Archive for December, 2008

December 19, 2008

Saturday, December 20th, 2008

S&P cut a whack of bank ratings today, on the following grounds:

  • overall assessment of industry risk has been increased
  • sensitivity of ratings model to reliance on short term funding has increased
  • levels of stress are expected to be higher than typical cycles
  • model emphasizing risk-adjusted capital; developing framework that is more risk-sensitive than Basel I and more conservative than Basel II, particularly with respect to market risk and private equity risk.
  • “Systemically important” banks will have potential government support recognized

Rating changes were:

  • Bank of America, AA- from AA
  • Barclays, AA- from AA
  • Citibank, A+ from AA
  • Credit Suisse, A+ from AA-
  • Deutsche Bank, A+ from AA-
  • Goldman Sachs, A from AA-
  • HSBC, AA (negative outlook) from AA (stable)
  • JPMorgan, AA- from AA
  • Morgan Stanley, A from A+
  • Royal Bank of Scotland, A+ from AA-
  • UBS, A+ from AA-
  • Wells Fargo, AA+ (negative outlook) from AAA (Watch negative)

Some pretend-managers, very upset by Deutsche Bank’s refusal to execute an out-of-the-money call are very upset:

Deutsche Bank AG’s decision to pass up an opportunity to redeem 1 billion euros ($1.39 billion) of bonds is a setback for financial market stability, according to U.K. and German investment management and insurance groups.

The bank’s choice “will weigh on the markets for months,” said Andreas Fink, a Frankfurt-based spokesman for the BVI German Investment and Asset Management Association, whose 92 members oversee about 1.4 trillion euros of assets.

“This is a setback for the stabilization of banking markets and is likely to increase funding costs for banks generally,” Jonathan French, the London-based spokesman for the Association of British Insurers, said in an e-mailed statement to Bloomberg News.

S&P’s note on their bank downgrades stated:

We believe that the difficult operating environment will increase payment deferral risk of most regulated financial institutions’ hybrid capital securities in the U.S. and Europe, including the large systemically important banks covered in this review. This is because the difficult environment is expected to pressure financial performance.

Both Sarkozy and our very own Spend-Every-Penny are grandstanding about what a great banking system there would be if only they ran it. However, not all Canadian politicians have their ideas forgotten! California’s civil servants will get Rae days!

Accrued Interest brings an update on the new Term Auction Loan Facility; it looks like the Fed is desperate to get the securitization market started again.

Via Dealbreaker comes a link to a NYT article, Even Winners May Lose with Madoff:

One client said he invested more than $1 million with Mr. Madoff over a decade ago. As his portfolio rose in value, he took out several million dollars. While his statements showed several million dollars in his Madoff account when the fund collapsed last week, the client still ended up ahead.

But previous court rulings regarding financial frauds suggest the winners could be forced to give up some of their gains to losers.

Yet even Mr. Madoff’s most fortunate clients may wind up having to give back some of their gains, as investors might have to do in another recent financial fraud, the collapse of the hedge fund Bayou Group in 2005.

In the Bayou case, in which investors lost $400 million, a bankruptcy judge ruled that investors who withdrew money even before Bayou collapsed might have to return their profits, and possibly some of the initial investments, to the bankruptcy trustee overseeing the unwinding of Bayou.

The returned money is to be distributed among all investors, who are expected to receive only about 20 to 40 percent of their original investments.

Mr. Madoff’s winning clients are likely to face similar legal challenges. In fact, the Madoff client who profited from his investment spoke on the condition that he not be identified, out of concern that he might be sought out to repay some of his gains to the receiver or bankruptcy trustee for Mr. Madoff.

This is the worst thing that can happen in a fraud like this. The highlighted investor, it would seem, did everything right (except due-diligence, and nobody does that; it’s too expensive and if you do do it, you’ve got to listen to some whiny little geek who can’t even sell investment strategies tell you that you can’t put your [client’s] money into a sure thing with a great story): he regarded his hedge fund investment as high-risk and rebalanced regularly, taking his money off the table. He has adjusted his investment portfolio – and quite possibly his entire lifestyle – as a result of his ethereal winnings and now has to give them back.

I was once part (a very small, clerical level part) of an investigation of a stockbroker who had been naughty. Little Joe & Jane Lunchbucket had gone out and bought houses – retired, even, if memory serves – on the basis that their accounts were worth lots of money and would support them. The firm made good on actual losses, but not on fictitious winnings. It was a really, really bad situation.

There’s a marvellous post regarding the Madoff scandal on Bronte Capital and a thoroughly fascinating letter to the SEC via the WSJ.

What-Debt? is musing about a $30-billion deficit. I don’t have any problems with a deficit of that size, and I support Econbrowser‘s James Hamilton’s call for the stimulus to take the form of unrestricted grants to lower levels of government. I would go farther than that: there are hospitals and charities (a friend specifically mentioned Habitat for Humanity) who can get shovels in the ground next week if they can get some funding. There should be controls, of course, to ensure that the capital projects are actually useful (unlike Japan’s Ibaraki Airport discussed on December 4); but speed in spending the money is important.

No, my problem with a $30-billion deficit is that we don’t have the money already. Planned debt reduction of $3 billion per year for 2010–11 to 2012–13 based on rosy forecasts of continued good times won’t pay for a lot of recessions. But What-Debt? and Spend-Every-Penny have crippled Canada’s ability to maintain a surplus through a normal business cycle, importing the simplistic US Republican thesis that tax cuts are always good, particularly if the cuts are completely bone-headed, like the GST cut. Throw the rascals out!

Another day of very heavy volume and … the sixth straight decline in PerpetualDiscounts, which now yield 8.31%; edging closer to their recent high of 8.63%. The former, current, figure is equivalent to 11.63% interest at the standard conversion factor of 1.4x; given that long corporates yield about 7.50%, the pre-tax interest-equivalent spread is an astonishing 413bp.

PerpetualDiscounts are currently down 1.48% total return on the month; Split-shares have had a better time of it and are now up 13.11% on the month; probably due to the market’s discovery of monthly retraction possibilities.

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.
The Fixed-Reset index was added effective 2008-9-5 at that day’s closing value of 1,119.4 for the Fixed-Floater index.
Index Mean Current Yield (at bid) Mean YTW Mean Average Trading Value Mean Mod Dur (YTW) Issues Day’s Perf. Index Value
Ratchet N/A N/A N/A N/A 0 N/A N/A
Fixed-Floater 8.57% 8.73% 134,564 11.91 7 -0.0141% 615.9
Floater 9.49% 9.56% 87,210 9.98 2 +4.7913% 342.5
Op. Retract 5.57% 6.98% 163,527 4.12 14 +0.3043% 976.6
Split-Share 6.68% 12.27% 96,353 3.94 15 +1.4955% 924.0
Interest Bearing 9.88% 19.63% 57,409 2.66 3 +1.6042% 750.4
Perpetual-Premium N/A N/A N/A N/A N/A N/A N/A
Perpetual-Discount 8.17% 8.31% 239,331 11.12 71 -0.4405% 680.0
Fixed-Reset 6.03% 5.38% 1,164,322 13.83 18 +0.0489% 1,002.3
Major Price Changes
Issue Index Change Notes
BCE.PR.Z FixFloat -5.8824%  
HSB.PR.C PerpetualDiscount -5.6250% Now with a pre-tax bid-YTW of 8.51% based on a bid of 15.10 and a limitMaturity. Closing quote 15.15-25, 20×20. Day’s range of 15.10-00.
POW.PR.C PerpetualDiscount -4.4251% Now with a pre-tax bid-YTW of 8.31% based on a bid of 17.51 and a limitMaturity. Closing quote 17.73-91, 1×1. Day’s range of 17.50-18.89.
CU.PR.B PerpetualDiscount -3.9543% Now with a pre-tax bid-YTW of 7.54% based on a bid of 20.16 and a limitMaturity. Closing quote 20.15-29, 8×5. Day’s range of 20.15-81.
BMO.PR.H PerpetualDiscount -3.7589% Now with a pre-tax bid-YTW of 8.35% based on a bid of 16.13 and a limitMaturity. Closing quote 16.18-39, 6×1. Day’s range of 16.05-60.
CM.PR.P PerpetualDiscount -3.0890% Now with a pre-tax bid-YTW of 8.80% based on a bid of 16.00 and a limitMaturity. Closing quote 16.21-45. Day’s range of 15.70-16.51.
SLF.PR.C PerpetualDiscount -2.8754% Now with a pre-tax bid-YTW of 9.23% based on a bid of 12.16 and a limitMaturity. Closing quote 12.26-49, 3×12. Day’s range of 12.15-10.
CM.PR.G PerpetualDiscount -2.7778% Now with a pre-tax bid-YTW of 8.78% based on a bid of 15.75 and a limitMaturity. Closing quote 15.91-00, 8×5. Day’s range of 15.75-50.
NA.PR.M PerpetualDiscount -2.5600% Now with a pre-tax bid-YTW of 8.36% based on a bid of 18.27 and a limitMaturity. Closing quote 17.31-60, 5×1. Day’s range of 17.31-60.
BNS.PR.N PerpetualDiscount -2.5507% Now with a pre-tax bid-YTW of 7.98% based on a bid of 16.81 and a limitMaturity. Closing quote 16.80-09, 9×18. Day’s range of 16.80-60.
CM.PR.K FixedReset -2.5352%  
BCE.PR.C FixFloat -2.5271%  
BAM.PR.N PerpetualDiscount -2.4390% Now with a pre-tax bid-YTW of 14.33% based on a bid of 8.40 and a limitMaturity. Closing quote 8.35-58, 1×1. Day’s range of 8.35-93.
SBN.PR.A SplitShare -2.3502% Asset coverage of 1.6+:1 as of December 11, according to Mulvihill. Now with a pre-tax bid-YTW of 9.04% based on a bid of 8.31 and a hardMaturity 2014-12-1 at 10.00. Closing quote of 8.30-82, 200×3. Yes, that’s a bid for 20,000 shares. The retraction is highly profitable.
MFC.PR.B PerpetualDiscount -2.2566% Now with a pre-tax bid-YTW of 7.74% based on a bid of 15.16 and a limitMaturity. Closing quote 14.51-92, 2×11. Day’s range of 14.75-64.
BAM.PR.M PerpetualDiscount -2.2196% Now with a pre-tax bid-YTW of 14.38% based on a bid of 8.37 and a limitMaturity. Closing quote 8.36-49, 10×1. Day’s range of 8.34-70.
BNS.PR.K PerpetualDiscount -2.1223% Now with a pre-tax bid-YTW of 7.81% based on a bid of 15.68 and a limitMaturity. Closing quote 15.54-14, 15×15. Day’s range of 15.53-20.
PWF.PR.K PerpetualDiscount -2.0408% Now with a pre-tax bid-YTW of 8.79% based on a bid of 14.40 and a limitMaturity. Closing quote 14.46-63, 5×1. Day’s range of 14.30-99.
POW.PR.A PerpetualDiscount +2.3270% Now with a pre-tax bid-YTW of 8.37% based on a bid of 16.80 and a limitMaturity. Closing quote 16.37-51, 10×2. Day’s range of 16.51-00.
RY.PR.W PerpetualDiscount +2.3399% Now with a pre-tax bid-YTW of 7.48% based on a bid of 16.62 and a limitMaturity. Closing quote 16.96-40, 2×10. Day’s range of 16.00-17.50.
BNA.PR.B SplitShare +2.6154% Asset coverage of 1.8+:1 based on BAM.A at 19.27 and 2.4 BAM.A per unit. Now with a pre-tax bid-YTW of 8.82% based on a bid of 20.01 and a hardMaturity 2016-3-25 at 25.00. This is now very clearly trading off the estimated retraction price of 21.69. Closing quote of 20.00-99, 4×1. Day’s range of 19.50-01.
FIG.PR.A InterestBearing +2.7132% Asset coverage of 1.0:1 as of December 18, according to Faircourt. Now with a pre-tax bid-YTW of 20.16% based on a bid of 5.30 and a (dubious) hardMaturity 2014-12-31 at 10.00. Closing quote of 5.30-49, 2×7. Day’s range of 5.17-33.
BAM.PR.H OpRet +2.8571% Now with a pre-tax bid-YTW of 13.89% based on a bid of 19.80 and a softMaturity 2012-3-30 at 25.00. Closing quote of 20.00-50, 10×5. Day’s range of 19.25-20.50.
LBS.PR.A SplitShare +2.9216% Recently discussed on PrefBlog. Now with a pre-tax bid-YTW of 11.70% based on a bid of 7.75 and a hardMaturity 2013-11-29 at 10.00. Closing quote of 7.86-35, 250×1. That’s right, a bid for 25,000 shares; estimated retraction price is 9.41; need I say more? Day’s range of 7.36-99.
SBC.PR.A SplitShare +3.0263% Asset coverage of 1.3+:1 as of December 18 according to Brompton. Now with a pre-tax bid-YTW of 12.81% based on a bid of 7.83 and a hardMaturity 2012-11-30 at 10.00. Closing quote of 7.85-98, 30×1. Day’s range of 7.60-00.
CL.PR.B PerpetualDiscount +3.0769% Now with a pre-tax bid-YTW of 7.83% based on a bid of 20.10 and a limitMaturity. Closing quote 19.51-07, 2×4. Day’s range of 19.25-20.74.
WFS.PR.A SplitShare +4.3478% Asset coverage of 1.2-:1 as of December 11 according to Mulvihill. Now with a pre-tax bid-YTW of 12.88% based on a bid of 8.40 and a hardMaturity 2011-6-30 at 10.00. Closing quote of 8.50-59, 115×8 (estimated retraction price is 9.60). Day’s range of 8.02-50.
FTN.PR.A SplitShare +4.5455% Asset coverage of 1.4-:1 as of December 15 according to the company. Now with a pre-tax bid-YTW of 9.78% based on a bid of 7.82 and a hardMaturity 2015-12-1 at 10.00. Closing quote of 8.01-15, 55×5. Day’s range of 7.50-01.
BNA.PR.A SplitShare +5.1795% See BNA.PR.B, above. Now with a pre-tax bid-YTW of 18.89% based on a bid of 20.51 and a hardMaturity 2010-9-30 at 25.00. Closing quote of 20.50-29, 2×1. Day’s range of 19.70-22.49 (!).
BCE.PR.F FixFloat +6.4701%  
BAM.PR.K FixFloat +9.5313%  
Volume Highlights
Issue Index Volume Notes
PWF.PR.J OpRet 154,000 Nesbitt crossed 150,000 at 24.60. Anonymous crossed (?) 10,000 at 24.59. Now with a pre-tax bid-YTW of 5.28% based on a bid of 24.60 and a softMaturity 2015-12-18 at 25.00.
MFC.PR.A OpRet 119,475 Desjardins crossed 100,000 at 24.25. Now with a pre-tax bid-YTW of 4.62% based on a bid of 24.26 and a softMaturity 2015-12-18 at 25.00.
BNS.PR.L PerpetualDiscount 105,980 Scotia bought 10,300 from TD at 14.35; Nesbitt crossed 35,400 at the same price. Now with a pre-tax bid-YTW of 7.90% based on a bid of 14.55 and a limitMaturity.
BNS.PR.M PerpetualDiscount 100,658 Nesbitt crossed 14,200 at 14.55. Now with a pre-tax bid-YTW of 7.90% based on a bid of 14.55 and a limitMaturity.
RY.PR.N FixedReset 96,515 RBC was buying! 20,600 from anonymous at 26.00; 25,000 from Nesbitt at 26.00; 19,800 from anonymous at 26.00; and 10,000 from TD at 25.99. Perhaps notable for being the first FixedReset issue for which the Real Genuine 100% YTW Scenario is the five year call.

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

LBS.PR.A : Dividends on Capital Units Suspended

Saturday, December 20th, 2008

Brompton Group has announced:

In accordance with its prospectus and the Class A Share Provisions, the regular, non-cumulative, monthly distribution for the month of December will not be paid on the class A shares of Life & Banc Split Corp. Under the prospectus, no cash distribution may be paid on the class A shares, if after payment of the distribution by the Fund, the net asset value per unit (consisting of one class A share and one preferred share) would be less than $15.00. The net asset value per unit as at December 11, 2008 was $12.86. The Fund will re-evaluate the payment of class A share distributions in each subsequent month with the expectation that normal monthly distributions will resume and a press release will be issued if the net asset value per unit is in excess of $15.00 prior to declaration.

LBS.PR.A has been placed on Review-Negative by DBRS … and Assiduous Reader lystgl asked the question:

LBS.PR.A is on the list of “about to be or may be” downgraded. I was just wanting, in terms I can understand, to know why.

My response is:

LBS.PR.A is backed by a portfolio of the Big 6 Banks and Big 4 Insurers. This is better than being backed by a single financial issuer, but is worse than the backing of a fully diversified portfolio.

Equity market declines have eroded the asset coverage of the portfolio to a mere 1.279:1 as of December 18. In DBRS terminology, thats “Downside Protection” of about 22% … in other words, if the portfolio declines by another 22%, then the Capital Units will have no intrinsic value (they will have option value) and the Preferred Shares will be fully exposed to further declines in portfolio value. Worse … when the NAV per Unit is $10, they have full downside exposure but no upside, as increases in the portfolio above that point will belong to the Capital Units.

The DBRS guideline (which is influenced by other factors, such as the nature of the underlying portfolio and income coverage) for a Pfd-2/Pfd-2(low) rating is downside protection of 40-50%. Since LBS.PR.A is currently below that figure, they’re reviewing it … and if there are no extenuating factors, they’ll cut the rating.

When we look at their most recent financial statements, we find that all the declared income looks sustainable – it’s nearly all dividends, with minor contributions from securities lending and interest income. There’s no one-off stuff in there, and no games-playing with “option income” or other crap. So we can estimate sustainable income going forward as $4.838-million per six-month period … dependent, of course, on none of their underlying holdings cutting the dividend.

Expenses were $1.189-million, which looks sustainable. Distributions on preferred shares were $2.980-million.

Thus, income coverage is 4.838/(1.189 + 2.980) = 1.16:1. This is a good number. They can cover their expenses and preferred share distribution with sustainable income (assuming no cuts in dividend receipts), which is a Good Thing and not the case for all split-shares (see Split Shares and the Credit Crunch).

There is a major drag on NAV of the Capital Unit distribution, which amounted to $6.818-million in the financial statements. Given that there were 11.363-million units outstanding, this amounts to a drag on NAV of $0.60 per unit per half, or $1.20 per year – which ties in admirably with the “8.0% targeted yield based on $15.00 issue price, paid monthly”. However, this drag has been eliminated due to:

No distributions will be paid on Class A shares if (i) distributions payable on the Preferred shares are in arrears or (ii) after the payment of the distributions by the Fund, the Published NAV per unit is less than $15.

Hurray!

So income and asset coverage both look reasonable especially when compared to the market price rather than to the obligation of $10. But to me, it doesn’t look good enough to warrant a Pfd-2/Pfd-2(low) rating and I expect a cut to maybe Pfd-3 / Pfd-3(high).

Yet ANOTHER DBRS Mass Review of Splits

Friday, December 19th, 2008

DBRS has announced that it:

has today placed the rating of certain structured preferred shares (Split Shares) Under Review with Negative Implications. Each of these split share companies 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 Preferred Shares benefit from a stable dividend yield and downside principal protection via the net asset value (NAV) of the Capital Shares against the percentage loss in the Portfolio’s NAV. Preferred Shares have experienced significant declines in downside protection during the past number of months due to volatility in the global equity markets. As a result, DBRS has placed the Preferred Shares listed below Under Review with Negative Implications. DBRS will take final rating action on these Preferred Shares once a longer-term trend has been established for the NAVs of the affected split share companies.

They note that analysis will be performed according to the methodology of 2007

They do not explicitly list the affected splits in the main text, but they do have a list of related issues. On the assumption that there is a one-to-one relationship, the following table may be prepared.

DBRS Review Announced 2008-12-19
Ticker Rating Asset
Coverage
Last
PrefBlog
Post
HIMIPref™
Index
ABK.PR.B Pfd-2(low) 1.3+:1
12/18
Issue Closes None
TDS.PR.B Pfd-2(low) 1.5-:1
12/18
Microscopic Redemption Scraps
FTN.PR.A Pfd-2 1.4-:1
12/15
No Fear! SplitShare
BMT.PR.A Pfd-2(low) 1.1+:1
12/18
Partial Call Scraps
MST.PR.A Pfd-2(low) 1.3+:1
12/18
Capital Unit Dividend Suspended Scraps
FFN.PR.A Pfd-2(low) 1.1+:1
12/15
Capital Unit Dividend Suspended SplitShare
EN.PR.A Pfd-2(low) 1.4+:1
12/18
Partial Redemption Scraps
BXN.PR.B Pfd-2(low) 1.6-:1
12/18
Partial Redemption None
PPL.PR.A Pfd-2 1.4-:1
12/15
Added to HIMIPref™ SplitShare
LSC.PR.C Pfd-2 1.4-:1
12/18
Partial Redemption None
BSC.PR.A Pfd-2(low) 1.4+:1
12/18
Partial Redemption None
SBC.PR.A Pfd-2 1.3+:1
12/18
Added to HIMIPref™ SplitShare
PDV.PR.A Pfd-2 1.3+:1
12/15
None None
SOT.PR.A Pfd-2(low) 1.4+:1
12/18
None None
BBO.PR.A Pfd-2 1.6+:1
12/11
Rights Offering None
LBS.PR.A Pfd-2 1.3-:1
12/18
Analysis SplitShare
RBS.PR.A Pfd-2(low) 1.2-:1
12/18
Tiny Redemption None
LCS.PR.A Pfd-2 1.2+:1
12/18
Analysis None

The previous DBRS Review of Splits has not yet been completed. All these are new.

GBA.PR.A Cuts Preferred Dividend; DBRS Review-Negative

Friday, December 19th, 2008

Globalbanc Advantaged 8 Split Corp. has announced:

a distribution of $0.07 per Preferred Share for the quarter ending December 31, 2008. The distribution will be paid on January 13, 2009 to holders of record on December 31, 2008. No distribution will be paid on the Class A Shares for the quarter ending December 31, 2008.

The Company has determined that, as a result of anticipated changes in the dividend payments to be paid by the banks included in the Bank Portfolio, future dividend payments to be received by the Company may not generate sufficient yield to pay in full the fixed cumulative quarterly dividends in the amount of $0.1125 per Preferred Share (as established by the share conditions relating to the Preferred Shares) and the expenses of the Company. Accordingly, the Company has determined to pay during 2009 a quarterly dividend amount of one-quarter of the Bloomberg Dividend Forecast of the dividends to be paid by the banks comprising the Bank Portfolio in the upcoming 12 months, less an estimate of the expenses of the Company. The Board of Directors will monitor these estimates and may revise the amount of dividends paid on the Preferred Shares in the future, up or down, to take in to account changes in these estimates and changes in the Company’s expenses.

Assuming dividends are paid by the Bank Portfolio at least consistent with these estimates over the coming 12 months, the Company will maintain sufficient cash flow to make dividend payments in accordance with the revised dividend policy and to fund current operating expenses. If the Company were to pay dividends and incur operating expenses in excess of these cash flows it may be necessary to dispose of a portion of the securities comprising the Bank Portfolio. The Board of Directors believes it is in the best interests of the Company to pay dividends at a level which avoids a sale of assets at this time.

The shortfall below the prescribed amount of the Preferred Share dividend will accumulate and, in accordance with the terms of the Preferred Shares and the Class A Shares, will be paid in priority to any payments on the Class A Shares.

In response, DBRS announced:

has today placed the Preferred Shares issued by GlobalBanc Advantaged 8 Split Corp. (the Company) Under Review with Negative Implications following the Company’s announcement of a revised dividend policy.

The Preferred Shares are entitled to fixed cumulative quarterly dividend payments of $0.1125 per share, yielding 4.5% per annum on the initial share price of $10. The Company has reduced the December 31 distribution to $0.07 per Preferred Share. For 2009, the Company plans to pay a quarterly dividend amount of one-quarter of the forecasted dividends to be received by the Company less an estimate of the expenses of the Company, in order for the Company to avoid a sale of assets to pay Preferred Share distributions.

As a result of the deterioration of the Company NAV and the decision by the Company to reduce the Preferred Shares dividend, DBRS has placed its rating of Pfd-5 (low) on the Preferred Shares Under Review with Negative Implications.

Asset coverage is 0.5+:1 as of December 18, according to the company.

GBA.PR.A was last mentioned on PrefBlog when DBRS downgraded it to Pfd-5(low). GBA.PR.A is not tracked by HIMIPref™.

Is There Really a Credit Crunch?

Friday, December 19th, 2008

Menzie Chinn of Econbrowser highlights an exchange between researchers sponsored by the Minneapolis Fed and some sponsored by the Boston Fed.

The Minneapolis group, Patrick J. Kehoe, V.V. Chari and Lawrence J. Christiano, have published Facts and Myths about the Financial Crisis of 2008; this paper has been rebutted in a paper by the Boston Fed’s Ethan Cohen-Cole, Burcu Duygan-Bump, Jose Fillat, and Judit Montoriol-Garriga in a paper titled Looking Behind the Aggregates: A reply to “Facts and Myths about the Financial Crisis of 2008”.

  • Bank lending to nonfinancial corporations and individuals has declined sharply
    • Minneapolis claims that:
      • Bank assets less vault cash have remained constant through the crisis
      • Loans and leases by US commercial banks have been constant
      • Commercial and Industrial Loans have been constant
      • Consumer loans have been constant
    • Boston claims that
      • Securitization has declined
      • There has been a significant increase in drawdowns from previously committed loans.
      • Unused lending commitments at commercial banks, especially for commercial and industrial loans, have contracted since the last quarter of 2007.
      • The price of loans (presumed to be related to LIBOR) has increased; spreads between jumbo and conforming mortgages have increased.
  • Interbank lending is essentially nonexistent.
    • Minneapolis claims that:
      • Interbank lending has been constant
    • Boston claims that:
      • Data appears to be from Federal Reserve report H8
      • Anecdotal evidence suggest that interbank lending has become largely comprised of overnight loans secured by Treasuries, but H8 is silent on the subject
      • Cash assets of banks have skyrocketted, due to cash hoarding by big banks.
  • Commercial paper issuance by non-financial corporations has declined sharply, and rates have risen to unprecedented levels.
    • Minneapolis claims that:
      • Commercial paper outstanding by financial corporations has declined, but non-financial paper has been constant.
      • Financial and lower-grade non-financial rates have increased, but high-grade non-financial rates have been constant.
    • Boston claims that:
      • New issuance by lower-grade non-financial corporations (the lion’s share of the total market) has plumetted since the Lehman default
      • The proportion of “overnight” (1-4 day maturity) paper has increased dramatically

I’ll give game, set and match to the Boston group (especially since Minneapolis ignored the securitization angle), but it’s an interesting exercise in seeing just how complicated things really are; I recommend the papers to any Assiduous Reader who doesn’t mind learning just how superficial is his understanding of the data!

Dr. Chinn also presents some conclusions from Tong & Wei, 2008:

First, we classify each non-financial stock (other than airlines, defense and insurance firms) along two dimensions: whether its degree of liquidity constraint at the end of 2006 (per the value of the Whited-Wu index) is above or below the median in the sample, and whether its sensitivity to a consumer demand contraction is above or below the median. Second, we form four portfolios on July 31, 2007 and fix their compositions in the subsequent periods: the HH portfolio is a set of equally weighted stocks that are highly liquidity constrained and highly sensitive to consumer demand contraction; the HL portfolio is a set of stocks that are highly liquidity constrained, but relatively not sensitive to a change in consumer confidence; the LH portfolio consist of stocks that are relatively not liquidity constrained but highly sensitive to consumer confidence; and finally, the LL portfolio consists of stocks that are neither liquidity constrained nor sensitive to consumer confidence. Third, we track the cumulative returns of these four portfolios over time and plot the results in Figure 6.

Dr. Chinn remarks that

They conclude that about half of the decline in stock prices is due to the credit crunch, with the other half attributable to the decline in consumer confidence

Well, I haven’t read the whole paper! But I will suggest that in using stock prices as a metric, Tong & Wei are not measuring “harm”; they are measuring “investor confidence”, which is not the same thing (Assiduous Readers will be all too well aware of my contempt for the Efficient Market Hypothesis!). However, I may well be in agreeement with Tong & Wei on this point, who state merely:

If subprime problems disproportionately harm those non-financial firms that are more liquidity constrained and/or more sensitive to a consumer demand contraction, could financial investors earn excess returns by betting against these stocks (relative to other stocks)? This is essentially another way to gauge the quantitative importance of these two factors.

December 18, 2008

Friday, December 19th, 2008

There’s an amusing story today about bonus policies at Credit Suisse:

Credit Suisse Group AG’s investment bank has found a new way to reduce the risk of losses from about $5 billion of its most illiquid loans and bonds: using them to pay employees’ year-end bonuses.

The bank will use leveraged loans and commercial mortgage- backed debt, some of the securities blamed for generating the worst financial crisis since the Great Depression, to fund executive compensation packages, people familiar with the matter said. The new policy applies only to managing directors and directors, the two most senior ranks at the Zurich-based company, according to a memo sent to employees today.

Credit Suisse is the first to use the debt to pay employees. Outside investors may also be permitted to invest in the facility, according to the people familiar with the matter, who declined to be identified because the plan hasn’t been made public. The bank will boost the potential for returns by providing leverage to the facility, and will be paid back first, according to the people.

If I am correct – with the support of the BoE – and bank assets have, in general, been written down to far below fundamental value, this is a clever way for the executives to (a) earn brownie points, and (b) give themselves enormous bonuses.

In sad news for bond investors, General Electric’s debt ratings are at risk. This is particularly grievous because GE has long had a well-deserved AAA rating but has yielded like a single-A … and any time you can pick up free credit quality is a Good Time.

Allan Greenspan opines in an Economist op-ed Banks need more capital:

As recently as the summer of 2006, with average book capital at 10%, a federal agency noted that “more than 99% of all insured institutions met or exceeded the requirements of the highest regulatory capital standards.”

Today, fearful investors clearly require a far larger capital cushion to lend, unsecured, to any financial intermediary. When bank book capital finally adjusts to current market imperatives, it may well reach its highest levels in 75 years, at least temporarily (see chart). It is not a stretch to infer that these heightened levels will be the basis of a new regulatory system.

Note that the chart shows “Book equity as % of book assets”. I believe that this is equal to the FDIC’s ratio “Equity capital to assets”. The FDIC defines this as “Total equity capital as a percent of total assets”, whereas the more commonly referenced “Leverage Ratio” is

Tier 1 (core) capital as a percent of average total assets minus ineligible intangibles.

Tier 1 (core) capital includes: common equity plus noncumulative perpetual preferred stock plus minority interests in consolidated subsidiaries less goodwill and other ineligible intangible assets. The amount of eligible intangibles (including mortgage servicing rights) included in core capital is limited in accordance with supervisory capital regulations. Average total assets used in this computation are an average of daily or weekly figures for the quarter.

The equity capital ratio for all FDIC insured institutions was reported in their 3Q08 Report to be 9.63%, compared to 10.45% (3Q07); 10.25% (3Q05); and 9.13% (3Q03). Note that Mr. Greenspan’s chart forecasts a massive increase in this ratio without this forecast being justified in the text.

Moody’s cut Citigroup from Aa3 to A2:

Moody’s Investors Service lowered the debt ratings of Citigroup Inc. (senior debt to A2 from Aa3) and the ratings on its lead bank, Citibank N.A. (long-term bank deposits to Aa3 from Aa1). The financial strength rating on the bank was lowered three notches to C from B, which translates to a change in the baseline credit assessment to A3 from Aa3. The outlook on the bank financial strength rating is negative and the rating outlooks on the deposit and debt ratings at both the bank and the holding company are stable.

Moody’s said that its downgrade of Citigroup’s debt and deposit ratings was moderated by Moody’s opinion that Citigroup enjoys a very high probability of systemic support from the U.S. government. The benefits of this systemic support partially offset the deterioration in Citigroup’s stand-alone credit quality, which is driven by worsening asset quality and the likelihood that Citigroup could see further decline in its tangible capital base in the next two years.

This had immediate contagion effects, with HSBC getting hammered in Hong Kong. Look out below!

Holy smokes, what a day. Very heavy volume and the market tanked. An Assiduous Reader wrote in:

Another dismal day for PerpetualDiscounts on fairly big volume. Could this downward momentum be caused by margin calls…forced selling…or panicking investors and their advisors?

I’m ready to pull the sell trigger myself….Clients will be in disbelief with Dec 31st statements.

Well … I still like the tax-loss-selling hypothesis. It fits with the season, volume and direction. Margin calls and forced selling, not so much, because I don’t think a lot of prefs are bought on margin, or are held in margin accounts that are levered to the max (I could be wrong. It would be interesting to see some figures). Panicking clients? I would think that any client with the guts to hang in this long will consider recent declines to be a mere bagatelle, but panicking advisors sounds more possible. There will be a fair number of clients who haven’t received a statement since September and things …. are a little different now.

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.
The Fixed-Reset index was added effective 2008-9-5 at that day’s closing value of 1,119.4 for the Fixed-Floater index.
Index Mean Current Yield (at bid) Mean YTW Mean Average Trading Value Mean Mod Dur (YTW) Issues Day’s Perf. Index Value
Ratchet N/A N/A N/A N/A 0 N/A N/A
Fixed-Floater 8.56% 8.74% 123,030 11.89 7 -6.8574% 615.9
Floater 9.92% 10.00% 87,719 9.59 2 -5.6942% 326.8
Op. Retract 5.59% 7.05% 161,126 4.12 15 -1.2140% 973,7
Split-Share 6.77% 12.78% 93,946 3.94 15 -0.6757% 910.4
Interest Bearing 10.04% 20.69% 58,158 2.65 3 -2.5488% 738.5
Perpetual-Premium N/A N/A N/A N/A N/A N/A N/A
Perpetual-Discount 8.12% 8.26% 234,276 11.15 71 -1.7264% 683.0
Fixed-Reset 6.03% 5.38% 1,185,392 13.83 18 -0.3100% 1,001.8
Major Price Changes
Issue Index Change Notes
BCE.PR.F FixFloat -12.7857%  
BAM.PR.J OpRet -12.1374% Now with a pre-tax bid-YTW of 17.40% based on a bid of 11.51 and a softMaturity 2018-3-30 at 25.00. Closing quote of 11.51-99, 1×10. Day’s range of 10.71-13.50 (!).
BCE.PR.S FixFloat -9.1544%  
BSD.PR.A InterestBearing (for now!) -9.0703% Asset coverage of 0.8-:1 as of December 12, according to Brookfield Funds. Now with a (currently dubious) yield of 26.12% based on a bid of 4.01 and a hardMaturity 2015-3-31 at (a currently dubious value of) 10.00. Closing quote of 4.01-10, 5×1. Day’s range of 4.00-41.
BAM.PR.K Floater -8.7019%  
BCE.PR.R FixFloat -8.6207%  
HSB.PR.D PerpetualDiscount -7.8125% Now with a pre-tax bid-YTW of 8.54% based on a bid of 14.75 and a limitMaturity. Closing quote 14.75-35, 6×5. Day’s range of 14.75-16.25.
BCE.PR.G FixFloat -7.1429%  
FBS.PR.B SplitShare -6.5772% Asset coverage of 1.1-:1 as of December 15 according to TD Securities. Now with a pre-tax bid-YTW of 18.59% based on a bid of 6.96 and a hardMaturity 2011-12-15 at 10.00. Closing quote of 6.96-20, 45×10. Day’s range of 6.90-35.
BCE.PR.I FixFloat -6.2676%  
BCE.PR.Z FixFloat -6.2500%  
POW.PR.D PerpetualDiscount -6.1856% Now with a pre-tax bid-YTW of 8.82% based on a bid of 14.56 and a limitMaturity. Closing quote 14.56-89, 4×4. Day’s range of 14.51-50.
BCE.PR.A FixFloat -5.9761%  
BAM.PR.H OpRet -5.8680% Now with a pre-tax bid-YTW of 14.89% based on a bid of 19.25 and a softMaturity 2012-3-30 at 25.00. Closing quote of 19.25-89, 2×5. Day’s range of 18.30-20.75 (!).
POW.PR.B PerpetualDiscount -5.4328% Now with a pre-tax bid-YTW of 8.67% based on a bid of 15.84 and a limitMaturity. Closing quote 15.84-09, 2×5. Day’s range of 15.75-16.80.
CM.PR.J PerpetualDiscount -5.1355% Now with a pre-tax bid-YTW of 8.6584% based on a bid of 13.30 and a limitMaturity. Closing quote 13.30-74, 15×15. Day’s range of 13.00-14.19.
Volume Highlights
Issue Index Volume Notes
RY.PR.N FixedReset 255,145 Royal bought 163,700 from National in five blocks at 26.00.
MFC.PR.A OpRet 173,150 Desjardins crossed 60,000 at 24.25; Nesbitt crossed 100,000 at the same price. Now with a pre-tax bid-YTW of 4.67% based on a bid of 24.19 and a softMaturity 2015-12-18 at 25.00.
BNS.PR.K PerpetualDiscount 129,905 TD crossed 100,000 at 16.00. Now with a pre-tax bid-YTW of 7.64% based on a bid of 16.02 and a limitMaturity.
RY.PR.I FixedReset 90,270 RBC crossed 19,700 at 22.00.
CM.PR.I PerpetualDiscount 88,372 Now with a pre-tax bid-YTW of 8.53% based on a bid of 14.10 and a limitMaturity.

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

Cleveland Fed Releases December "Economic Trends"

Thursday, December 18th, 2008

The Cleveland Fed has released the December issue of Economic Trends, with articles:

  • October Price Statistics
  • The Yield Curve, November 2008
  • Japan’s Quantitative Easing Policy
  • Industrial Production, Commodity Prices, and the Baltic Dry Index
  • GDP: Third Quarter Preliminary Estimate
  • The Employment Situation, October 2008
  • Metro-Area Differences in Home Price Indexes
  • Fourth District Employment Conditions, October 2008
  • Fourth District Community Banks

One table and one chart are of particular interest:

Deflation is always a possibility, but for now it looks like a simple unwind of the commodity boom.

Houses, ditto.

Cities like Miami, Los Angeles, San Diego, and Washington, D.C. all saw tremendous growth in home prices during the boom and have all subsequently seen massive declines in values. On the other hand, cities like Denver and Charlotte saw little to no unusual home price appreciation during the boom and have seen home prices decline only modestly during the bust.

More Theory on Bank Sub-Debt Spreads

Thursday, December 18th, 2008

Bank Sub-Debt has been in the news lately, with Deutsche Bank’s refusal to execute a pretend-maturity, and I have dug up another theoretical paper: What does the Yield on Subordinated Bank Debt Measure, by Urs W. Birchler (Swiss National Bank) & Diana Hancock (Federal Reserve):

We provide evidence that the yield spread on banks’ subordinated debt is not a good measure of bank risk. First, we use a model with heterogeneous investors in which subordinated debt is primarily held by investors with superior knowledge (i.e., the“informed investor hypothesis”). Subordinated debt, by definition, coexists with non-subordinated, or “senior,” debt. The yield spread on subordinated debt thus must not only compensate investors for expected risk (i.e., to satisfy their participation constraint), but also offer an “incentive premium” above a “fair” return to induce informed investors to prefer it to senior debt (i.e., to satisfy an incentive constraint). Second, we test the model using data we collected on the timing and pricing of public debt issues made by large U.S. banking organizations in the 1986-1999 period. Findings with respect to issuance decisions lend strong support for the informed investor hypothesis. But rival explanations for the use of subordinated debt, such as differences in investor risk aversionor such as the signaling of earnings prospects by the bank, are rejected.A sample selection model on observed issuance spreads provides evidence for the existence of the postulated subordinated incentive premium. In line with predictions from the model, the influence of sophisticated investors’ information on the subordinated yield spread became weaker after the introduction of prompt corrective actions and depositor preference regulatory reforms, while the influence of public risk perception grew stronger. Finally, our model explains some results from the empirical literature on subordinated debt spreads and from market interviews — such as limited spread sensitivity to bank specific-risk or of the “ballooning” of spreads in bad times.

The conclusions are consistent with those of other researchers.

There’s a good line in the discussion:

These results are consistent with the “informed investor hypothesis” that claims that banking organizations would issue debt of different priority status to separate investors with different, yet unobservable, beliefs on the probability of bank failure.

I claim that a good definition of an “informed investor”, suitable for ex ante assignment of investors into different groups is: “one who knows that there is a difference”. The authors would not, I think, disagree too violently with this definition:

Paradoxically, the quality of the subordinated debt spread to measure banking organizations’ risks as they are perceived by most sophisticated investors has deteriorated after the introduction of FDICIA or, more precisely, of depositor preference rules. With depositor preference rules, the risk characteristics of senior debt have become more similar to those of subordinated debt; at the same time, the subordinated debt spread has become (even) more dependent on factors influencing the senior spread.

The deterioration of the risk measurement quality of the subordinated spread after the introduction of depositor preference, however, is likely to understate the longer term virtues of the reform. Once senior debtors realize that their claims are subordinated to depositors, senior spreads may well more fully reflect specialist information. Therefore, we expect that senior debt will be held by more sophisticated investors in the future.

Assiduous Readers will remember that in my essay on Fixed-Reset Analysis I pointed out a very low spread between deposit notes and sub-debt in February 2007.

US Bank Deposits Increasing

Thursday, December 18th, 2008

The FDIC has released its December edition of the FDIC Quarterly, which contains an article on Highlights from the 2008 Summary of Deposits Data:

To better understand the industry’s level of expansion, it is useful to look at various measures of deposit and office growth in relation to demographic trends. For example, trends in deposit growth and population can be compared to the number of bank offices. As shown in Chart 2, banks continue to expand their retail presence at a faster pace than population growth at the national level. Both the number of offices per million people and the volume of deposits per office continue to increase. However, the pace of this growth is slowing. Indeed, the annual growth in both domestic deposits per office and offices per million people were below their respective five-year averages.

This will be another data point to support the thesis of Banks’ Advantage in Hedging Liquidity Risk.

Convertible Preferreds? In Canada?

Thursday, December 18th, 2008

Another hot tip from Assiduous Reader tobyone leads to more musings from Barry Critchley of the Financial Post:Flurry of Share Offerings:

And it seems OSFI is interested in other types of securities that would constitute Tier 1 capital. In yesterday’s column we mused the market was speculating that soft retractable pref shares — which used to count as Tier 1 capital before OSFI ruled to make them Tier 2 capital — would be on the list. The chance of such a return is low if issuers are talking about the former type of soft retractables. (OSFI ruled against them in part because of the potentially huge increase in common shares outstanding, in the rare event that the issuer opted to pay in stock and not cash.) However, if they come with new bells and whistles, then OSFI may be interested — but only after the security has undergone the normal review process. “Part of OSFI’s mandate is to see what they come up with and figure out if it works or not,” said the OSFI spokesperson.

One type of pref share that may cut the mustard is convertible pref shares.

An OSFI spokesperson said it would be interested in such a security counting as Tier 1 capital “if it had the right kind of features for capital. Convertibles is something that’s been floated. It has been discussed,” added the spokesperson, noting that issues of mandatory convertible prefs, are part of Tier 1 capital in some countries.

What else could OSFI be looking at?

Underwriters report that issuers would like an increase in the percentage of Tier 1 capital allocated to innovative instruments. Currently 15% of Tier 1 capital can be in the form of such securities. But that percentage hasn’t changed — despite the recent 10-percentage-point increase, to 40%, in the share of preferred shares in Tier 1 capital. (At the start of the year, the percentage was 25%, meaning a 15-percentage-point increase for the year.)

“Investors are more interested in taking the 15% stake up to 25% because the innovative Tier 1 market is an institutional market,” said one market participant, noting that the change would allow larger issues, certainly larger than issues of rate reset preferred shares which are largely bought by retail investors.

Mandatory convertibles have certain advantages for all issuers:

A relatively large proportion of convertibles are currently issued as mandatory convertibles. A mandatory convertible is automatically converted into equity at a specific maturity date, thus removing the optionality for the buyer of the convertible. The transfer of risk to the buyer is usually compensated by a higher yield. Companies want to issue mandatory
convertibles in order to avoid their experiences of 1999 and 2000, when many telecoms companies issued convertibles in the expectation that they would be converted into equity at the time of redemption. In most cases the conversion did not take place due to the sharp decline in equity prices, leaving them with much higher than expected debt/equity ratios. Another attractive feature for the issuer of mandatory convertibles is that they are in general not treated by the rating agencies as pure debt. The biggest mandatory convertible issues in the
first quarter of 2003 were a €2.3 billion offering by Deutsche Telekom and one of ¥345 billion ($2.9 billion) by Sumitomo Mitsui Financial Group.

As far as BIS is concerned, banking implications of convertible preferreds are (largely?) limited to the United States

Cumulative preference shares, having these characteristics, would be eligible for inclusion in [Tier 2]. In addition, the following are examples of instruments that may be eligible for inclusion: long-term preferred shares in Canada, titres participatifs and titres subordonnés à durée indéterminée in France, Genusscheine in Germany, perpetual subordinated debt and preference shares in the United Kingdom and mandatory convertible debt instruments in the United States.

… but I note a recent issuance by UBS:

At UBS, the government package provided significant relief to the balance sheet from the burden of illiquid positions particularly affected by the crisis. With this package, the SNB made it possible for UBS to transfer illiquid positions to a special purpose vehicle. The UBS provided this special purpose vehicle with equity amounting to USD 6 billion. The Confederation compensated UBS for the capital requirement arising for this purpose by subscribing to mandatory convertible notes (MCN). Since the announcement of the package, the UBS liquidity situation has stabilised.

The recent issue by Morgan Stanley gives an important clue as to the value of Convertible Preferreds in times of stress:

Under the revised terms of the transaction, MUFG has acquired $7.8 billion of perpetual non-cumulative convertible preferred stock with a 10 percent dividend and a conversion price of $25.25 per share, and $1.2 billion of perpetual non-cumulative non-convertible preferred stock with a 10 percent dividend.

Half of the convertible preferred stock automatically converts after one year into common stock when Morgan Stanley’s stock trades above 150 percent of the conversion price for a certain period and the other half converts on the same basis after year two. The non-convertible preferred stock is callable after year three at 110 percent of the purchase price.

With other examples from Citigroup, we may conclude that Convertible Preferreds can be very useful in times when the common dividend is in doubt, or is otherwise thought to be insufficient for the risk of holding the common.

The Federal Reserve allows inclusion of convertible preferreds in Tier 1 in a manner analogous to the Canadian treatment of perpetuals:

The Board has also decided to exempt qualifying mandatory convertible preferred securities from the 15 percent tier 1 capital sub-limit applicable to internationally active BHCs. Accordingly, under the final rule, the aggregate amount of restricted core capital elements (excluding mandatory convertible preferred securities) that an internationally active BHC may include in tier 1 capital must not exceed the 15 percent limit applicable to such BHCs, whereas the aggregate amount of restricted core capital elements (including mandatory convertible preferred securities) that an internationally active BHC may include in tier 1 capital must not exceed the 25 percent limit applicable to all BHCs.

Qualifying mandatory convertible preferred securities generally consist of the joint issuance by a BHC to investors of trust preferred securities and a forward purchase contract, which the investors fully collateralize with the securities, that obligates the investors to purchase a fixed amount of the BHC’s common stock, generally in three years. Typically, prior to exercise of the purchase contract in three years, the trust preferred securities are remarketed by the initial investors to new investors and the cash proceeds are used to satisfy the initial investors’ obligation to buy the BHC’s common stock. The common stock replaces the initial trust preferred securities as a component of the BHC’s tier 1 capital, and the remarketed trust preferred securities are excluded from the BHC’s regulatory capital [footnote].

Allowing internationally active BHCs to include these instruments in tier 1 capital above the 15 percent sub-limit (but subject to the 25 percent sub-limit) is prudential and consistent with safety and soundness. These securities provide a source of capital that is generally superior to other restricted core capital elements because they are effectively replaced by common stock, the highest form of tier 1 capital, within a few years of issuance. The high quality of these instruments is indicated by the rating agencies’ assignment of greater equity strength to mandatory convertible trust preferred securities than to cumulative or noncumulative perpetual preferred stock, even though mandatory convertible preferred securities, unlike perpetual preferred securities, are not included in GAAP equity until the common stock is issued.

Nonetheless, organizations wishing to issue such instruments are cautioned to have their structure reviewed by the Federal Reserve prior to issuance to ensure that they do not contain features that detract from its high capital quality.

Footnote: The reasons for this exclusion include the fact that the terms of the remarketed securities frequently are changed to shorten the maturity of the securities and include more debt-like features in the securities, thereby no longer meeting the characteristics for capital instruments includable in regulatory capital.

Section 4060.3.9.1 of the Fed’s Bank Holding Company Supervision Manual extends this treatment to convertible preferreds that convert to perpetual non-cumulative preferreds.

I have no problem from a public policy perspective of allowing the inclusion of Convertible Preferreds into Tier 1 capital, provided they meet the basic requirements of subordination and the potential for having their income suspended on a non-cumulative basis without recourse for the holders.

If such are issued, however, they will almost certainly not be included in the HIMIPref™ database, as there is considerable potential for such issues to “sell off the stock”. In fact, I would consider such issues – in the absence of even more innovation – to be equivalent to common stock with a bonus dividend; not fixed income at all.

I have a much bigger problem with the second proposal in Mr. Critchley’s column – the expansion of the Innovative Tier 1 limit to 25% from its current 15%. I will not accept that further debasement of bank credit quality is justified by prior debasement; let’s see a little more analysis and stress-testing than that!