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The business models of large interconnected banks and the lessons - - PowerPoint PPT Presentation

The business models of large interconnected banks and the lessons from the financial crisis Adrian Blundell-Wignall, Paul Atkinson and Caroline Roulet (OECD) ESRC/NIESR conference Financial Structure: Fine Tuning or Radical Reform?


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The business models of large interconnected banks and the lessons from the financial crisis

Adrian Blundell-Wignall, Paul Atkinson and Caroline Roulet (OECD)

ESRC/NIESR conference “Financial Structure: Fine Tuning or Radical Reform?” London, 22 February 2013

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3 main lessons from the crisis

  • The system is too interconnected with too many

banks that cannot be allowed to collapse. This creates an “implicit guarantee” which cannot credibly be denied and encourages high-risk behavior.

  • There is too little capital and too much leverage in

the system. Local problems too quickly become systemic.

  • There are too many perverse incentives. Better

governance arrangements are needed.

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The major issues are the GSIFIs and how to regulate them

Not to ignore macro issues or structural policy failures. Crisis has been a “perfect storm”, with many separate driving forces converging and interacting. But GSIFIs are at the top of the financial food chain:

  • Dominant in interbank market
  • Derivatives trading
  • Prime broker activities
  • Central to originate-to -distribute chains

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Focus on derivatives

Trading, mostly OTC, dominated by a handful of huge US and European banks . Major source of leverage:

  • Up-front fees and small cash payments can support very

large exposures.

  • These enable sophisticated structuring of tax-effective

products which generate fee income. Fee income drives activity.

  • Re-hypothecation of collateral (more about this later)

allows leverage to be multiplied.

  • Derivatives facilitate arbitrage of Basel capital rules.

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How big is the derivative mountain?

Notional value of derivatives and primary securities worldwide

(per cent of world GDP)

5 0.0 2.0 4.0 6.0 8.0 10.0 12.0 14.0 16.0 18.0

Total Primary Securities Derivatives

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But notional values exaggerate. Other measures are much smaller

  • Settlement exposure, i.e. gross market value

(GMV), can be tiny in comparison: $16 tn or 2.7% of $586 tn notional at end-2007.

  • Banks hedge most of their positions.
  • Most exposure is with a small number of

counterparties and for many purposes banks can reasonably net these positions.

  • So gross credit exposure (GCE), i.e. non-netted

GMV, is smaller still.

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Gross market value of derivatives, netting and gross credit exposure

7 5000 10000 15000 20000 25000 30000 35000 40000 Jun-98 Mar-99 Dec-99 Sep-00 Jun-01 Mar-02 Dec-02 Sep-03 Jun-04 Mar-05 Dec-05 Sep-06 Jun-07 Mar-08 Dec-08 Sep-09 Jun-10 Mar-11 Dec-11 Sep-12 $bn Gross Mkt Value OTC GCE Netting

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Even valued at GMV derivatives can dominate GSIFI balance sheets (1)

The case of Deutsche Bank

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Balance sheet at year-end 2008 on IFRS (no "netting") and GAAP (with "netting") bases (billion euros) Accounting system IFRS GAAP Difference: IFRS and GAAP Trading account assets

  • /w

Derivatives 1224.5 128 1096.5 Non-derivative trading assets 247.5 247.5 Reverse repos and borrowed sec. 168 161 7 Net loans 269.3 269.3 Brokerage, sec-related receivables 104.1 35.1 69 Other assets* 189 189.1 Total assets 2202.4 1030 1172.4 n.a. not available, I.e. sources' presentations differ. *Includes cash; near-cash; land, prop. and equip.; intangibles; and other as well as unidentified items.

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Even valued at GMV derivatives can dominate balance sheets (2)

The case of 6 US mega-banks

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Total Assets, end-Q3 2012 ($ billion) GAAP basis IFRS-adjusted BAML 2166 3578 Citigroup 1931 2945 GS 949 1748 JPMChase 2321 3966 MS 765 1738 WFC 1375 1439 Source: Bank reports, authors' calculations

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GMV is not a measure of market risk

  • Derivatives are contracts that normally trade
  • n margins collateralized mainly by cash.
  • Price movements in reference securities are

reflected in GMVs of derivatives.

  • Given the effective leverage, derivative price

movements can be huge.

  • Essential point: netting, which is about

settlement amounts at close-out prices, does nothing to protect against market risk.

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Simple derivative interactions

4 period model for CDS, annual survival probabilities considered are 95%, 90%, 70%, 30%. Valuation assumptions: Recovery rate 50% Discount rate 6% Premium 4% Notional contract of EUR 100 million

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Notional €100m Probability of Default (& 50% Recovery Rate) After 4 Periods 0.99 €45.2m 0.76 €33.3m 0.34 €11.7m 0.19 €4.6m

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Price movements are not trivial

Deutsche Bank asset position, end year

(EUR billion)

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2005 2006 2007 2008 2009 Trading account assets 448.4 1104.7 1378.0 1623.8 965.3 Other assets 543.7 479.8 547.0 578.6 535.4 Total assets 992.1 1584.5 1925.0 2202.4 1500.7

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Consequences: collateral and margin calls

  • Derivatives are risk-transfer instruments

whose price movements are zero-sum.

  • Price movements generate both winners and

losers.

  • When prices move, losing parties typically

have to meet margin or collateral calls by their winning counterparties.

  • These can require large dollar-for-dollar

payments in cash or securities at short notice.

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Global overview: gross credit exposure (GCE) and collateral for derivatives

14 1000 2000 3000 4000 5000 6000 Jun-98 Mar-99 Dec-99 Sep-00 Jun-01 Mar-02 Dec-02 Sep-03 Jun-04 Mar-05 Dec-05 Sep-06 Jun-07 Mar-08 Dec-08 Sep-09 Jun-10 Mar-11 Dec-11 Sep-12 $bn Collateral Gross Credit Exposure

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Systemic implications (1)

  • Re-hypothecation: practice of reusing

collateral that has been transferred contractually for new derivative trades.

  • This is common. ISDA puts it at more than

90% for the (predominant) cash portion.

  • Where banks are well-hedged as market

values move, gains will match losses. With re- hypothecation normal cash calls can be absorbed smoothly.

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Systemic implications (2)

  • Where hedging is imperfect, large net winners

and losers emerge.

  • Losers face large net cash calls.
  • Q. Where do losers find the cash once collateral is

no longer being re-hypothecated to them?

  • A. Interbank market (incl. non-bank GSIFI winners)
  • r the central bank.

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Systemic implications (3)

  • Who will lend? Market price movements have

implication for balance sheets. Issue is not just liquidity.

  • Net losers facing huge cash demands have

potentially large balance sheet holes making them unattractive credit risk.

  • Perceptions are important here. Lack of

transparency can lead to defensive behavior.

  • So pressure on central banks become intense.
  • Without support, collapse is inevitable.

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Epicenter of crisis 2008: Fed payouts to AIG counterparties

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Institution Collateral postings for credit default swapsa) Payments to securities lending counterpatiesb) Total As a share of capitalc) at end- 2008 Goldman Sachs 8.1 4.8 12.9 29.1% Société Générale 11 0.9 11.9 28.9% Deutsche Bank 5.4 6.4 11.9 37.4% Barclays 1.5 7 8.5 20.0% Merrill Lynch 4.9 1.9 6.8 77.4% Bank of America 0.7 4.5 5.2 9.1% UBS 3.3 1.7 5 25.2% BNP Paribas … 4.9 4.9 8.3% HSBC 0.2 3.3 3.5 5.3% [memo: Bank of America after its merger with Merrill Lynch] 12 [18.1%]

a) Direct payments from AIG through end-2008 plus payments by Maiden Lane III, a financing entity established by AIG & the New York federal reserve Bank to purchase underlying securities. b) September 18 to December 12, 2008. c) Common equity net of goodw ill; net of all intangible assets for Merrill Lynch and HSBC.

In USD billion

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Most recent GSIFI collapse: Dexia

  • Summer 2011, sharp fall in long term interest

rates led to a EUR 15 billion cash collateral call.

  • Downgrade by Moody’s 3 October, unsecured

funding and deposit drain.

  • Increased resort to ECB, rescue by Belgium,

France and Luxembourg governments 10 October.

  • Losses for 2011 amounted to EUR 11.6 billion,

wiping out its net worth.

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Going forward: 2 obvious concerns

Collateral and central bank money

  • 1. Can the ocean of

central bank money safely be removed?

  • 2. Basel 3 high quality

liquid assets (to meet LCR) must be unencumbered except during “stress”. Cash for LCR cannot be used as collateral.

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  • 1000

1000 2000 3000 4000 5000 6000 7000 0.0 0.2 0.4 0.6 0.8 1.0 1.2 Jun-98 Mar-99 Dec-99 Sep-00 Jun-01 Mar-02 Dec-02 Sep-03 Jun-04 Mar-05 Dec-05 Sep-06 Jun-07 Mar-08 Dec-08 Sep-09 Jun-10 Mar-11 Dec-11 Sep-12 $bn Ratio Collateral/Cash GCE net of Collateral RHS

  • Cent. Bank Cash RHS
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What needs to be done?

  • Simplify the system
  • Insist on meaningful capital levels in banks

and other regulated financial institutions

  • Find ways to minimize or eliminate the implicit

guarantee in order to end TBTF

  • Strengthen incentive structures and improve

governance of banks

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Simplify Ratio of RWA/TA for GSIFIs

  • Basel is too complex

(c.f. Haldane, Jackson Hole). Regulatory arbitrage defeats purpose of capital rules. Derivatives play a major role.

  • Tax complexity invites

arbitrage via structuring

  • f products

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30.0 35.0 40.0 45.0 50.0 55.0 60.0 Mar/04 Aug/04 Jan/05 Jun/05 Nov/05 Apr/06 Sep/06 Feb/07 Jul/07 Dec/07 May/08 Oct/08 Mar/09 Aug/09 Jan/10 Jun/10 Nov/10 Apr/11 Sep/11 Feb/12 % Europe GSIFI's UK GSIFI's USA: C,BAC,JPM

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Insist on meaningful capital levels

  • Given scope for arbitraging Basel required regulatory

ratios achieve little.

  • Simplest way around this is a leverage ratio.
  • Set a minimum for an all-equity measure of capital –

Basel 3 Core tier 1 is fine – as a share of total assets (net of goodwill).

  • Use IFRS accounting for derivatives.
  • US FDIC 5% “well capitalized” standard, implying

leverage of equity as high as 20, seems like a minimum.

  • Could look for ways to reward diversification.

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Equity (net of goodwill) to total asset ratios, end 2008 and 2011

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0.00 1.00 2.00 3.00 4.00 5.00 6.00 7.00 8.00 9.00

BAC CITI JPM WFC CS UBS DBK CBK UCG ISP SAN BBVA BPOP SAB BNP SGE ACA BARC RBS HSBC LLOYD

Equity/TA (%) Equity/TA Q4 2011 Equity/TA Q4 2008 5% Equity Ratio

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Ending the implicit guarantee and TBTF

Requires changing business models

  • Privilege separating retail banking form

investment banking, notably OTC derivative trading.

  • Various proposals on the table: Volcker, Vickers,

Liikanen.

  • We favor an NOHC structure, much in common

with Vickers. Avoids restrictions on competition, while ending cross-subsidization of capital costs for derivatives trading.

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Other elements:

  • Where guarantees cannot be avoided, make

them explicit and fund them.

  • Begin prompt corrective action at an early

stage, while banks are still solvent.

  • Design effective resolution regimes.
  • Allow some large creditors to lose some

money when they make mistakes

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Incentive structures and governance

  • Find alternatives to “issuer pays” model for auditors

and rating agencies.

  • Assure independence of Boards acting in shareholders’

interest: separate roles of Chairman and CEO; no role for CEO in choosing Board members.

  • Chief risk officer to have direct access to Board,

independence from CEO.

  • Transparent compensation arrangements for mgt.

based on long-term performance

  • Clearly-defined fiduciary duties for Board members,

without multiple- or cross-directorships.

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Thank you for your attention. [Author contacts: adrian.blundell- wignall@oecd.org; patkinson@noos.fr; caroline.roulet@oecd.org .]

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