Interesting External Papers

Effective Fed Funds and Interest on Excess Reserves

The Federal Reserve Bank of New York has released a staff report by Morten L. Bech and Elizabeth Klee titled The Mechanics of a Graceful Exit: Interest on Reserves and Segmentation in the Federal Funds Market:

To combat the financial crisis that intensified in the fall of 2008, the Federal Reserve injected a substantial amount of liquidity into the banking system. The resulting increase in reserve balances exerted downward price pressure in the federal funds market, and the effective federal funds rate began to deviate from the target rate set by the Federal Open Market Committee. In response, the Federal Reserve revised its operational framework for implementing monetary policy and began to pay interest on reserve balances in an attempt to provide a floor for the federal funds rate. Nevertheless, following the policy change, the effective federal funds rate remained below not only the target but also the rate paid on reserve balances. We develop a model to explain this phenomenon and use data from the federal funds market to evaluate it empirically. In turn, we show how successful the Federal Reserve may be in raising the federal funds rate even in an environment with substantial reserve balances.

This issue has been discussed on PrefBlog before, two posts being Effective Fed Funds Rate Continues to Confuse and Effective Fed Funds Rate: A Technical Explanation?.

The authors state the problem succinctly:

Between the October and December 2008 FOMC meetings the average effective federal funds rate was 32 basis points, while the target was 1 percent; the interest rate paid on reserves was 65 basis points or higher for the entire period. This deviation from the theoretical prediction was surprising for even the most astute observers of the federal funds market (Hamilton, 2008, for example). Why did interest on reserves provide an imperfect floor for the federal funds rate, even after the policy was changed so that the interest rate paid on reserves was set equal to the target rate?2 Why would any financial institution lend out funds below the rate paid by the central bank? And even if that were the case, arbitrageurs would surely relish the opportunity of making a pure profit by borrowing cheaply in the market and placing the proceeds with the central bank, and by doing so, move the market rate toward the floor.

… and propose:

The explanation for the puzzling outcome is at least threefold. First, not all participants in the federal funds market are eligible to receive interest on their reserve balances. Government-sponsored enterprises (GSEs) in particular, which are significant sellers of funds on a daily basis, are not legally eligible to receive interest on balances held with Reserve Banks. This heterogeneity across participants created a segmented market with different rate dynamics. Second, banks’ apparent general unwillingness or inability to engage in arbitrage has produced a market structure in which those banks that are willing and able to buy funds from the GSEs have been able to exercise bargaining power and pay the GSEs rates below the interest rate paid on reserves. The lack of arbitrage possibly has been driven in part by banks seeking to control the size of their balance sheet more closely in part to avoid stressing regulatory capital and leverage ratios, as mentioned in Bernanke (2009a). Third, a combination of financial consolidation, credit losses, and changes to risk management practices has led at least some GSEs to limit their number of counterparties in the money market and to tighten credit lines. This trimming of potential trading partners has likely decreased bargaining power with the remaining counterparties. In addition, the GSEs have become a larger share of the federal funds market in recent history and hence have pulled down the weighted average federal funds rate.

The paper is organized as:

First, we briefly discuss the institutional details of the federal funds market. Second, we turn to the history and implementation of the interest-on-reserves regime. Third, we present our model of a bifurcated federal funds market with banks and GSEs. We also sketch out how the model can be extended to describe a trifurcated market in which some banks are slow to adopt the new policy regime. Fourth, we calibrate our model to federal funds market data and back out the relative bargaining power of the different market participants. Fifth, we explore the factors that affect our computed bargaining parameters. We show that the level and distribution of reserve balances, rates in other overnight funding markets, and the riskiness of the buyers all have significant predictive power in explaining the bargaining power of the different types of sellers. With this information, in our sixth section, we forecast the effective federal funds rate under a variety of exit scenarios from the current accommodative stance of monetary policy. The seventh section concludes and offers directions for further research.

Issue Comments

YPG.PR.D Plummets on Opening Day

YPG.PR.D, the 6.90%+426 FixedReset announced December 7, commenced trading today with a dull thud.

It traded 157,195 shares in a range of 23.75-25 before closing at 23.86-90.

Vital statistics are:

YPG.PR.D FixedReset Not Calc! YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 22.68
Evaluated at bid price : 23.86
Bid-YTW : 7.14 %

Looking at relative yields is amusing:

YPG issues on December 22
Ticker Quote Bid Yield Bid YTW Scenario
YPG.PR.A 24.00-10 5.72% SoftMaturity 2012-12-30 at 25.00
YPG.PR.B 18.52-68 10.05% SoftMaturity 2017-6-29 at 25.00
YPG.PR.C 24.00-15 7.02% LimitMaturity
YPG.PR.D 23.86-90 7.14% LimitMaturity
Market Action

December 22, 2009

So much for the Christmas lull! Trading was heavy today and PerpetualDiscounts were down 14bp, while FixedResets were up 13bp as investors realized that a lot of the product available was not the YPG.PR.D new issue.

HIMIPref™ Preferred Indices
These values reflect the December 2008 revision of the HIMIPref™ Indices

Values are provisional and are finalized monthly
Index Mean
Current
Yield
(at bid)
Median
YTW
Median
Average
Trading
Value
Median
Mod Dur
(YTW)
Issues Day’s Perf. Index Value
Ratchet 0.00 % 0.00 % 0 0.00 0 0.1266 % 1,576.6
FixedFloater 5.84 % 3.97 % 41,119 18.81 1 -1.4293 % 2,667.6
Floater 2.49 % 2.90 % 111,326 19.99 3 0.1266 % 1,969.6
OpRet 4.86 % -4.45 % 129,703 0.09 15 0.0306 % 2,319.2
SplitShare 6.44 % -4.43 % 227,943 0.08 2 -0.0887 % 2,086.6
Interest-Bearing 0.00 % 0.00 % 0 0.00 0 0.0306 % 2,120.7
Perpetual-Premium 5.86 % 5.80 % 81,734 2.32 7 -0.0397 % 1,881.3
Perpetual-Discount 5.80 % 5.86 % 197,765 14.03 68 -0.1436 % 1,795.4
FixedReset 5.39 % 3.63 % 343,652 3.86 41 0.1317 % 2,168.9
Performance Highlights
Issue Index Change Notes
HSB.PR.D Perpetual-Discount -2.07 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 21.30
Evaluated at bid price : 21.30
Bid-YTW : 5.90 %
RY.PR.C Perpetual-Discount -1.66 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 20.75
Evaluated at bid price : 20.75
Bid-YTW : 5.61 %
POW.PR.D Perpetual-Discount -1.57 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 20.63
Evaluated at bid price : 20.63
Bid-YTW : 6.08 %
BAM.PR.J OpRet -1.52 % YTW SCENARIO
Maturity Type : Soft Maturity
Maturity Date : 2018-03-30
Maturity Price : 25.00
Evaluated at bid price : 26.00
Bid-YTW : 4.82 %
BAM.PR.G FixedFloater -1.43 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 25.00
Evaluated at bid price : 18.62
Bid-YTW : 3.97 %
BNS.PR.Q FixedReset -1.09 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2013-11-24
Maturity Price : 25.00
Evaluated at bid price : 26.36
Bid-YTW : 3.68 %
PWF.PR.K Perpetual-Discount -1.04 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 20.93
Evaluated at bid price : 20.93
Bid-YTW : 6.02 %
BAM.PR.K Floater 1.06 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 13.40
Evaluated at bid price : 13.40
Bid-YTW : 2.93 %
CM.PR.K FixedReset 1.26 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-08-30
Maturity Price : 25.00
Evaluated at bid price : 27.25
Bid-YTW : 3.42 %
RY.PR.Y FixedReset 1.30 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-12-24
Maturity Price : 25.00
Evaluated at bid price : 28.00
Bid-YTW : 3.61 %
CM.PR.A OpRet 1.32 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-01-21
Maturity Price : 25.25
Evaluated at bid price : 26.85
Bid-YTW : -52.24 %
NA.PR.L Perpetual-Discount 1.49 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 21.48
Evaluated at bid price : 21.75
Bid-YTW : 5.64 %
HSB.PR.C Perpetual-Discount 1.67 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 21.58
Evaluated at bid price : 21.90
Bid-YTW : 5.84 %
Volume Highlights
Issue Index Shares
Traded
Notes
CM.PR.L FixedReset 268,035 RBC crossed 26,700 at 28.15; then bought 19,900 from CIBC at the same price. CIBC then sold 19,000 to TD and 17,900 more to RBC at 28.15; TD bought 13,500 from HSBC at 28.15; RBC crossed 40,400 at 28.15. TD crossed a block of 30,900 at 28.16 (finally, a different price) and crossed two blocks, of 37,000 and 15,400 shares, both at the same old 28.15.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-05-30
Maturity Price : 25.00
Evaluated at bid price : 28.14
Bid-YTW : 3.69 %
ACO.PR.A OpRet 194,888 RBC crossed 194,800 at 25.90.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-01-21
Maturity Price : 25.50
Evaluated at bid price : 25.99
Bid-YTW : -13.17 %
GWO.PR.J FixedReset 53,065 RBC crossed 50,000 at 27.16.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-01-30
Maturity Price : 25.00
Evaluated at bid price : 27.16
Bid-YTW : 3.67 %
TD.PR.N OpRet 51,880 TD crossed blocks of 31,000 and 15,000 at 26.33.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-01-21
Maturity Price : 26.00
Evaluated at bid price : 26.40
Bid-YTW : -6.45 %
BNS.PR.T FixedReset 38,555 RBC crossed 18,800 at 28.00.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-05-25
Maturity Price : 25.00
Evaluated at bid price : 28.00
Bid-YTW : 3.57 %
BNS.PR.J Perpetual-Discount 36,620 RBC crossed 18,000 at 23.92.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-22
Maturity Price : 22.74
Evaluated at bid price : 23.74
Bid-YTW : 5.57 %
There were 64 other index-included issues trading in excess of 10,000 shares.
Indices and ETFs

GWO.PR.X, IGM.PR.A to be Removed from TXPR

Standard & Poor’s has announced:

  • • The Series E First Preferred Shares of Great-West Lifeco Inc. (TSX:GWO.PR.X) have been called for redemption on Thursday, December 31, 2009, at $26.00 per share. The shares will be removed from the S&P/TSX Preferred Share Index after the close of Wednesday, December 30, 2009.
  • •The 5.75% First Preferred Shares, Series A, of IGM Financial Inc. (TSX:IGM.PR.A) have been called for redemption on Thursday, December 31, 2009, at $26.00 per share. The shares will be removed from the S&P/TSX Preferred Share Index after the close of Wednesday, December 30, 2009.

The GWO.PR.X redemption and the IGM.PR.A redemption have been reported on PrefBlog.

Issue Comments

DBRS Mass Review of SplitShares

DBRS has announced that it:

has today taken rating action on structured preferred shares issued by 18 split share companies and trusts (the Issuers).

Each of the Issuers has invested in a portfolio of securities (the Portfolio) funded by issuing two classes of shares – dividend-yielding preferred shares or securities (the Preferred Shares) and capital shares or units (the Capital Shares). The main form of credit enhancement available to these Preferred Shares is a buffer of downside protection. Downside protection corresponds to the percentage decline in market value of the Portfolio that must be experienced before the Preferred Shares would be in a loss position. The amount of downside protection available to Preferred Shares will fluctuate over time based on changes in the market value of the Portfolio.

Of the 18 structured Preferred Share ratings updated today by DBRS, 16 have been upgraded and two have been downgraded. The upgraded ratings reflect an increase in net asset value (NAV) of the respective portfolios over the past four months and a greater stability in equity prices over this period. Two Preferred Share ratings were downgraded mainly because their Issuers have 100% exposure to Canadian life insurance companies, whose equity prices declined in value over the past four months.

They claim The upgraded ratings reflect an increase in net asset value (NAV) of the respective portfolios over the past four months and a greater stability in equity prices over this period …. while the latter part of this assertion is indubitably correct, some NAVs have actually declined over the period – at least, according the NAVs given in my August report of their review and the current NAVs. Of course, reporting-time is not the same thing as rating-time, so it could well be that the NAVs of all upgraded companies did, in fact, increase when measured from rating-time to rating time. Maybe!

I note, for instance, that the NAV of FTN / FTN.PR.A was 18.44 on August 31 and 17.42 on November 30 (the July 31 NAV was 17.89, while Dec 15 was 17.30).

DBRS Review Announced 2009-8-27
Ticker Old
Rating
Asset
Coverage
Last
PrefBlog
Post
HIMIPref™
Index
New
Rating
ABK.PR.B Pfd-3(high) 2.1+:1
12/17
Upgraded None Pfd-2(low)
ALB.PR.A Pfd-3 1.8+:1
12/17
Upgraded Scraps Pfd-3(high)
BSC.PR.A Pfd-3(high) 2.3+:1
12/17
Partial Call for Redemption None Pfd-2(low)
BSD.PR.A Pfd-5 1.2:1
12/18
Semi-Annual Financials Scraps Pfd-5(high)
LCS.PR.A Pfd-3(low) 1.4+:1
12/17
Upgraded None Pfd-4(high)
ES.PR.B Pfd-4(low) 1.4-:1
12/17
Small Call for Redemption None Pfd-4(high)
EN.PR.A Pfd-3 2.0+:1
12/17
Tiny Partial Redemption None Pfd-3(high)
FCS.PR.A Pfd-3(low) 1.5+:1
12/21
Upgraded None Pfd-3
FTN.PR.A Pfd-3(low) 1.7+:1
12/15
Upgraded Scraps Pfd-3
FFN.PR.A Pfd-4(high) 1.5+:1
12/15
Resumes Capital Unit Dividend Scraps Pfd-3(low)
FIG.PR.A Pfd-4 1.4+:1 (?)
Capital Units Rights Offering Scraps Pfd-4(high)
PIC.PR.A Pfd-4 1.4-:1
12/17
Upgraded Scraps Pfd-4(high)
SXT.PR.A Pfd-2(low) 2.3+:1
12/17
Small Partial Redemption Scraps Pfd-2
SLS.PR.A Pfd-4 1.1+:1
12/17
Upgraded None Pfd-4(low)
SNP.PR.V Pfd-3(low) 1.6-:1
12/17
Upgraded None Pfd-3
SOT.PR.A Pfd-3(high) 2.2-:1
12/21
Downgraded None Pfd-2(low)
TDS.PR.B Pfd-3(high) 2.3-:1
12/17
Partial Redemption Scraps Pfd-2(low)
WFS.PR.A Pfd-4 1.3-:1
12/17
Warrants Prospectus Filed Scraps Pfd-4(high)
PrefLetter

PrefLetter Reference to Essay Regarding Implied Volatility

In the December edition of PrefLetter, I suggested that an article regarding the calculation of Implied Volatility as it related to PerpetualDiscounts “should be published in the next edition of Canadian Moneysaver”.

As it turns out, the article has not been published.

The article will be published in expanded form in the January edition of PrefLetter; in the interim, interested PrefLetter subscribers may contact me to receive a copy of the article I had anticipated would be published in CMS.

Regulation

Canadian ABCP

The ABCP settlements have been released:

In the Scotia agreement, the “Contraventions” section is one paragraph long:

71. The Respondent admits to the following contraventions of IIROC Rules, Guidance, IDA By-Laws, Regulations or Policies:

Between July 25 and August 10, 2007, the Respondent failed to adequately respond to emerging issues in the Coventree ABCP market insofar as it continued to sell Coventree ABCP without engaging Compliance and other appropriate processes for the assessment of such emerging issues, contrary to IDA By-law 29.1 (ii) (now Dealer Member Rule 29.1(ii)).

If we have a look at Rule 29.1:

29.1. Dealer Members and each partner, Director, Officer, Supervisor, Registered Representative, Investment Representative and employee of a Dealer Member (i) shall observe high standards of ethics and conduct in the transaction of their business, (ii) shall not engage in any business conduct or practice which is unbecoming or detrimental to the public interest, and (iii) shall be of such character and business repute and have such experience and training as is consistent with the standards described in clauses (i) and (ii) or as may be prescribed by the Board.

For the purposes of disciplinary proceedings pursuant to the Rules, each Dealer Member shall be responsible for all acts and omissions of each partner, Director, Officer, Supervisor, Registered Representative, Investment Representative and employee of a Dealer Member; and each of the foregoing individuals shall comply with all Rules required to be complied with by the Dealer Member.

The agreed statement of facts for Scotia’s “Response to Emerging Issues” is:

60. Notwithstanding the events described above, the Respondent failed to fully assess the information in the July 24th e-mail in a meaningful way. The Respondent did not notify its Compliance Department (“Compliance”) of the July 24th email or its contents until after August 13, 2007.

61. Notwithstanding its concerns about emerging market issues for Coventree ABCP, the Respondent failed to engage an adequate process to fully assess the impact of those concerns. The Respondent did not notify Compliance of its concerns.

62. Notwithstanding the emerging issues relating to the Coventree ABCP market as described above, the Respondent continued to sell Coventree ABCP to institutional clients, primarily by way of newly issued paper.

63. From July 25 to August 3, 2007, the Respondent sold Comet E from inventory, as noted in paragraph 56, and newly issued Planet A ABCP in the amount of $35,400,000, to institutional clients who the Respondent was not aware had knowledge of the US subprime exposure.

64. On August 3 the Respondent sold $28 million and from August 7 to 10 the Respondent sold $235 million in newly issued Aurora A, SAT A, and SIT III A to institutional clients (excluding sales of ABCP that matured prior to August 13, 2007 and sales to the CDPQ and other certain professional counterparties).

Update: The AMF Press Release provides more detail:

Five of the institutions involved are alleged to have failed to adequately respond to issues in the third party ABCP market, as they continued to buy and/or sell without engaging compliance and other appropriate processes for assessing such issues. Particularly, they did not disclose to all their clients the July 24th e-mail from Coventree providing the subprime exposure of each Coventree ABCP conduit.

Market Action

December 21, 2009

Goldman is burnishing its credentials as the toughest dealer on the Street:

Goldman Sachs has threatened the UK Treasury with plans to move up to 20 per cent of its London-based staff to Spain in a standoff over tax and bonuses.

It’s believed that the Wall Street investment bank, which paid more than £2bn to the Exchequer’s ailing coffers in corporation tax alone last year, has fired a warning shot across the Government’s bows in response to the tax measures unveiled in the pre-Budget report earlier this month.

Goldman Sachs International was the biggest contributor from the financial services sector to Britain’s purse last year. Previous reports suggest that in some years the firm’s staff have contributed more than £1bn in personal income tax to public coffers.

PerpetualDiscounts were off today, losing 8bp, but FixedResets just kept on keeping on, gaining 6bp on good volume. How Low Can They Go?

HIMIPref™ Preferred Indices
These values reflect the December 2008 revision of the HIMIPref™ Indices

Values are provisional and are finalized monthly
Index Mean
Current
Yield
(at bid)
Median
YTW
Median
Average
Trading
Value
Median
Mod Dur
(YTW)
Issues Day’s Perf. Index Value
Ratchet 0.00 % 0.00 % 0 0.00 0 0.2326 % 1,574.6
FixedFloater 5.76 % 3.90 % 41,043 18.91 1 -1.6146 % 2,706.3
Floater 2.49 % 2.91 % 107,859 19.95 3 0.2326 % 1,967.1
OpRet 4.86 % -4.35 % 130,747 0.09 15 -0.1019 % 2,318.5
SplitShare 6.43 % -6.01 % 231,371 0.08 2 0.1555 % 2,088.4
Interest-Bearing 0.00 % 0.00 % 0 0.00 0 -0.1019 % 2,120.0
Perpetual-Premium 5.86 % 5.77 % 81,846 2.32 7 0.2444 % 1,882.0
Perpetual-Discount 5.79 % 5.85 % 198,595 14.05 68 -0.0844 % 1,798.0
FixedReset 5.40 % 3.68 % 348,265 3.86 41 0.0561 % 2,166.1
Performance Highlights
Issue Index Change Notes
HSB.PR.C Perpetual-Discount -2.71 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-21
Maturity Price : 21.54
Evaluated at bid price : 21.54
Bid-YTW : 5.95 %
BAM.PR.G FixedFloater -1.61 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-21
Maturity Price : 25.00
Evaluated at bid price : 18.89
Bid-YTW : 3.90 %
MFC.PR.A OpRet -1.18 % YTW SCENARIO
Maturity Type : Soft Maturity
Maturity Date : 2015-12-18
Maturity Price : 25.00
Evaluated at bid price : 26.04
Bid-YTW : 3.35 %
CIU.PR.A Perpetual-Discount -1.00 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-21
Maturity Price : 19.80
Evaluated at bid price : 19.80
Bid-YTW : 5.87 %
Volume Highlights
Issue Index Shares
Traded
Notes
MFC.PR.A OpRet 51,219 RBC crossed 48,800 at 26.45.
YTW SCENARIO
Maturity Type : Soft Maturity
Maturity Date : 2015-12-18
Maturity Price : 25.00
Evaluated at bid price : 26.04
Bid-YTW : 3.35 %
CM.PR.L FixedReset 46,986 RBC bought 15,500 from CIBC at 28.15.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-05-30
Maturity Price : 25.00
Evaluated at bid price : 28.15
Bid-YTW : 3.68 %
RY.PR.F Perpetual-Discount 44,474 YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-21
Maturity Price : 20.30
Evaluated at bid price : 20.30
Bid-YTW : 5.55 %
GWO.PR.I Perpetual-Discount 43,226 TD crossed 25,000 at 18.74.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-21
Maturity Price : 18.70
Evaluated at bid price : 18.70
Bid-YTW : 6.05 %
GWO.PR.X OpRet 38,991 Called for redemption.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-10-30
Maturity Price : 25.67
Evaluated at bid price : 25.96
Bid-YTW : 3.20 %
BAM.PR.K Floater 33,250 RBC crossed 25,000 at 13.25.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2039-12-21
Maturity Price : 13.26
Evaluated at bid price : 13.26
Bid-YTW : 2.96 %
There were 34 other index-included issues trading in excess of 10,000 shares.
Miscellaneous News

DBRS Redefines "Default"

DBRS has issued a press release, DBRS Clarifies its Approach to Rating Bank Subordinated Debt and Hybrid Instruments.

I love the word “clarifies”. It should mean “make clearer” or “resolve ambiguity”, but is nowadays used by smiley-boys to mean “changing our position while hoping you don’t notice”.

The interesting bits are as follows:

DBRS does not view the ability to defer payments as a credit risk, but rather, a risk that holders of the deferrable instruments have agreed to as per the contractual terms of the instrument and DBRS does not consider “deferral” as being equal to “default”.

Notching for Deferral or Skipping of Payments

DBRS will add an additional notch when instruments with discretionary payments defer or skip. This notch will be applied as long as discretionary payments are not being made. This additional notch serves to differentiate between instruments that are still making payments from those that are not paying, but otherwise meeting the instrument’s terms and covenants. As noted already, DBRS does not view the exercising of the right to defer or skip payments as equivalent to default. Typically, a bank that defers or skips discretionary payments is usually in significant difficulty, so that its senior debt rating is already under pressure and its rating has likely been lowered. That results in lower ratings for subordinated debt. Recent examples, however, have illustrated occasions when a bank may defer or skip due to regulatory events, but retain significant strength and remain investment grade. In these circumstances, the senior debt rating remains the principal driver of the likelihood that payments will be resumed and insolvency avoided.

This represents something of a change from their treatment of Quebecor World:

While the cumulative nature of the Series 3 and Series 5 preferred shares affords Quebecor World the flexibility to suspend dividends, provided dividends are paid in arrears, DBRS notes preferred shareholders maintain a level of expectation that these dividends will be paid in a timely manner, and this expectation is reflected in the preferred share ratings. Having not met the expectation of preferred shareholders, DBRS notes the preferred shares are more reflective of a “D” rating.

What’s right or wrong? There is, of course, no right or wrong.

DBRS is definitely in the wrong, though, for changing their policy under the banner of “clarification” and for not specifying just what does constitute a default under their terminology. When does a Straight Perpetual default? Not when it skips a payment, under the new policy. So when? When it enters CCCA protection? When it’s written down or otherwise has its claim on assets extinguished? When?

Interesting External Papers

Securitization: BIS Examines New Century Capital

The Bank for International Settlements has released a working paper by Allen B Frankel titled The risk of relying on reputational capital: a case study of the 2007 failure of New Century Financial:

The quality of newly originated subprime mortgages had been visibly deteriorating for some time before the window for such loans was shut in 2007. Nevertheless, a bankruptcy court’s directed ex post examination of New Century Financial, one of the largest originators of subprime mortgages, discovered no change, over time, in how that firm went about its business. This paper employs the court examiner’s findings in a critical review of the procedures used by various agents involved in the origination and securitisation of subprime mortgages. A contribution of this paper is its elaboration of the choices and incentives faced by the various types of institutions involved in those linked processes of origination and securitisation. It highlights the limited roles played by the originators of subprime loans in screening borrowers and in bearing losses on defective loans that had been sold to securitisers of pooled loan packages (ie, mortgage-backed securities). It also illustrates the willingness of the management of those institutions that became key players in that market to put their reputations with fixed-income investor clients in jeopardy. What is perplexing is that such risk exposures were accepted by investing firms that had the wherewithal and knowledge to appreciate the overall paucity of due diligence in the loan origination processes. This observation, in turn, points to the conclusion that the subprime episode is a case in which reputational capital, a presumptively effective motivator of market discipline, was not an effective incentive device.

The end of the road for New Century came when:

Purchasers of New Century’s loan production normally conducted a due diligence examination after a sales agreement had been reached. The investor, or a due diligence firm hired by the investor, would review loan files to determine whether the loan was underwritten according to the pool’s guidelines. Loans not meeting guidelines could be excluded from the loan bundle (kicked out) and returned to the originator.

Once kicked out, the mortgages were known as a “scratch and dent” (S&D) loans, which were purchased by specialised investors at a large discount to their principal balance. Consequently, one measure of the deterioration of the quality of New Century’s loan production is the percentage of S&D loan sales. In 2004 and 2005, such sales amounted to less than 0.5% of New Century’s secondary market transactions. By contrast, in the first three quarters of 2006, S&D loan sales accounted for 2.1% of such transactions (Missal (2008, p. 68)).

The upsurge in loan repurchase requests to New Century coincided with a change in the methodology employed to estimate its allowance for loan repurchase losses. New Century’s board learned of the change after a considerable delay. This discovery was followed, after a few days, by a public announcement on 7 February 2007 that New Century’s results for the three quarters of 2006 needed to be restated. It also noted an expectation that losses would continue due to heightened early payment default (EPD) rates.

New Century’s announcement prompted margin calls by many of its warehouse lenders and requests for accelerated loan repurchases. Soon, all of New Century’s warehouse lenders ceased providing new funding. Because simultaneous margin calls by its warehouse lenders could not be met, New Century filed for bankruptcy on April 2, 2007. It ceased to originate mortgages and entered into an agreement to sell off its loan servicing businesses.

Amusingly, in the light of the current bonus hysteria:

The examiner’s access to internal New Century documents provided valuable insights into how the appearance of the warning flags influenced, or did not influence, management. For example, the examiner could find no reference to loan quality in the internal documents that described New Century’s bonus compensation system for regional managers for 2005 and 2006 (Missal (2008, p. 147)). The examiner says that the compensation of New Century’s loan production executives was directly and solely related to the amount of mortgage loans originated, loans that, in turn, were subsequently sold or securitised.32 Likewise, the examiner found no mention of penalties (reduced commission payments to loan production staff) that would be assessed against defective loans that required price discounts for secondary market sale.

Heightened investor concerns about the performance of subprime loans were reflected in changes in their due diligence processes (Missal (2008, p. 165)). Historically, investors would ask due diligence firms to examine, on their behalf, only a small sample of loans in a particular pool. The character of the process first changed in 2006 when most investors began to look at the appraisal documents in all loan files in a loan pool. Investors then increased the share of loan files examined. This intensification of due diligence efforts was responsible for a sharp increase in New Century’s kickout rate from 6.9% in January 2006 to 14.95% in December 2006 (Missal (2008, p. 161)).

The author concludes:

The examiner’s report suggests that some of the actions undertaken to improve loan quality in late 2006 and early 2007 were designed to anticipate new credit risk concerns among New Century’s counterparties. Nonetheless, when New Century announced a need to recast its financial reports, there had not yet been a defection by any of its largest counterparties. Not surprisingly, defections ensued immediately after the announcement. In those circumstances, the bunching of defections probably signalled an absence of attention on the part of counterparties to the mounting risks of ongoing transactions with New Century. In turn, the evidence of ineffective counterparty risk management has led to concerns about the effectiveness of existing governance structures (corporate and regulatory) and, in particular, reputational capital as an incentive device. Can those structures now be relied on to discipline the risk-taking incentives of those involved in underwriting securities backed by subprime (and other risky) assets?