a quarter, there might be a 25% chance that it’s a trend change as opposed to a 75% chance that it’s just noise. Which is not to say that estimating the chances of a change in trend is not useful; but which does mean that assigning a lot of weight to the idea that house prices will continue to decline by 2%/quarter over the medium term is quite aggressive

I will have to see how S&P fleshes out this idea – and how much disclosure they make of their future projections as part of the credit rating process.

With respect to projecting trend changes, lets look at one of the more respective organizations in the business – the National Bureau of Economic Research. How well do they do in determining trend changes? As they say:

On November 26, 2001, the committee determined that the peak of economic activity had occurred in March of that year. For a discussion of the committee’s reasoning and the underlying evidence, see http://www.nber.org/cycles/november2001. The March 2001 peak marked the end of the expansion that began in March 1991, an expansion that lasted exactly 10 years and was the longest in the NBER’s chronology. On July 16, 2003, the committee determined that a trough in economic activity occurred in November 2001. The committee’s announcement of the trough is at http://www.nber.org/cycles/july2003. The trough marks the end of the recession that began in March 2001.

So it took the NBER over a year and a half to look at all the data and determine where the bottom was. And S&P – under pressure by thousands of bozos who could have predicted the credit crunch ever-so-much-better, except that nobody asked them to – is going to try and predict the future?

It’s a scary thought – I hope that the implementation of the plans outlined in the S&P presentation is very, very restrained.