Footnotes

 

1.      The authors said it; we didn’t. This paper is associated with Dexia, a Belgian-French financial group that had to be recapitalized with state funds. The recapitalization was partly caused by residential real estate problems in Germany.

 

2.      Here is the problematic assumption, “…we can take the implicit approach by using market observable information (our emphasis) such as asset swap spreads or risky corporate bond prices.”

 

3.      Derivatives Week; “Empirical Asset Correlations”;  July 1, 2005; https://www.derivativesweek.com/Article/1251277/Empirical_Asset_Correlations.html

 

4.      In a 8/07 study of structured finance at the ratings agencies, the SEC found:

a) None of the agencies had specific written procedures for rating RMBS (subprime residential mortgage securities) and CDOs (collateralized debt obligations). The structured finance ratings process was "inherently flexible and subjective." At one firm, an analyst expressed the opinion that the ratings model did not capture "half" of a deal's risk. This, we might add, was for investments that were sold as being precise and scientific. An analytic manager wrote, "the rating agencies continue to create an even bigger monster-the CDO market. Let's hope we are all wealthy and retired by the time this house of cards falters.'"

b) The ratings agencies made "out of model adjustments" (guess in what direction) and did not document the rationales for these adjustments.

c) The ratings agencies do not appear to have specific policies to identify or address errors in their models or methodologies.

d) The SEC could not "assess compliance with ...established policies and procedures, and to identify the factors that were considered in developing a particular rating....There was also a lack of documentation of ratings committee actions or decisions...there was sometimes no documentation of committee attendees."

e) One agency allowed their senior analytical managers to discuss fees with issuers.

f) Since the arranger often designs the deal, he has the flexibility to adjust deal structure to obtain a desired credit rating, as compared to arrangers of non-structured assets...arrangers that underwrite (structured finance) offerings have substantial influence over the choice of rating agencies hired to rate the deals." The structure of the deal determines the price of the package, and thus its profits.

g) The actual ratings models used were incredibly complex. “while RMBS default probability and loss severity…models required 50 to 60 (sic) inputs, CDO models required only five inputs: current credit rating (of RMBS securities), maturity, asset type, country, and industry. “ Unfortunately the CDO models used credit ratings derived from the CLO models we discuss here.

 

5.       George Soros writes, “Starting around 2005, securitization became a mania. It was easy and fast to create ‘synthetic’ securities that mimicked the risks of real securities but did not carry the expense of buying and assembling actual loans. Risky paper could therefore be multiplied well beyond the actual supply in the market. Enterprising investment banks sliced up CDOs and repackaged them into CDOs of CDOs, or CDO2. There were even CDO3…In this way more AAA liabilities were created than there were AAA assets. Towards the end, synthetic products accounted for more than half the trading volume.”

 

Soros, George; “The New Paradigm for Financial Markets; Public Affairs (2008), p.p. xviii-xix.

 

 

6.      Since actual bank loans usually don’t meet the latter two criteria perfectly, lending is about taking intelligent risks. But bankers should never approve loans that they don’t realistically think will be repaid. The statistical models underlying structured finance, however, assume that loan defaults will occur as an abstract law of nature.

     

      On a 1/13/10 PBS broadcast, former mortgage banker Mary Tootikian said that house mortgage underwriting standards began dropping in 2000, finally becoming “non-existent.” Currently problematic mortgage products, such as stated income loans, were niche products; designed to make credit available (probably at sky-high interest rates) to borrowers that had a large amount of equity in their existing homes. These products were made widely available to purchasers with no equity in their homes, the fatal argument being that home prices could only appreciate and the debt could be refinanced if it proved onerous.

 

      Pending congressional inquiries promise to discover fraud and incompetence in the retail housing market. But what about the smaller commercial real estate market; where buyers, sellers, and lenders are informed professionals? Yet, as detailed in an excellent January 2010 Atlantic article, buyers and lenders made the same mistake. The fatal assumption by both the retail and commercial markets in their models was G, an assumed perpetual growth in house prices or rent rolls as the real estate mania rolled on. The article estimates that $250 billion in commercial property loans have to be refinanced over the next few years, with asset values collapsing. At least the documentation in the commercial case was better. 

 

     

7.     Reinhart and Rogoff list sixteen bank crises in high-income countries between 1970 and 2008, about one every 2.4 years. Banking crises are not uncommon because banks borrow short and lend long, depending upon public confidence in their stabilities.

 

Reinhart and Rogoff, “This Time It’s Different”; Princeton University Press (2009); Table A.3.1.

 

8.      Tilman, Leo; “Financial Darwinism”; John Wiley & Sons (2009); p. 126.

 

 

9.      In the notable Chapter 12 of “The General Theory,” Keynes (1935) wrote:

 

In the absence of security markets, there is no object in frequently attempting to revalue an investment to which we are committed. But the Stock Exchange revalues many investments every day and the revaluations give a frequent opportunity to the individual (though not to the community as a whole) to revise his commitments….  

 

Of the maxims of orthodox finance none, surely, is more anti-social than the fetish of liquidity, the doctrine that it is a positive virtue on the part of investment institutions to concentrate their resources upon the holding of “liquid” securities. It forgets that there is no such thing as liquidity of investment for the community as a whole. 

                        

                    Keynes, J.M.; “The General Theory (1935)”; Harcourt Brace (ed) 1964; 

                     p.p. 151, 155.

 

 

10.  Kaufman, Henry; “The Road to Financial Reformation”; John Wiley & Sons (2009); p. 196.

 

 

11.  Madison, James; “The Federalist No. 51”;   https://www.constitution.org/fed/federa51.htm

 

12.  Financial Services Authority; “Turner Review Conference Discussion Paper,”  p. 26.

 

Mervyn King, Governor of the Bank of England; stated, in our opinion, the definitive view:

    

       

The belief that appropriate regulation can ensure that speculative activities do not result in failures is a delusion.

 

…the implicit government guarantee means that the true cost of …maturity mismatch does not, as it should, fall on those who receive the benefits. The aim of policy should be to minimize or eliminate that subsidy. Separation of activities (does not hinder) that objective, not least because it is the mixture of activities that reduces the robustness of the system (our emphasis).

 

                                                            Speech to Scottish business organizations; October 20, 2009.

 

 

Mr. King says that the government should separate public utility banking from the rest, and not subsidize the latter with guarantees.

 

 

 

 

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