BNS.PR.Q Closes Comfortably

June 10th, 2008

Scotiabank has announced:

that it has completed the domestic offering of 14 million, non-cumulative 5-year rate reset preferred shares Series 20 (the “Preferred Shares Series 20”) including the full exercise of the underwriters’ option, at a price of $25.00 per share. The gross proceeds of the offering were $350 million.
The offering was made through a syndicate of investment dealers led by Scotia Capital Inc. Following the successful sale of the initially announced 12 million Preferred Shares Series 20, the syndicate fully exercised the underwriters’ option to purchase an additional 2 million shares. The Preferred Shares Series 20 commence trading on the Toronto Stock Exchange today under the symbol BNS.PR.Q.

The issue traded 629,480 shares today in a range of 24.95-07, closing at 24.98-00, 4×156. The related BNS.PR.P (which resets at +205) closed at 25.41-50, 15×66. It would seem the market it placing a lot of faith in actually seeing those extra thirty-five beeps!

BNS.PR.Q was announced and analyzed on May 27.

BIS Quarterly Review Deprecates ABX Benchmark for SubPrime

June 10th, 2008

As reported by the WSJ, the BIS Quarterly Review deprecated the widespread use of the ABX indices when estimating credit losses on sub-prime.

They make three major points regarding pitfalls in using the ABX:

  • Accounting Treatment – many subprime RMBS are held by investors who do not mark-to-market, resulting in a wide gap between reported writedowns and estimated fair value of losses.
  • Market Coverage – the indices only sample the universe … but this is probably not a big deal, the sample is reasonable.
  • Deal-Level coverage – “Similarly, ABX prices may not be representative because each index series covers only part of the capital structure of the 20 deals included in the index … In particular, tranches referenced by the AAA indices are not the most senior pieces in the capital structure, but those with the longest duration (expected average life) – the so-called “last cash flow bonds”.”

The last point is very important and forms the core of their argument.

This information has been available to non-specialists for some time … I could have sworn I mentioned it specifically on PrefBlog at one point, but can’t find the reference … and at any rate I should have emphasized it myself when discussing the fair value estimates. The best tracing to this information I can give is … in my discussion of the Greenlaw paper, I referenced the comments to Econbrowser’s Mortgage Securitization post, in which I referenced Felix Salmon’s How to test the accuracy of the ABX post, which referenced his prior ABX RIP post, which referenced Alea’s ABX Extra piece, which … highlighted the information.

The guts of the BIS argument are given only in the notes:

Incomplete coverage at the deal level further reduces effective market coverage: typical subprime MBS structures have some 15 tranches per deal, of which only five were originally included in the ABX indices. As a result, each series references less than 15% of the underlying deal volume at issuance.

Duration effects at the AAA level are bound to be significant for overall loss estimates as the AAA classes account for the lion’s share of MBS capital structures. Using prices for the newly instituted PENAAA indices, which reference “second to last” AAA bonds, to calculate AAA mark to market losses generates an estimate of $73 billion. This, in turn, translates into an overall valuation loss of $205 billion (ie some 18% below the unadjusted estimate of $250 billion).

I will suggest that even the PENAAA indices will be not very well corellated with actual credit analysis, but these data certainly provide an indication of the value of subordination.

The last review of loss estimates was the discussion of the OECD paper; there is not really enough data in the BIS note to put it on the board as an estimate … but it certainly seems to support the “lowball Bank of England estimate” rather than the “terrifying IMF estimate”!

The main articles – apart from the “Overview” and “Highlights” – in the BIS Review are:

  • International Banking Activity Amidst the Turmoil
  • Managing International Reserves: How Does Diversification Affect Financial Costs?
  • Credit Derivatives and Structured Credit: the Nascent Markets of Asia and the Pacific
  • Asian Banks and the International Interbank Market

Update, 2008-6-11: This post was picked up by iStockAnalyst and attracted a puzzled comment on the Housing Doom blog:

Here’s a technical criticism of the ABX index that was posted yesterday. If you can understand what this guy is complaining about you’re doing better than me.

“BIS Quarterly Review Deprecates ABX Benchmark for SubPrime”, James Hymas, iStockAnalysis, June 10, 2008.

Well, I guess for new readers who have not been assiduously reading my remarks, this post will be a little cryptic!

The gist is: in order to make a sub-prime RMBS with a large AAA component, it must be tranched; for example, the Bear Stearns ABS I use as a model had a total value of USD 395-million, which was divided into seven publicly marketed and three private tranches … payments went first to the USD 314-million senior tranche, then on down the line until the final (public) tranche of USD 4.5-million, initially rated at BBB- and downgraded to B on August 24, 2007 gets paid … if it ever does! I looked at the economics of tranching very early on.

This particular issue is relatively simple, but there are issues with more tranches … as the BIS piece above notes, the average is 15 tranches per deal of which … maybe five? I’m guessing … would be rated AAA.

So you have five AAA tranches that get paid one after the other. Obviously, the first one to be paid is the safest and most likely to meet its committments; the ratings agencies, in their infinite wisdom, determined that tranche #5 was also good enough to warrant an AAA rating. The ten that came after that would be sold to the public with worse ratings and higher yields.

So … the market goes blahooey and all of sudden banks and brokerages, with a need to mark their inventories to market to meet the accounting rules, are stuck with the problem: how to assign a market price to inventory comprised of relatively small issues representing a class of security that simply isn’t trading at all. After discussion with their accountants, they determine that the methodology least likely to get them into trouble is to use the Markit ABX indices as a benchmark. This methodology is also used by third parties (e.g., the OECD, referenced above) to estimate what the total losses for the entire universe of about USD 1.4-trillion might be.

There are a number of problems with this approach. Firstly, the Markit ABX index only rates the worst tranche for each credit rating … the value for the AAA-rated index is based entirely on tranche #5 of our example, even though there are four other tranches rated AAA in this deal, each of which (this is the important bit) are safer than the chosen tranche by definition.

Secondly, the ABX index is based on Credit Default Swaps, a market that is now basically dysfunctional.

Thirdly, we are interesting times; getting out of sub-prime paper is currently a “crowded trade” and the cash market itself is dysfunctional (although it is starting to show signs of life). The market price of the securities does not have a lot to do with the present value of its expected cash flows.

All these factors mean that estimates of sub-prime losses that mark-to-market off the Markit ABX index are (a) highly imprecise, and (b) greatly overstated.

The new PENAAA index referred to above is based on the penultimate tranche in the AAA tranche – tranche #4 in our 15-tranche mini example. A quality spread is quite evident; using the value of this index to estimate market values over the universe results in BIS computing an estimate for losses that is much, much lower than the initial estimate.

June 9, 2008

June 9th, 2008

Timothy Geithner of the Federal Reserve Bank of New York has delivered a fine speech, Reducing Systemic Risk in a Dynamic Financial System. He notes:

This afternoon, 17 firms that represent more than 90 percent of credit derivatives trading, meet at the Federal Reserve Bank of New York with their primary U.S. and international supervisors to outline a comprehensive set of changes to the derivatives infrastructure. This agenda includes:

  • the establishment of a central clearing house for credit default swaps,
  • a program to reduce the level of outstanding contracts through bilateral and multilateral netting,
  • the incorporation of a protocol for managing defaults into existing and future creditderivatives contracts, and
  • concrete targets for achieving substantially greater automation of trading and settlement.

Establishment of this clearing-house has been reported on Bloomberg; a later press release from the FRBNY gave further details.

Geithner nails the essential point:

supervision will have to focus more attention on the extent of maturity transformation taking place outside the banking system.

And goes further, to make the point I have been making for a while:

I do not believe it would be desirable or feasible to extend capital requirements to institutions such as hedge funds or private equity firms. But supervision has to ensure that counterparty-credit risk management in the regulated institutions contains the level of overall exposure of the regulated to the unregulated. Prudent counterparty risk management, in turn, will work to limit the risk of a rise in overall leverage outside the regulated institutions that could threaten the stability of the financial system.

To the extent that this reflects Official Thinking, I’m very relieved. We should not be concerned that Joe’s Hot Dog Stand and Mortgages is levered 40:1 … we should only be concerned with the amount of counterparty risk taken by the banks who lend to him.

I’m not entirely certain as to what I should make of the section:

The most fundamental reform that is necessary is for all institutions that play a central role in money and funding markets—including the major globally active banks and investment banks—to operate under a unified framework that provides a stronger form of consolidated supervision, with appropriate requirements for capital and liquidity.

To complement this, we need to put in place a stronger framework of oversight authority over the critical parts of the payments system, not just the centralized payments, clearing and settlements systems but the infrastructure that underpins the decentralized over-the-counter markets.

The Federal Reserve should play a central role in this framework, working closely with supervisors here and in other countries. At present the Federal Reserve has broad responsibility for financial stability not matched by direct authority, and the consequences of the actions we have taken in this crisis make it more important that we close that gap.

I will assert that brokerages are fundamentally different from banks and should have not just different rules, but a different supervisor … in the US, the SEC is doing as well as any other regulator and should not lose any authority. I worry about how much the Bear Stearns fiasco will be used a lever in a silly bureaucratic turf fight that might, ultimately, lead to a blurring of the distinction between the two components of the financial system. He does mention Bear Stearns, by the way, but doesn’t add anything new.

Carnage on the preferred share market today, with the TXPR Index down 0.61% and Claymore’s CPD about the same. Sunlife, comprising a little over 6% of CPD, got hammered.

Note that these indices are experimental; the absolute and relative daily values are expected to change in the final version. In this version, index values are based at 1,000.0 on 2006-6-30
Index Mean Current Yield (at bid) Mean YTW Mean Average Trading Value Mean Mod Dur (YTW) Issues Day’s Perf. Index Value
Ratchet 4.16% 4.17% 54,155 17.1 1 -0.0787% 1,113.3
Fixed-Floater 4.92% 4.67% 61,982 16.03 7 -0.4778% 1,017.0
Floater 4.04% 4.09% 61,693 17.15 2 -0.0432% 936.1
Op. Retract 4.82% 1.93% 86,852 2.66 15 -0.0011% 1,058.6
Split-Share 5.27% 5.49% 70,186 4.19 15 -0.2649% 1,053.5
Interest Bearing 6.06% 6.04% 48,832 3.80 3 +0.5060% 1,123.8
Perpetual-Premium 5.85% 5.78% 405,175 9.18 13 -0.1063% 1,024.0
Perpetual-Discount 5.70% 5.76% 224,561 14.23 59 -0.3876% 919.3
Major Price Changes
Issue Index Change Notes
BNA.PR.B SplitShare -2.5487% Asset coverage of just under 3.6:1 as of May 30 according to the company. Now with a pre-tax bid-YTW of 7.76% based on a bid of 21.03 and a hardMaturity 2016-3-25 at 25.00. Compare with BNA.PR.A (6.10% to 2010-9-30) and BNA.PR.C (6.76% to 2019-1-10).
GWO.PR.G PerpetualDiscount -2.4861% Now with a pre-tax bid-YTW of 5.72% based on a bid of 22.75 and a limitMaturity.
SLF.PR.D PerpetualDiscount -2.1543% Now with a pre-tax bid-YTW of 5.71% based on a bid of 19.53 and a limitMaturity.
PWF.PR.L PerpetualDiscount -1.7544% Now with a pre-tax bid-YTW of 5.77% based on a bid of 22.40 and a limitMaturity.
POW.PR.D PerpetualDiscount -1.7117% Now with a pre-tax bid-YTW of 5.83% based on a bid of 21.82 and a limitMaturity.
WFS.PR.A SplitShare -1.6915% Asset coverage of just under 1.8:1 as of May 31, according to the company. Now with a pre-tax bid-YTW of 6.10% based on a bid of 9.88 and a hardMaturity 2011-6-30 at 10.00.
IAG.PR.A PerpetualDiscount -1.6585% Now with a pre-tax bid-YTW of 5.72% based on a bid of 20.16 and a limitMaturity.
GWO.PR.H PerpetualDiscount -1.6144% Now with a pre-tax bid-YTW of 5.54% based on a bid of 21.94 and a limitMaturity.
SLF.PR.B PerpetualDiscount -1.2617% Now with a pre-tax bid-YTW of 5.70% based on a bid of 21.13 and a limitMaturity.
SLF.PR.E PerpetualDiscount -1.2370% Now with a pre-tax bid-YTW of 5.65% based on a bid of 19.96 and a limitMaturity.
BCE.PR.R FixFloat -1.0870%  
IGM.PR.A OpRet -1.0401% Now with a pre-tax bid-YTW of 3.05% based on a bid of 26.64 and a call 2009-7-30 at 26.00.
PWF.PR.F PerpetualDiscount -1.0235% Now with a pre-tax bid-YTW of 5.72% based on a bid of 23.21 and a limitMaturity.
BSD.PR.A InterestBearing +1.5353% Now with a pre-tax bid-YTW of 6.18% (mostly as interest) based on a bid of 9.92 and a hardMaturity 2015-3-31 at 10.00.
Volume Highlights
Issue Index Volume Notes
CM.PR.I PerpetualDiscount 670,210 Nesbitt crossed 50,000 at 19.90. Now with a pre-tax bid-YTW of 6.00% based on a bid of 19.89 and a limitMaturity.
BNS.PR.K PerpetualDiscount 147,996 “Anonymous” bought 10,000 from Raymond James at 22.04, then another 20,000 at 22.02 … not necessarily the same anonymous! Now with a pre-tax bid-YTW of 5.51% based on a bid of 22.08 and a limitMaturity.
FAL.PR.B FixFloat 109,652 TD crossed 109,200 at 24.80.
RY.PR.B PerpetualDiscount 105,135 National Bank crossed 100,000 at 21.10. Now with a pre-tax bid-YTW of 5.64% based on a bid of 21.06 and a limitMaturity.
TD.PR.O PerpetualDiscount 82,325 Nesbitt bought 18,000 from anonymous in three tranches at 22.36 … not necessarily the same anonymous … and National Bank crossed 50,000 at the same price. Now with a pre-tax bid-YTW of 5.50% based on a bid of 22.33 and a limitMaturity.

There were twenty other index-included $25-pv-equivalent issues trading over 10,000 shares today.

OSFI Drafts Advisory to Create New Tier 1 Capital

June 9th, 2008

The Office of the Superintendent of Financial Institutions has released a Draft Advisory envisaging a new type of Tier 1 Capital that may be considered to be slightly senior to preferred shares.

Key provisions under this advisory are:

  • innovative instruments issued to the public can now include securities which mature in 99 years. These, however, will be subject to straight-line amortization for regulatory capital purposes beginning 10 years prior to maturity.
  • An innovative instrument is now permitted to be “share cumulative” where deferred cash coupons on the inter-company instrument issued by the FRE to the SPV become payable in directly issued perpetual preferred shares of the FRE, subject to the following requirements:
    • Coupons on the innovative instrument can be deferred at any time, at the FRE management’s complete discretion, with no limit on the duration of the deferral, apart
      from the maturity of the instrument.

    • The preferred shares issued by the FRE to the SPV under the inter-company instrument may only be distributed by the SPV to the holders of the innovative instrument to pay for deferred coupons once the cash payments on the inter-company instrument are resumed.
    • The number of preferred shares to be distributed by the FRE to the SPV to effect payment of deferred coupons must be calculated by dividing the deferred cash coupon amount by the face amount of the preferred shares.
    • The credit spread imbedded in the dividend rate of the preferred shares must be determined based on market rates prevailing at the outset – i.e. upon original issuance of the innovative instrument.

Tier 1 Capital with a cumulative coupon? That’s innovative indeed!

The following eMail has been sent to OSFI:

I read the captioned notice with great interest.

i) Are any background papers available which would shed some light on the somewhat startling intention to allow cumulative payments on these new instruments?

ii) Innovative Tier 1 Capital has historically been marketted to the public as having an effective maturity equal to the step-up date. This creates a certain amount of reputational risk for the issuing bank which could lead to riskier decisions being made regarding refinancing at step-up; or, at the very least, to a presumed penalty rate being paid on capital following the step-up date at a time when it may be assumed the bank is experiencing difficulties. Why does the draft advisory not prohibit step-ups for these instruments? Why is there no allowance for partial amortization for regulatory capital purposes prior to any step-up?

iii) Will comment letters and OSFI discussion be published?

Ellen Roseman of the Toronto Star on Preferred Shares

June 8th, 2008

Ellen Roseman, who writes the “Money 911” column for the Toronto Star, devoted a piece to preferred shares today: Preferred Shares are Ideal for the Risk-Averse

It’s a good introduction – considering she only had 600-words! I was interviewed and mentioned in the article:

So, why invest in preferred shares? I asked James Hymas of Hymas Investment Management Inc. in Toronto, who runs a fund for high-net-worth investors, publishes a newsletter about preferred shares and has a website, www.prefblog.com.

“The common share investor is taking the first loss,” he says. “Common shares provide a higher expected long-term return, but it could be a bumpier flight.”

He points to U.S. banks, hit hard by the credit crunch. News reports indicate that up to half of them may be cutting their dividends this year.

Preferred shares have a somewhat more secure dividend than common shares. Moreover, they trade in a tight price range, generally with no big gains or losses.

Suppose you have $10,000 or more to invest in preferred shares. Hymas recommends buying at least three issues with a top-quality credit rating, such as Pfd-1 from Dominion Bond Rating Service.

“If you can afford five to six issues, you can get a Pfd-2. And with 10 different issues, I wouldn’t mind too much if one was Pfd-3.”

You don’t have much choice when it comes to sectors. A large proportion of preferred shares are from banks and insurance companies.

“With Canadian preferred shares, you have to resign yourself to a high exposure to financials,” he says. “You can make allowances for that in the rest of your portfolio.”

I discussed US Banks cutting their common dividends in FDIC Releases 1Q08 Report on US Banks.

The column quotes me as saying “If you can afford five to six issues, you can get a Pfd-2” … I shouldn’t have said “a”, I should have said “some”. I have published an article on Portfolio Construction which fleshes out my thoughts on this matter.

It was very kind of Ms. Roseman to mention my product offerings! The fund mentioned is Malachite Aggressive Preferred Fund and the newsletter is PrefLetter.

Update: The column has attracted some comment on Financial Webring Forum, where in response to a question about the ‘irritant of issuer calls’ I posted the following:

There’s some data in my article A Call, too, Harms – but note that data for that article reflect a period when, after a long period of declining long term rates, most perpetuals were trading above par … something that is not currently the case.

Many investors – some of them professional – buy preferreds on the basis of current yield, ignoring potential calls. This is not a strategy I recommend to my friends. I’ve summarized data on potential calls at prefInfo.com.

In times where call-dates become important, they cannot be escaped by buying a passive fund, as I point out in my article Closed End Preferred Funds: Effects of Calls

June 6, 2008

June 6th, 2008

The biggest financial news in recent days is the Moodys / S&P downgrade of two monolines, MBIA and Ambac. Accrued Interest opines that this is long overdue as far as the current balance sheet goes, but may be related to their low share prices and general unpopularity making it hard for them to raise capital. Naked Capitalism passes along some speculation that the ratings cuts will cause massive write-offs at the brokerages.

The two monolines insure more than $1-trillion of third party debt; competition is poised to take advantage … and the politicians are grandstanding:

The companies also face competition from billionaire Warren Buffett’s Berkshire Hathaway Inc., the largest shareholder in credit-rating company Moody’s Corp. Buffett started a new bond insurer in December and is charging more than MBIA and Ambac to guarantee payment on municipal debt while avoiding the CDOs and other securities that jeopardized their credit ratings.

Macquarie Group Ltd., Australia’s biggest securities firm, also plans to form a U.S. bond-insurance company. The Sydney- based company has been in talks with the New York State Insurance Department since April to provide bond insurance in the state, Superintendent Eric Dinallo said in an e-mailed statement today.

California Treasurer Bill Lockyer and Connecticut Attorney General Richard Blumenthal are among officials seeking a change in how Moody’s and S&P rate municipal bonds. States and local governments say they were forced to buy now worthless bond insurance because Moody’s and S&P “knowingly and systematically” ranked municipal issues lower than they should have. Reform may negate the need for bond insurance.

In an announcement late today, S&P is lowering the boom on monolines:

Standard & Poor’s took negative ratings actions on the bond insurance businesses of CIFG Guaranty, Security Capital Assurance Ltd. and FGIC Corp. as the companies struggle to address potential losses on securities they guaranteed.

CIFG, stripped of its AAA rating in March, was downgraded further today to A-, while SCA’s XL Capital Assurance Inc. and XL Financial Assurance Ltd. had their financial strength ratings cut to BBB-, the lowest investment-grade level. FGIC, owned by Blackstone Group LP and PMI Group Inc., had the BB ratings on its bond insurer placed under review for a possible downgrade.

The other major story of the past week has been Lehman’s search for capital:

Lehman, the fourth-largest U.S. securities firm, has already sold bonds and preferred shares to generate $8 billion in capital since February. Chief Executive Officer Richard Fuld is trying to reduce leverage, the firm’s ratio of assets to equity, to help offset a decline in the value of debt securities. Concern that Bear Stearns Cos. faced a cash shortage pushed the firm to the brink of bankruptcy in March.

Well, they have to raise capital and otherwise delever their balance sheet. In this environment, fundamentals don’t really matter a lot. Leverage doesn’t matter, asset quality doesn’t matter, profitability doesn’t matter … you just don’t want to be the weakest broker on the Street. Look what happened to Bear Stearns! And if Bear had been unable to cut some kind of deal on the fateful Sunday evening and been forced into Chapter 11 on Monday morning, the run on Lehman would have started instantly.

Naked Capitalism is decidedly unimpressed with Lehman’s disclosure.

Bloomberg has an amusing piece on the value of sell-side analysis:

Investors who followed the advice of analysts who say when to buy and sell shares of brokerage firms and banks lost 17 percent in the past year, twice the decline of the Standard & Poor’s 500 Index.

Buying shares on the advice of Merrill Lynch & Co.’s Guy Moszkowski, the top-ranked brokerage analyst in Institutional Investor’s annual survey, cost investors 17 percent, according to data compiled by Bloomberg. Deutsche Bank AG analyst Michael Mayo’s counsel to purchase New York-based Lehman Brothers Holdings Inc. lost 59 percent. Citigroup Inc.’s Prashant Bhatia still rates Merrill “buy” after its 56 percent retreat from a January 2007 record.

Granted, it’s only one year, but I do like to see even the slightest hint that the media is actually following up on the recommendations they report so breathlessly.

Naked Capitalism reports on the Lacker speech I mentioned yesterday, with a greater emphasis on the Fed’s independence:

But there has been another thread mixed in with this: resentment at the Fed salvaging the banking industry, with contingent and real costs, in the form of higher inflation, per Alford’s and Leijonhufvud’s analysis. Now that many of those actions may indeed have been the best among a set of bad choices (although I suspect economic historians will conclude the Fed cut rates too far too fast). However, the big issue is that they involved consequences of such magnitude that they should not have been left to the Fed. I was amazed, and was not alone, when Congress did not dress down the Fed in its hearings on the Bear rescue for the central bank’s unauthorized encroachment into fiscal action (ie., if any of the $29 billion in liabilities assumed by the Fed in that rescue comes a cropper, the cost comes from the public purse). So the frustration isn’t merely about outcomes, it’s about process, about the sense of disenfranchisement. And that will only get worse as this crisis grinds along.

The word “resentment” is critical and may have an effect on shaping policy in the future. It seems to me that, by and large, Americans are big fans of punishment:

One in thirty-two US adults are now under some form of correctional supervision. Although Americans only constitute 5 percent of the world’s population, one-quarter of the entire world’s inmates are contained in our jails and prisons, something that baffles other democratic societies that have typically used prisons as a measure of last resort, especially for nonviolent offenders.

But mass incarceration in America remains a nonissue, largely because of a lack of any serious or effective discourse on the part of our political leaders. At most, election season brings out the kinds of get-tough-on-crime platforms that have already given us misguided Three Strikes and mandatory-minimum sentencing laws.

Throughout the credit crunch, the worry about effects on the economy – and the personal effects on the worrier – has been leavened by what can only be described as joy that traders, bankers, big investors and over-leveraged real-estate purchasers are getting wiped out. Part of America’s inheritance from the Puritans is a deep-seated belief that those who behave improperly should be punished, and much of the criticism of the Fed’s actions with respect to Bear Stearns feeds itself from this source.

Don’t get me wrong, here! I’m not proposing that mummy-government give everything a kiss and make it better! In the end, I am opposed to government infusions of capital – but I don’t take any joy in seeing people get wiped out because they stayed at the party for five minutes too long; nor do I approach the situation with the idea that since things have gone wrong, there must be a villain somewhere. Violent mood swings from euphoria to gloom may be undesirable in individuals, but are a normal and valuable element of financial markets.

Other elements of the “Fed Independence” debate were most recently mentioned on PrefBlog on May 26 and May 13. In times like this, we do not need grandstanding politicians getting in the way. Hire smart technocrats, pay them well, give them discretion – and periodically review the boundaries of that discretion.

Nicholas Bloom of Stanford has an interesting piece on VoxEU today, Will the Credit Crunch Lead to Recession?. His answer is yes:

So what is stopping Chairman Bernanke from acting to counteract this rise in uncertainty and forestall the recession? Well, as Bernanke also knows, the same forces of uncertainty that lead to a recession also render policy-makers relatively powerless to prevent it.

When uncertainty is high, firms become cautious, so they react much less readily to monetary and fiscal policy shocks. According to research on UK firms, which I conducted with two colleagues, uncertainty shocks typically reduce the responsiveness of firms by more than half, leaving monetary and fiscal policy-makers relatively powerless (Bloom et al. 2007).

So the current situation is a perfect storm – a huge surge in uncertainty that is not only generating a rapid slowdown in activity but also limiting the effectiveness of standard monetary and fiscal policy to prevent this.

Policy-makers are doing the best they can – making huge cuts in interest rates, dishing out tax rebates and aggressively pouring liquidity into the financial markets. But will this be enough? History suggests not. A recession looks likely.

It all makes sense, but I’m not sure about the direct equivalence of stock market volatility and delays in direct investment. Bloom states:

In recent research, I show that even the temporary surges in uncertainty that followed previous shocks had very destructive effects. The average of the 16 shocks plotted in Figure 1 (before the credit crunch) cut US GDP by two percent over the next six months (Bloom 2007).

One of his cited papers is on-line: The Impact of Uncertainty Shocks: Firm Level Estimation and a 9/11 Simulation, but such is my laziness that I haven’t read it yet.

I will admit that on first glance, the post on WSJ titled Bubble Proposal: Let Banks Pay for Their Own Bailouts looked like the silliest thing I’ve ever heard:

Borrowing from the world of carbon-emission trading, Ian Harnett, managing director of Absolute Strategy Research Ltd., suggests that governments set up a market in which banks buy the rights to expand their assets. The money banks pay would then be set aside by governments as a form of insurance. So, if the banks get it wrong, their money would be used to bail them, or the market, out, said Mr. Harnett, musing in London Thursday.

“Banks can buy the right to increase their asset base beyond what the regulator thinks is prudent. If you tax them upfront, you would force them to consider the expansion of their lending,” he said.

See the comments on the WSJ blog for examples supporting my “punishment” thesis!

Sober second thoughts about the idea’s practicality, however, convinced me that (to some degree) the proposal is already in effect – and there’s even a General Guidance for Developing Differential Premium Systems available from the International Association of Deposit Insurers c/o Bank for International Settlements:

Deposit insurers collecting premiums from member financial institutions which accept deposits from the public (hereafter referred to as “banks”) usually choose between adopting a flat-rate premium or a system that seeks to differentiate premiums on the basis of individual-bank risk profiles. Although flat-rate premium systems have the advantage of being relatively easy to understand and administer, they do not take into account the level of risk that a bank poses to the deposit insurance system and can be perceived as unfair in that the same premium rate is charged to all banks regardless of their risk profile. Primarily for these reasons, differential premium systems have become increasingly adopted in recent years.

Differential premia are in effect at the FDIC:

the FDIC Board adopted a new risk-based deposit insurance premium system effective January 2007. The assessment approach adopted relies on an institution’s supervisory ratings, financial ratios, and long-term debt issuer ratings. For most institutions, supervisory ratings will be combined with financial ratios to determine assessment rates. For large institutions (over $10 billion in assets) with long-term debt issuer ratings, assessment rates will be based on supervisory ratings combined with debt ratings.

The adopted rule allows for some pricing discretion by the FDIC with respect to certain large institutions, recognizing that proper assessment of the risk of large complex institutions cannot always be adequately measured using a formulaic approach. In such cases, other market information, as well as additional supervisory and financial information, will be used to determine whether a limited adjustment to an institution’s assessment rate is warranted. All of this additional information will help ensure that institutions with similar risks pay similar rates.

The CDIC also charges differential premia:

The CDIC Differential Premiums By-law (“By-law”) came into effect for the premium year beginning May 1, 1999. The By-law undergoes regular reviews (including a 2004 comprehensive review) and has been amended on numerous occasions following consultation with member institutions, their associations and regulators. The By-law and its amendments are provided under the Tabs titled “Differential Premiums By-law” and “Amendments to Differential Premiums By-law”, respectively.

Whether the differential premia are, in fact, differential enough is another matter entirely – and there’s not much by way of disclosure to allow for an informed judgement on the matter. But … the framework is in place.

Long corporates now yield something like 6.05%, so the 5.73% dividend on PerpetualDiscounts, x1.4 Equivalency Factor, equals 8.02% interest equivalent, implies that the preferred spread continues to hang in at around 200bp.

Good volume for RY issues today, but no trend to the prices. The yields relative to the discount-to-call-price don’t make a lot of sense to me either:

RY Issues, Close 2008-6-6
Issue Dividend Quote YTW at bid
RY.PR.F 1.1125 19.95-99 5.63%
RY.PR.D 1.1250 20.05-14 5.66%
RY.PR.G 1.1250 20.05-13 5.66%
RY.PR.A 1.1125 20.11-26 5.58%
RY.PR.E 1.1250 20.12-17 5.64%
RY.PR.C 1.1500 20.40-50 5.69%
RY.PR.B 1.1750 21.11-18 5.62%
RY.PR.W 1.2250 22.36-49 5.52%
RY.PR.H 1.4125 25.05-12 5.71%

If you accept my estimate in my article about convexity which stresses the asymmetry of the risk/reward potential for issues trading near(er) par, you will understand my confusion … RY.PR.H and RY.PR.W look quite expensive! At least … they do relative to their deeper discount siblings, which have the same credit risk, but offer the potential for capital gains that won’t be quickly called away should interest rates decline. But such is life in the preferred share market.

Note that these indices are experimental; the absolute and relative daily values are expected to change in the final version. In this version, index values are based at 1,000.0 on 2006-6-30
Index Mean Current Yield (at bid) Mean YTW Mean Average Trading Value Mean Mod Dur (YTW) Issues Day’s Perf. Index Value
Ratchet 4.17% 3.86% 54,830 0.08 1 +0.0394% 1,114.1
Fixed-Floater 4.90% 4.65% 61,026 16.06 7 +0.0706% 1,021.9
Floater 4.03% 4.08% 61,260 17.16 2 +0.3899% 936.5
Op. Retract 4.82% 1.98% 87,082 2.67 15 -0.0076% 1,058.6
Split-Share 5.26% 5.38% 70,870 4.20 15 -0.0577% 1,056.3
Interest Bearing 6.09% 6.10% 48,928 3.80 3 -0.0664% 1,118.2
Perpetual-Premium 5.84% 5.74% 409,236 8.40 13 +0.0580% 1,025.0
Perpetual-Discount 5.68% 5.73% 223,874 14.27 59 -0.0450% 922.9
Major Price Changes
Issue Index Change Notes
BNA.PR.C SplitShare -1.6738% Asset coverage of just under 3.6:1 as of May 30 according to the company. Now with a pre-tax bid-YTW of 6.76% based on a bid of 20.56 and a hardMaturity 2019-1-10 at 25.00. Compare with BNA.PR.A (5.86% to 2010-9-30) and BNA.PR.B (7.33% to 2016-3-25).
MFC.PR.C PerpetualDiscount -1.1434% Now with a pre-tax bid-YTW of 5.44% based on a bid of 20.75 and a limitMaturity.
Volume Highlights
Issue Index Volume Notes
BNS.PR.K PerpetualDiscount 183,300 National Bank crossed 50,000 at 22.15 for delayed delivery. Now with a pre-tax bid-YTW of 5.50% based on a bid of 22.10 and a limitMaturity.
RY.PR.B PerpetualDiscount 109,005 “Anonymous” crossed 100,000 at 21.10 – maybe the same “anonymous”, maybe not. If not, then it wasn’t a cross! Now with a pre-tax bid-YTW of 5.62% based on a bid of 21.11 and a limitMaturity.
RY.PR.A PerpetualDiscount 41,990 Now with a pre-tax bid-YTW of 5.58% based on a bid of 20.11 and a limitMaturity.
RY.PR.W PerpetualDiscount 27,695 Now with a pre-tax bid-YTW of 5.52% based on a bid of 22.36 and a limitMaturity.
RY.PR.C PerpetualDiscount 24,550 Now with a pre-tax bid-YTW of 5.69% based on a bid of 20.40 and a limitMaturity.

There were twenty-one other index-included $25-pv-equivalent issues trading over 10,000 shares today.

HPF.PR.A & HPF.PR.B : Conference Call!

June 6th, 2008

Lawrence Asset Management continues to break new ground in the field of split-share corporation management.

Assiduous Readers will recall my post regarding the Annual Retraction Feature for these shares; the “equity” (ha-ha) shares are guaranteed a price well in excess of their value, while the “preferred” (ha-ha) shares will get a price that may be well below their NAV.

They have now announced:

it intends to hold a conference call at 10 a.m. EST on June 10, 2008, to discuss the outlook for HI PREFS (TSX:HPF.pr.a, HPF.pr.b).

Shareholders and Investment Advisors are invited to join the conference call.

The details are as follows:
Date: Tuesday, June 10, 2008
Time: 10:00 am EST
Dial in: 416-695-7806 / 1-888-789-9572
Passcode: 3267826
For More Information Contact:
Investor Relations
Catherine Stretch
416-362-6283
info@lawvest.com

I will be the first to admit that I don’t know everything there is to know about the financial world – but I can’t remember seeing any such announcement for a split-share corporation before, let alone one for a conference call with such a vague agenda.

Canadian Non-Bank ABCP: Almost Beginning Cash Payments!

June 6th, 2008

The Globe and Mail reports:

An Ontario judge has approved the plan to restructure $32-billion of asset-backed commercial paper, moving individual and corporate investors closer to recovering troubled investments that have been frozen since last August.

Mr. Justice Colin Campbell of the Superior Court of Ontario issued reasons for his decision to approve a plan that was challenged by a number of individual and corporate investors.

The plan grants a sweeping immunity to every bank, rating agency and other major funds that helped nurture the market. The immunity will shield the ABCP players from future lawsuits related to the investment crisis. Not protected from this immunity are brokerages or dealers that may have fraudulently sold the troubled notes to investors.

It is widely expected that some investors will seek to appeal the judge’s decision, meaning that investors may have to wait at least another month to receive money or new securities that will be issued under the plan.

The Financial Post notes:

The plan calls for the ABCP, which seized up when the credit crunch hit nearly 10 months ago, to be converted to long-term notes.

It will be most interesting to see what disclosures are made on the notes and what price levels become established for them. PrefBlog’s last post in this dreary saga was Almost, but Campbell Procrastinates.

June 5, 2008

June 5th, 2008

Finance Geeks will be pleased to learn that I have finished my post Expected Losses and the Assets to Capital Multiple. All other will simply let their eyes glaze over and look forward to a resumption of PrefBlog’s regular schedule of news and snarky comments.

Bear Stearns controversy is reaching new heights:

Richmond Federal Reserve Bank President Jeffrey Lacker, challenging Chairman Ben S. Bernanke’s unprecedented actions to stem a financial panic, warned that lending to securities firms raises the risk of future tumult.

“The danger is that the effect of the recent credit extension on the incentives of financial-market participants might induce greater risk taking,” Lacker said in a speech to the European Economics and Financial Centre in London. That “in turn could give rise to more frequent crises,” he said.

Bernanke and New York Fed President Timothy Geithner have defended the central bank’s extraordinary moves as preventing a cascading financial panic. A growing group of Fed bank presidents, who are charged with direct supervision of financial institutions, are saying limits now need to be drawn around the Fed loan facilities.

If investors anticipate an official intervention to limit losses in “situations of financial stress,” firms will be less likely to take “costly” measures to protect themselves, Lacker said.

Lacker in his remarks distinguished between “fundamental” runs on financial institutions where creditors have good economic reasons to question their investments, and “non-fundamental” runs typified by panics.

Types of Runs

He said a case can be made for intervention to stem disorderly non-fundamental runs. He doesn’t see a case for action when a crisis is unavoidable based on a deteriorating credit or business plan. “Instances of run-like behavior since last summer appear to be attributable to real fundamental causes,” Lacker said in his speech.

In the case of Bear Stearns, Lacker said in the interview that it’s hard to tell whether the New York-based firm’s crisis was due to fundamental reasons or a creditor panic.

In Lacker’s actual speech he said:

Researchers have found it useful to distinguish between what I’ll call “fundamental” and “non-fundamental” runs. Non-fundamental runs are of the self-fulfilling variety; if all depositors who do not need their money right away believe that other such depositors will not withdraw their money, then no run occurs. In another potential equilibrium, the belief that other patient depositors will withdraw nonetheless induces all patient depositors to withdraw, thus confirming their beliefs. Fundamental runs occur when people seek to remove their money from an intermediary because they have information that makes them mark-down their valuation of the intermediary’s assets; waiting is not a reasonable option (that is, not an equilibrium). This distinction is important because the two types of runs have very different policy implications. Preventing a non-fundamental run avoids the cost of unnecessarily early asset liquidation, and in some models can rationalize government or central bank intervention. In contrast, in the case of runs driven by fundamentals, the liquidation inefficiencies are largely unavoidable and government support interferes with market discipline and distorts market prices.

However, in most instances of runs that we have observed — for example, the wave of U.S. bank runs in the Great Depression — careful analysis has shown that banks that experienced runs tended to be in observably worse condition than those that did not.3 That is, there usually appears to be some fundamental impetus behind a run.

… significant concerns were circulating publicly regarding mortgage-related assets on Bear Stearns’ balance sheet, making money market counterparties (short-term investors) reluctant to continue dealing with the firm.

It’s a good speech, worthy of reading in full. I will certainly agree that institutions that experience runs are observably worse than ones that do not – the markets are not wholly irrational! However, you don’t need to watch the markets for very long before you conclude that markets are excitable and will make mountains out of molehills at every opportunity.

I think we’re now in the “political football” of Bear Stearns discussion and that we’ll remain there for quite some time … at least until the new president, whoever he is, makes a policy decision and attempts to sell it. It looks to me – from the careful avoidance of any mention of the SEC in any of the Fed representatives’ discussion of the Bear Stearns affair – that the Fed wants to take over supervisory authority of the investment banks. By not mentioning SEC supervision – and what I would call the certainty that Bernanke called Cox at some point during the critical weekend and asked ‘Is it solvent?’ – the Fed’s turf-fighters will create the impression that there’s nobody minding the store at all. It also seems to me that the SEC is constrained from defending its turf due to fear of the disingenuous observation ‘But BSC was going BK!’

We can only hope that – whoever the actual supervisor ends up being – the rules continue to recognize a distinction between banks and investment dealers. Layers, that’s what we need, layers! Banks – safe! Investment Banks – risky! Hedge Funds – Wild!

Added: I came under a certain amount of eerily familiar sounding criticism in the comments to Accrued Interest’s Bailouts, Wall Street, and the Bad Motivator for daring to suggest that Bear Stearns was probably solvent at the time of its demise. It’s not a particularly strong addition to my argument, but I will suggest that Bernanke is far too rigorous a central banker to bail out an insolvent institution. See, for example, US Bank Panics in the Great Depression, with particular attention to the references in the last paragraph of the conclusion. Also, see The Discount Window: Good or Bad? for some of the current thinking.

A poor day in the markets as prices declined with a decline in volume to average levels.

Note that these indices are experimental; the absolute and relative daily values are expected to change in the final version. In this version, index values are based at 1,000.0 on 2006-6-30
Index Mean Current Yield (at bid) Mean YTW Mean Average Trading Value Mean Mod Dur (YTW) Issues Day’s Perf. Index Value
Ratchet 4.19% 4.20% 57,067 17.0 1 +0.0394% 1,113.7
Fixed-Floater 4.90% 4.67% 62,778 16.06 7 -0.6494% 1,021.1
Floater 4.05% 4.10% 62,707 17.14 2 +0.1475% 932.9
Op. Retract 4.82% 1.81% 87,357 2.67 15 +0.1347% 1,058.6
Split-Share 5.26% 5.39% 71,765 4.21 15 -0.0467% 1,056.9
Interest Bearing 6.09% 6.08% 49,777 3.80 3 +0.0669% 1,118.9
Perpetual-Premium 5.84% 5.76% 419,444 8.29 13 -0.1846% 1,024.5
Perpetual-Discount 5.68% 5.73% 223,941 14.07 59 -0.2018% 923.3
Major Price Changes
Issue Index Change Notes
BCE.PR.G FixFloat -1.9780%  
CIU.PR.A PerpetualDiscount -1.4493% Now with a pre-tax bid-YTW of 5.68% based on a bid of 20.40 and a limitMaturity.
GWO.PR.I PerpetualDiscount -1.1933% Now with a pre-tax bid-YTW of 5.45% based on a bid of 20.70 and a limitMaturity.
RY.PR.A PerpetualDiscount -1.1724% Now with a pre-tax bid-YTW of 5.55% based on a bid of 20.23 and a limitMaturity.
BCE.PR.A FixFloat -1.0526%  
Volume Highlights
Issue Index Volume Notes
TD.PR.O PerpetualDiscount 286,200 Now with a pre-tax bid-YTW of 5.49% based on a bid of 22.35 and a limitMaturity.
TD.PR.R PerpetualPremium 127,200 Now with a pre-tax bid-YTW of 5.67% based on a bid of 25.21 and a limitMaturity.
BMO.PR.L PerpetualPremium 62,140 Now with a pre-tax bid-YTW of 5.88% based on a bid of 25.10 and a limitMaturity.
BMO.PR.J PerpetualDiscount 58,350 Now with a pre-tax bid-YTW of 5.64% based on a bid of 20.11 and a limitMaturity.
GWO.PR.I PerpetualDiscount 56,205 Now with a pre-tax bid-YTW of 5.45% based on a bid of 20.70 and a limitMaturity.

There were sixteen other index-included $25-pv-equivalent issues trading over 10,000 shares today.

Expected Losses and the Assets to Capital Multiple

June 5th, 2008

My introductory piece on this topic was Bank Regulation: The Assets to Capital Multiple and later noted that the RY : Assets-to-Capital Multiple of 22.05 for 1Q08 was in excess of the usual guideline and in the 20-23 range where prior permission must be sought from OSFI.

When reviewing the RY Capitalization: 2Q08 I found the following note in their Supplementary Package:

Effective Q2/08, the OSFI amended the treatment of the general allowance in the calculation of the Basel II Assets-to-capital multiple. Comparative ratios have not been revised.

… and at the OSFI website I find the following Advisory regarding Temporary Adjustments to the Assets to Capital Multiple (ACM) for IRB Institutions and an accompanying letter. The advisory states:

This Advisory, which applies to banks, federally regulated trust and loan companies and bank holding companies incorporated or formed under Part XV of the Bank Act, complements the guidance contained in the Capital Adequacy Requirements (CAR) Guideline A-1, November 2007.

The CAR Guideline A-1 sets out capital adequacy requirements, including an asset to capital multiple (ACM) test. Upon the adoption of the Basel II framework, the ACM calculation changed for institutions using an Internal Ratings Based (IRB) approach. The change in the ACM calculation is a direct consequence of changes to the treatment of eligible general allowances used to calculate regulatory capital under the IRB framework and the distinction between expected and unexpected loss. OSFI has decided to reverse this unintended change to the ACM for IRB institutions until a comprehensive review of the ACM has been completed.

Adjustments should be made to both the numerator (total assets) and denominator (total capital) of the ACM in order to reverse the Basel II inclusions in and deductions from capital related to general allowances. This will allow IRB institutions to continue with the Basel I treatment of general allowances for the purposes of calculating the ACM.

Specifically, the amounts reported as Net on- and off-balance sheet assets and Total adjusted net tier 1 and adjusted tier 2 capital on Schedule 1 of the BCAR reporting forms should be adjusted as follows:
• Any deduction related to a shortfall in allowances should be added.
• For IRB institutions that have been given prior approval to include general allowances in capital, the amount of general allowances included under Basel II should be subtracted and the amount of general allowances taken by the institution should be added, up to maximum of 0.875% of Basel I risk-weighted assets.

The OSFI Rules are available for download. Link corrected 2008-6-13. There is also a Guideline to the Capital Adequacy Requirements

The advisory is interesting, particularly in light of the fact that RY is currently in the grey zone. The effect on RY’s capital multiple from this change is approximated as:

Effect on 1Q08 RY ACM of OSFI Advisory
Item 1Q08
As Reported
Change 1Q08
Adjusted
Capital 27,113 471 27,584
Assets 597,833 471 598,304
Multiple 22.05   21.69

It’s a significant change! But what does it mean?

As I noted in the introductory post, the variation in Assets:Risk-Weighted-Assets ratios between banks was enormous; the IMF pointed out that institutions with higher ratios appear to have been punished for this by the equity markets; I drew the conclusion that UBS had been “gaming the system” by leveraging the hell out of assets with a low regulatory risk weight … such as, f’rinstance, AAA subprime paper.

Now, the idea that the Basel II RWA calculations could possibly be gamed – or, even without conscious effort, be simply misleading – should not come as a surprise. Overall capital adequacy under preliminary guidelines was criticized in a 2005 speech by Donald E. Powell, FDIC Chair:

The magnitude of the departure from current U.S. norms of capital adequacy is illustrated by the observation that a bank operating with tier 1 capital between one and two percent of assets could face mandatory closure, and yet, according to Basel II, it has 25 percent more capital than needed to withstand a 999-year loss event.1 For 17 of the 26 organizations to be represented under Basel II as exceeding risk based minimums by 25 percent, when they would face mandatory supervisory sanctions under current U.S. rules if they were to operate at those levels of capital, is evidence that Basel II represents a far lower standard of capital adequacy than we have in the U.S. today.

Further, the FDIC argued that Basel II was incomplete without an ACM cap in its Senate Testimony:

My testimony will argue that the QIS-4 results reinforce the need to revisit Basel II calibrations before risk-based capital floors expire and to maintain the current leverage ratio standards. Leverage requirements are needed for several reasons including:
• Risks such as interest-rate risk for loans held to maturity, liquidity risk, and the potential for large accounting adjustments are not addressed by Basel II.
• The Basel II models and its risk inputs have been, and will be determined subjectively.
• No model can predict the 100 year flood for a bank’s losses with any confidence.
• Markets may allow large safety-net supported banks to operate at the low levels of capital recommended by Basel II, but the regulators have a special responsibility to protect that safety-net.

Some comment is also needed about the possibility of using the allowance for loan and lease losses (ALLL) as a benchmark for evaluating the conservatism of ELs. The aggregate allowance reported by the 26 companies in QIS-4 totaled about $55 billion, and exceeded their aggregate EL, and this comparison might suggest the ELs were not particularly conservative and could be expected to increase. We do not believe this would be a valid inference. The ALLL is determined based on a methodology that measures losses imbedded over a non-specific future time horizon. Basel II ELs, in contrast, are intended to represent expected one-year credit losses. Basel II in effect requires the allowance to exceed the EL (otherwise there is a dollar for dollar capital deduction to make up for any shortfall). More important, the Basel II framework contains no suggestion that if the EL is less than the ALLL, then the EL needs to be increased—on the contrary this situation is encouraged, up to a limit, with tier 2 capital credit.

In the view of the FDIC, the leverage ratio is an effective, straightforward, tangible measure of solvency that is a useful complement to the risk-sensitive, subjective approach of Basel II. The FDIC is pleased that the agencies are in agreement that retention of the leverage ratio as a prudential safeguard is a critical component of a safe and sound regulatory capital framework. The FDIC supports moving forward with Basel II, but only if U.S. capital regulation retains a leverage-based component.

Which is not to say that imposition of an ACM cap is universally accepted. After all, such a thing never made it into Basel II – perhaps due to this argument against leverage ratio:

As a final point, the U.S. applies an even more arbitrary “Tier 1 leverage” ratio of 5% (defined as the ratio of Tier 1 capital to total assets) in order for a bank to be deemed “well-capitalized”. As we have noted in our prior responses, the leverage requirement forces banks with the least risky portfolios (those for which best-practice Economic Capital requirements and Basel minimum Tier 1 requirements are less than 5% of un-risk-weighted assets) either to engage in costly securitization to reduce reported asset levels or give up their lowest risk business lines. These perverse effects were not envisioned by the authors of the U.S. “well-capitalized” rules, but some other Basel countries have adopted these rules and still others might be contemplating doing the same.

ALLL should continue to be included in a bank’s actual capital irrespective of EL. As we and other sourcesfootnotes 3,4,5 have noted, it is our profit margins net the cost of holding (economic) capital that must more than cover EL. As a member of the Risk Management Association’s (RMA) Capital Working Group, we refer the reader to a previously published detailed discussion of this issue that we have participated with other RMA members in developingfootnote 4. This issue is also addressed at length in RMA’s pending response to this same Oct. 11, 2003 proposal.

Speaking in general terms, I am all in favour of a second check on the adequacy of bank capital. Looking at problems in different ways generally leads to a conclusion that is better overall than the sum of its parts. HIMIPref™, for instance, uses 23 different valuation measures and applies them in a non-linear fashion to the question of trading. No single measure has veto power; some of the valuation measures turn out to be of negligible independent importance; but the system as a whole provides answers that are better than the sum of its parts.

In this particular instance, it is not the ACM, per se, that we are examining, but the effect of deducting from capital the shortfall of provisions actually taken relative to the Expected Loss (EL) defined in the Basel II accord:

384. As specified in paragraph 43, banks using the IRB approach must compare the total amount of total eligible provisions (as defined in paragraph 380) with the total EL amount as calculated within the IRB approach (as defined in paragraph 375). In addition, paragraph 42 outlines the treatment for that portion of a bank that is subject to the standardised approach to credit risk when the bank uses both the standardised and IRB approaches.

385. Where the calculated EL amount is lower than the provisions of the bank, its supervisors must consider whether the EL fully reflects the conditions in the market in which it operates before allowing the difference to be included in Tier 2 capital. If specific provisions exceed the EL amount on defaulted assets this assessment also needs to be made before using the difference to offset the EL amount on non-defaulted assets.

386. The EL amount for equity exposures under the PD/LGD approach is deducted 50% from Tier 1 and 50% from Tier 2. Provisions or write-offs for equity exposures under the PD/LGD approach will not be used in the EL-provision calculation. The treatment of EL and provisions related to securitisation exposures is outlined in paragraph 563.

EL is calculated as:

EL = EAD x PD x LGD

where EAD is Exposure at Default; PD is Probability of Default; and LGD is Loss Given Default.

The FDIC provides a good explanation of the number:

A final determinant of required capital for a credit exposure or pool of exposures is the expected loss, or EL, defined as the product of EAD, PD and LGD. For example, consider a pool of subprime credit card loans with an EAD of $100. The PD is 10 percent – in other words, $10 of cards per year are expected to default, on average. The LGD is 90 percent, so that the loss on the $10 of defaults is expected to be $9. The EL is then $100 multiplied by 0.10 multiplied by 0.90, that is, $9. EL can be interpreted as the amount of credit losses the lender expects to experience in the normal course of business, year in and year out. If the total EL for the bank, on all its exposures, is less than its allowance for loan and lease losses (ALLL), the excess ALLL is included in the bank’s tier 2 capital (this credit is capped at 0.6 percent of credit risk-weighted assets). Conversely, if the total EL exceeds the ALLL, the excess EL is deducted from capital, half from tier 1 and half from tier 2. In this example, the EL that would be compared to the ALLL was a very substantial 9 percent of the exposure. The example is intended to illustrate that for subprime lenders or other lenders involved in high chargeoff, high margin businesses, the EL capital adjustment may be significant.

In the negotiations that resulted in Basel II, a major point of contention was the difference between expected losses and unexpected losses. It was agreed that unexpected losses (UL) could not really be modelled – by definition! – and that the purpose of bank capital was to guard against UL. On the other hand, EL could be calculated in accordance with credit models at any time as a routine part of the lending process, with provisions taken as necessary to reduce capital (and profit).

A major bone of contention was … what to do when a bank’s provisions were not equal to the Expected Loss as calculated? According to the BIS press release and final paper:

The Committee proposed in October 2003 that the recognition of excess provisions should be capped at 20% of Tier 2 capital components. Many commenters noted that this would provide perverse incentive to banks. The Committee accepted this point and has decided to convert the cap to a percentage (to be determined) of credit risk-weighted assets.

In order to determine provision excesses or shortfalls, banks will need to compare the IRB measurement of expected losses (EAD x PD x LGD) with the total amount of provisions that they have made, including both general, specific, portfolio-specific general provisions as well as eligible credit revaluation reserves discussed above. As previously mentioned, provisions or write-offs for equity exposures will not be included in this calculation. For any individual bank, this comparison will produce a “shortfall” if the expected loss amount exceeds the total provision amount, or an “excess” if the total provision amount exceeds the expected loss amount.

Shortfall amounts, if any, must be deducted from capital. This deduction would be taken 50% from Tier 1 capital and 50% from Tier 2 capital, in line with other deductions from capital included in the New Accord.

Excess provision amounts, if any, will be eligible as an element of Tier 2 capital. The Tier 2 eligibility of such excess amounts is subject to limitation at supervisory discretion, but in no case would be allowed to exceed a percentage (to be determined) of credit risk weighted assets of a bank.

The existing cap on Tier 2 capital will remain, Thus, the amount of Tier 2 capital, including the amount of excess provisions, must not exceed the amount of Tier 1 capital of the bank.

The basis of the difference (between EL and ALLL) is tricky to understand – possibly on purpose. Some of it may be due to correllations – as explained in a comment letter from Wachovia:

Removal of EL from required capital further highlights the problems with the retail capital functions that we and other banks have discussed in our previous letters. Assuming a 100% LGD for the “other retail” category, capital actually decreases after removing EL from the capital formula when PD increases from 2.6% to 4.6%, as shown in Figure 2 below. The correlations decline so rapidly that they more than offset the increase in PDs.

Our proposed solution is to reduce the asset value correlations at the high quality (low PD) end of the spectrum. For example, the curve smoothes out if the maximum correlation is lowered to the .08 to .10 range.

Remember correllations? That’s what makes pricing CDOs so interesting!

Another rationale (echoing that presented with WaMu’s arguments against any ACM in the first place, quoted above) was provided in a discussion by Price Waterhouse:

It is therefore clear that the calculation of expected losses is still relevant to the Basel IRB capital calculation in order to identify these shortfalls or excesses. Unless a bank has explicitly captured expected losses within its future margin income and can demonstrate this to be the case, the regulator will need to understand the amount of cushion that is in place to manage expected losses – either within capital or as part of provisions. In theory the regulator should not mind where this cushion for expected losses is positioned – future margin income, provision or capital – just as long as it is somewhere!

While this makes a certain amount of sense, it doesn’t sit well with me on a philosophical basis. All that’s happening – when expected losses are presumed to be covered by margin – is that the bank is stating that the loan is expected to be profitable. Well, holy smokes, we can assume that anyway, can’t we? Applying this rationale over a block of loans would mean that capital is equally unaffected by a stack of safe loans made at a small margin, or an equally sized stack of risky loans made at a fat margin … it makes much more sense to me to deduct the expected losses from capital (via provisioning) when the loans are made and subsequently to realize a greater proportion of the interest spread as profit as time goes on.

I’m certainly open to further discussion on this point – but that’s what it looks like from here, from the perspective of a fixed income investor to whom capitalization and loss protection is of more importance than equity stuff like income.

I am not particularly impressed by the explanation given in the TD Bank Guide to Basel II:

Referring to page 24 lines 14 and 21 of the Supp-pack, how is the “50% shortfall in allowance” derived?

The shortfall under Basel II is a regulatory calculation. The methodology is prescriptive and builds in possible, but not necessarily probable, assumptions. Examples could include downturns in the economy, sectors that experience particular challenges, among other items. Our current general allowance methodologies are in accordance with GAAP and approved by OSFI. We believe the existing allowance reported on the Balance sheet is adequate and we are comfortable with our current allocation.

This doesn’t make a lot of sense to me. TD’s EL is entirely under their control; they, not the regulators, determine the EAD, PD and LGD for each loan (subject to approval of methodology by the regulator). I will write them for more information on this matter.

Remember the OSFI advisory? The thing that this post is (allegedly) about? I’m deeply suspicious of the sentence OSFI has decided to reverse this unintended change to the ACM for IRB institutions until a comprehensive review of the ACM has been completed. They’re saying they want to do this now, and that the change was unintended? Not only have they spent the last year bragging about how hard they worked, but

  • The Expected/Unexpected losses thing was a major issue, that actually held up the signing of the Basel II accord. I would have expected anything to do with these effects to have be subject to more scrutiny than other elements, not less.
  • The ACM cap is exclusive to North America (as far as I know). Again, surely all elements of this measure must have been scrutinized with more care than others.

I will certainly be following their “comprehensive review of the ACM” with great interest – and, for what my two cents are worth, lobbying for the divisor to be Tier 1 Capital, as it is in the States, not Total Capital.

Here’s a summary of the differences as of the end of the second quarter. Kudos to BMO, who seem (seem!) to have bitten a bullet that has frightened off the competition.

Provisions vs. Expections & Total Capital
2Q08
Bank Excess
(Under)
Provision
Total
Capital
Percentage
RY (383) 28,597 (1.33%)
BNS (1,014)* 25,558 (3.97%)
BMO 0 21,675 0%
TD (478) 22,696 (2.11%)
CM (122)* 16,490 (0.74%)
NA (403)* 7,353 (5.48%)
*BNS, CM, NA – deduction may include securitization deductions, etc.; the figure is not adequately disclosed.

Update: The following eMail has been sent to BMO Investor Relations:

I note from page 19 of your 2Q08 Supplementary Package that “Expected loss in excess of allowance – AIRB approach” is zero, implying that your provisions for expected loan losses (ALLL) is equal to your Basel II EL = EAD * PD * LGD.

(i) Is this equality deliberate? Is there a policy at BMO that states a desired relationship between ALLL and EL?

(ii) Do you have any discussion papers or written policies available that will explain BMO’s policy in computing ALLL and/or EL?

(iii) Has the bank determined a position regarding the “comprehensive review of the [Assets to Capital Multiple]” announced by OSFI in their advisory of April, 2008?

Update, 2008-6-5: The following eMail has been sent to TD’s Investor Relations Department:

I note that in your discussion of Basel II at http://www.td.com/investor/pdf/2008q1basel.pdf you state: “The shortfall under Basel II is a regulatory calculation. The methodology is prescriptive and builds in possible, but not necessarily probable, assumptions. Examples could include downturns in the economy, sectors that experience particular challenges, among other items.”

However, I also note that in testimony to the US Senate Donald Powell stated that ALLL should normally be – and should be encouraged to be – greater than EL due largely to a shorter time horizon for the latter measure of credit risk. It is also my understanding that the factors of EL (EAD, PD and LGD) are entirely within your control.

What specific differences in assumptions are applied by TD when computing ALLL as opposed to EL? Do you have a reconciliation between the two figures that shows the effect of these assumptions? Do you have any policies in place that would have the effect of targetting a relationship between the two measures?

Update, 2008-6-5: The following eMail has been sent to OSFI:

I have read your April Advisory on the captioned matter (http://www.osfi-bsif.gc.ca/app/DocRepository/1/eng/guidelines/capital/
advisories/Advisory_Temp_Adjust_ACM_e.pdf) with great interest. I have a number of questions:

(i) Why does OSFI enforce the ACM using total capital instead of solely Tier 1 Capital, the latter being the practice in the United States?

(ii) Was testing of the ACM incorporated in any run-throughs and pro-forma financial tests performed by OSFI prior to implementation of the Basel II accord? Were the effects of provision shortfalls simply missed or have they changed significantly in the interim?

(iii) It is my understanding (from Donald Powell’s 2005 Senate testimony, published at http://banking.senate.gov/public/_files/ACF269C.pdf) that in the States it is expected that ALLL will normally exceed EL, due to differences in the desired effects of these two measures. Are you aware of any methodological or philosophical differences that have led to this situation being reversed in Canada for five of the Big-6 banks as of 2Q08?

(iv) I also understand that ACM is normally regarded as being a more stringent constraint on bank policies that Tier 1 Capital and Total Capital Ratios. Is this the view of OFSI?

(v) I understand that some justification for ALLL being lower than EL is that some proportion of EL is expected to be made up as a component of gross loan margin. Is this rationale accepted by OSFI?

(vi) Should the answer to (v) be affirmative, it seems to me that two similar banks could each make a basket of loans having the same value, with Bank A’s basket being lower-margin, lower-risk than Bank B’s basket. The EL for Bank B would be higher, but ALLL for both banks could be the same if Bank B determined that their higher margin justified a shortfall of ALLL relative to EL. Under the rules effective 1Q08, the effect of the ACM cap would be more constraining than they currently are after giving effect to the advisory; that there is currently no effect of risk on the ACM cap (although there is an effect on the Capital Ratios). Is this the intent of the advisory?

(vii) Will OSFI be dedicating a section of its website to the “comprehensive review of the ACM”? Will draft papers, requests for comments and responses from interested parties be made public in this manner? Have the terms of the comprehensive review yet been set?