Category: Public Policy

Central Bank Independence is Overrated

Central Bank Independence is Overrated

Central Banks, should they exist, should be able to do what is right for monetary policy, which includes regulation of credit.? In a fiat money world, where credit exists as electronic entries, credit is money.

But wait, what if central bank independence is compromised from within?? What if voluntarily becomes the lap dog of the President, Treasury, or Congress?

It takes a bold man to stand up to the powers that be, and the Fed has had its share of them.? Marriner Eccles opposed Truman.? William McChesney Martin, Jr. stood up to Presidents and Congress for his long term as Chairman.? Paul Volcker blew cigar smoke at representatives and Senators as he restored sound money to the US amid screams of pain in the economy.

Central bank independence doesn’t mean squat unless the central bank uses it!

In the name of independence, for fear that the President or Congress would restrict the central bank, many Fed Chairmen have given in to the powers that be:

  • Ben Bernanke, rescued entities that he should not have rescued, and established lending programs that use the national credit to benefit a minority of participants.? These actions should have been taken by Congress, if done at all, so that the voters could decide whether it was right to do it or not.? Bernanke validates the idea that the government keeps the Fed around to do what it cannot do constitutionally.
  • Alan Greenspan threw liquidity at every little and big problem, and was slow to withdraw liquidity, pushing the US slowly but surely into a liquidity trap, which Ben Bernanke was saddled with.
  • G. William Miller and Arthur F. Burns, who facilitated the inflation of the ’70s, at the behest of Nixon and Carter.
  • Daniel R. Crissinger and Roy A. Young, who facilitated the loose monetary policy of the ’20s.

Central bank independence means risking your own tenure for the good of the institution.? Marriner Eccles and Paul Volcker did not get reappointed because they offended the President.??? Central bank independence does not mean compromising in order to protect against micromanagement.? Independence means being a man, and telling the President and congressmen that you will do what is right to preserve sound money, regardless of the consequences.

The Fed as Systemic Risk Regulator

I have suggested in the past that the Fed should regulate systemic risk as an aspect of its mandate only because they are the biggest creator of systemic risk through loose monetary policy.? I am not suggesting this on the basis of competence — that is ridiculous.? But on the basis of modifying the behavior of the Fed to make it more resistant to loosening rates early because of systemic risk concerns — that makes sense, because it will increase the emphasis on a sound currency.

Now, many economists are pleading with Congress to be gentle on the Fed because an independent Fed is critical to sound economic policy.? That would be true if the Fed were willing to take politically unpopular actions that were in the best interests of the economy.? Sadly, that is not true of the present Fed.? They do what the politicians want, and give the politicians cover, because the politicians can point at the Fed as the actor, via the rubric of “Central Bank independence.”

I say that the Fed needs more accountability and transparency to Congress, and ultimately to the American.? The quasi-public, quasi-private nature of the Fed needs to be changed to public or private.? Section 13.3 of the Federal Reserve Act, which allowed for the most egregious bailout actions, should be repealed. If bailouts need to be done, let Congress do them, and let them take the heat for their actions.

Not only should the Fed be audited as any large public or private organization, but if they are a public organization they should respond to the FOIA requests from major news organizations (Bloomberg, Fox Business, etc.) without hiding behind technicalities of protecting business secrets.? The insurance industry regularly reveals detailed data on their operating companies, with little seeming harm.? The banks can afford to do the same.

Power without accountability should be foreign to our republican form of government.? Control of our currency rightfully belongs to Congress, and Congress should tighten controls on the Fed so that its degree of independence is limited to the ordinary matters pertaining to a central bank — preserving the soundness of the currency.? Its competence there has been limited; but hey, at least focus on the basics would restore confidence in an institution that no longer has the confidence of the American people.

“Central Bank independence” is a nice phrase, but to the economists who petitioned Congress to preserve the status quo, I would simply ask this: How and from what should the central bank be independent?? To whom and in what ways should it be accountable?

Goldman?s Gain, America?s Risk?

Goldman?s Gain, America?s Risk?

Today I was featured at the New York Times “Room for Debate” blog, along with five others more notable than me.

The question was “about Goldman’s compensation pool, which will be? $11.36 billion (set aside) for the first half of 2009 (working out to about $386,429, on average, for each of the roughly 29,400 employees and?temps).

The average reader may be?perplexed?about huge bonuses making such a comeback.We’re asking?various economists,?whether it’s reasonable to be critical of this kind of payday at Goldman when the rest of the economy is still floundering? Or is this a sign that the?financial industry is stabilizing and?the federal government’s aid is doing what we want it to do?”

Word limit was 300.? I had more to say, because if you’ve read me for any length of time, you know that I am no fan of government intervention.? I was against the bailout from the start, preferring Resolution Trust-style solutions.

My view is that Goldman would have survived on its own without the bailout, though it would have scraped by.? That said, absent the bailout, Goldman might have ended up being a near-monopoly.? Bank of America would be gone, as would Citi, and Wachovia. Wells Fargo, JP Morgan and Morgan Stanley would be question marks.? The amount of increased pricing power to the remaining investment banks would be even larger than it is today.

Most of the government programs Goldman Sachs benefited from were available to many institutions of their size and class.? The government took the risk that some of the money would be used by healthy firms to make more money, in order to prevent panic regarding firms that needed the money to survive.? Other money, like the TARP, was forced on Goldman.

Does this mean I don’t think that Wall Street (and thus Goldman) has too much influence on government policy?? No, I believe that the US Treasury has been captured by those that regulate them.? This includes Pimco and Blackrock, who finance the government, and the investment banks, who try to profit from government policy.? There are too many appointees in high positions at the Treasury and Fed coming from firms that seek to influence the US government.

I don’t fault Goldman for its actions; they are a profit-seeking firm, and a very good one.? I fault our government for intervening where they should not have done it.

Let the bonuses be paid, why should the employees of Goldman be held responsible for the errors of the US Government?? That is water under the bridge.? Let us move on and try to make future government policy better (less interventionist).

PS — does that mean we shouldn’t investigate Goldman Sachs to see if they aren’t front running the market with their high frequency trading?? No, that’s worth looking into, but such an investigation would need some deeply smart people to be able to understand what is going on.

To Control Bubbles, the Fed Must First Control Itself

To Control Bubbles, the Fed Must First Control Itself

I’ve written before about the Fed’s de facto triple mandate:

  1. Low goods-price inflation.
  2. Low labor unemployment.
  3. Protect the financial system in a crisis.

Number 3 is the implicit obligation of the Fed, for several reasons:

  • The Fed carries out monetary policy (in ordinary times) through the banks.
  • Banks in the Federal Reserve System have close ties to the regional Federal Reserve Banks.
  • Bankers and those sympathetic to bankers comprise a large portion of the leadership and staff of the Federal Reserve.
  • Regulating banks gives jobs to many at the Fed.

Stepping back, let me tell you a story.? In the mid-90s, I became worried about inflation going out of control again, given the degree of monetary growth that I saw.? I’m not sure where I got the idea, but eventually it struck me that in the ’70s, when inflation was running hot, we had a lot of spenders and few savers.? In the ’90s, more savers and fewer spenders.? (You have to add in agents of the baby boomers, including the defined benefit plans, and the growth in 401(k)s, and products like them.)? Goods weren’t inflating from excess money, assets were being inflated as the baby boomers were socking away funds for retirement.

(Note to stock investors: be wary when market P/Es rise dramatically — there are limits to what is reasonable in P/Es for any level of corporate bond yields.? This applies to price-to-book and -sales ratios as well.)

As one more example of how monetary policy affects the asset markets, consider how the Fed temporarily flooded the banks with liquidity to avert problems regarding Y2K, and the stock markets reacted to the excess liquidity with a two month lag.? The Fed helped put in the top of the tech bubble.? I don’t know how the money leaked out of the banks to the stock market, but excess reserves under good conditions will produce loans.

Thus, I came to the conclusion that the Fed ought to look at asset inflation as well as goods inflation somewhere in the late ’90s.? But doesn’t the implicit third mandate cover that?? Alas, no, the third mandate is reactive, not proactive.? It kicks in after a crisis hits — Greenspan then floods the market with liquidity, and only steps back when things are running hot again.

A proactive policy would limit the degree of easing that the FOMC could do — once the spread of ten-year Treasuries over two-year Treasuries exceeds 1%, all easing would stop.? The banks can easily make money with a yield curve that steep… not much money, but enough to keep them alive (the financial sector would shrink under these rules).? There would be a second rule that when he spread of ten-year Treasuries over two-year Treasuries is less than 0%, all tightening would stop.? During times of extreme inflation or unemployment, these rules could be waived by Congress for a year at a time.? But that lays the policy back at the door of Congress, which represents the people and the states, where the decision belongs.

A policy like this eliminates the risk that the Fed can steepen the yield curve dramatically, leading to bubble creation — the excess credit has to go somewhere.? Another limit on the Fed could be a limit on total leverage in the economy — above a certain limit, such as 2x GDP, the Fed raises the Fed funds rate, regardless of the unemployment situation, until indebtedness falls.

Bubbles are financing phenomena.? Controlling bubbles can be done by controlling credit, and that is what the Fed tries to do — control credit, which is money in our era.? (Until we go back to something better, and get the government out of the money business — some sort of commodity standard.)

The present Fed holding action inflates assets not goods.? By offering financing to asset markets that are in disarray, it supports asset prices.? For now, none of that balance sheet expansion leaks out to the general public, and thus, little goods inflation.? But also, little true stimulus.

In short, the Fed should limit its powers to reliquefy the economy, because sloppy efforts in the past 25 years produced the popped bubbles that we are now dealing with.? Better to leave policy tight longer, and not loosen so much in troubles.? Don’t worry, we might have to wait longer for recovery, but the recoveries will be sounder when they come.

Parting Shots

Sorry, Doctor Shiller, not Everything can be Hedged

Sorry, Doctor Shiller, not Everything can be Hedged

Many people don’t think through questions systematically.? That includes very bright people like Dr. Robert Shiller, who said in this article in Fortune, “We should be able to hedge everything from the rising costs of health care and education to national income risk and oil crises.”

Ugh.? And this from an esteemed professor at a significant university?? And one with which I have sometimes agreed?

I’ve written about this before in some of my market structure articles, where I tried to dig into the difference between natural, hedging, and gambling exposures.? I’ll use an ordinary example to illustrate this: the bankruptcy of IBM.

I use IBM as an example because it is so unlikely to go under.? But who would be directly affected if IBM went under?

  • Stockholders, both preferred and common
  • Bondholders
  • Banks that have loaned money
  • Trade creditors
  • Workers

Let’s talk about the bondholders.? They could buy protection via credit default swaps [CDS] to hedge their potential losses.? In order for that to happen a new class of risk-takers has to emerge that wants to take IBM credit risk, that don’t own the bonds already.? It’s not always true, depending on the specualtive nature of the market (and synthetic CDO activity), but one would suspect that those that want to take on the risk of a default of IBM would only do it at a concession to current market bond pricing, or else they would buy the bonds and pay fixed, receive floating on a swap.

But often the amount of CDS created exceeds the amount of debt covered.? I’m not suggesting that everyone owning bonds has hedged, either, but when the amount of CDS exceeds outstanding bonds, that means there is gambling going on, because it means that there are market players that are not long the bonds that are taking the side of the trade where they receive income in the short-run if the company survives, and pay if the company fails.

I call this a gambling market, because there are parties where the transaction takes place where neither has a relationship to the underlying assets.? There is no risk transfer, but only a bet.? My view is such gambling should be illegal, but I am in a minority on such points.

Now think about another asset: my house.? Aside from being somewhat dumpy, beaten-up by my eight kids, the house has a virtue — I live in it free and clear, with no debts to anyone, so long as I pay my property taxes.? So what is there to hedge here?? I’m not sure, maybe future property taxes?

Aside from the county, and my insurance company, I’m not sure who has a real interest in my house.? If I knew that there were many people betting on the value of my house, I might become concerned.? What actions might people take against me in bad or good times?

But maybe no one would have interest in my house.? It’s just one house, after all.? Who would have a concentrated enough interest in it to wager on it?

Now, some would say, we don’t have an interest in your house specifically, but we do have an interest in houses on average? in your area.? That’s fine, but there is no one with a natural exposure to all of the houses in my area, aside from the county itself.

This is why I think that most real estate derivatives involve gambling.? There is no significant natural exposure hedged.? It is only a betting market.

And such it would be for most real assets.? Few would want to create markets where the owner know more than they do, or, where there a few options for gaining control if things go bad.

At the end of the day, all of the assets of our world are owned 100%.? Everything else is a side-bet.? Personally, I would argue that the side bets should be prosecuted and eliminated, which would bring greater stability to the economic system.? No tail chasing the dog.? Let derivative transactions go on where here is real hedging taking place; away from that, such transactions are gambling, and should be illegal.

To Dr. Shiller, many markets are thin.? The concept that everything can be hedged assumes deep markets everywhere, which is not the case.? Time for you to step outside the university bubble and taste the real world.? It’s not as hedgeable as you might imagine.

It Takes Two to Tango

It Takes Two to Tango

For every buyer there is a seller.? For every debit, there is a credit.

People often accept naive views of how the market works, perhaps considering how their own life seems to work, and not considering? the other side of the trade.? As an example, aside from laziness, why do market observers report a day where the market goes down on no significant news as “profit taking,” or grab at some lame smaller story which couldn’t explain the decline?? For every seller, there is a buyer.? No money went into or out of the market unless there was a new IPO, rights offering, company sale for cash, buyback, cash dividend, etc.? People don’t run away from or run to the market; only the terms of the tradew change at the margin.

The same applies to current account deficits.? They have to get funded from somewhere, and on unfavorable terms to the lender if the borrower happens to be the world’s reserve currency.

Thus, when I consider arguments over whether America is to blame for its profligate ways, or whether those that funded the deficits are to blame, I simply say that the books have to balance.? Neither is to blame; both are to blame.

It is not as if China has free capital markets.? Given their neomercantilism (uneconomic export promotion), they had to find places where their exports would be accepted.? The answer was the US.? After that, what do their banks do with excess dollars?? They buy fixed income dollar assets, which they foolishly think will preserve value until they need to liquidate the assets for goods or services of some sort.

That recycling of the current account deficit forced rates lower in the US while the Fed was tightening.? For the Fed to have fought that influence, they should have tightened more rapidly, compared to the plodding 1/4% each FOMC meeting.? How often have mortgage interest rates fallen while the Fed is tightening?? Not often, which is why the Fed was impotent during the last tightening cycle.? It is also why the blows hitting the global economy have fallen more lightly on the US.? To the extent that foreigners buy our bonds denominated in dollars, that transfers a part of the pain to them.? Thanks, but you could have avoided our pain had you opened your markets to our goods and services.

There are many efforts in play to try to replace the dollar.? Most if not all will fail.? At present, the US is politically secure in ways the other large currencies are not, and many invest in the US not to preserve full value, but to preserve most of the value, whatever that may be.

As with many things in life — it takes two to tango.? Blame is infrequently singular.? Both the US and China should own up to their shares of the current problems.? Then, maybe, solutions could be found.

The Benefits of Dumb Regulation

The Benefits of Dumb Regulation

Apologies to readers.? I have been gone last week at my denomination’s annual meeting.? As I often say at this time of year, I never work harder than at that time, so please forgive my lack of posts.? As it is now, I am worn out, but at least I am home.? Home is my favorite place.

I am presently reading a book by Justin Fox, The Myth of the Rational Market: A History of Risk, Reward, and Delusion on Wall Street.? So far, a good book.? He has a recent blog post that impressed me as well: Dumbing Down Regulation.

Should regulation be dumb?? In one sense yes, in others, no.? It really depends on how well the regulators understand the risks involved, and how much they can encourage professionalism among marketers and risk managers.? As those two increase, regulation can be smart.? “Follow these detailed rules to calculate the capital you need to be solvent 99% of the time.”

But when either of those two aren’t true, dumb regulation may be in order:

  • Strict leverage limits, reflecting the worst outcome from underwriting poor quality loans.
  • Disallowing risky types of lending, regardless of capital level.
  • Disallowing liabilities that can run easily.
  • Disallowing products that commonly deceive buyers.
  • Disallowing certain types of contracts that fuddle accounting.

If everyone were smart, things could be different.? Deceiving people would not take place, and managements would not take undue risks.? Limits could be more loose, and products would be designed for discriminating buyers.

But, face it, we are dumber than we think, myself included.? Consumer choice is a good thing, though it implies that some will be deceived, no matter where one places the line of demarcation.? Along with that, some bank will not fit the rules and go insolvent, though it does not register so on the solvency tests.

My poster child for relatively good dumb regulation is the insurance industry in the US.? The industry is far less free-wheeling than the banking industry, and under most circumstances, the solvency margins are set high enough to have few insolvencies.? There is room for improvement, though:

  • Make risk based capital charges countercyclical.? Perhaps tinkering with the Asset Valuation Reserve would do that.
  • Have some sort of rigorous testing for capital relief from reinsurance treaties.
  • Ban surplus notes in related party transactions.
  • Ban all forms of capital stacking, especially where the transactions go both ways.? I.e., subsidiaries can’t own securities of any companies? in their corporate family.? All subsidiaries must be owned by the holding company.
  • More rigorous testing for deferred tax assets.
  • Assets as risky as equities, including limited partnerships, should be a deduction from capital.
  • Securitized bonds that are not “last loss” should have higher RBC charges than comparable rated corporates.
  • A standardized summary of cash flow testing results should be revealed.

As for the banks, they need to do that and more:

  • Insurance companies list all of their assets.? Banks should as well.
  • Intangible assets should be written to zero for regulatory capital purposes.
  • Risk-based capital standards need to be tightened to at least the level of insurance companies, if not tighter.
  • Some sorts of lending to consumers should be banned.? I am talking about complex agreements, that individuals with IQs less than 120 can’t understand.? Insurance policies have to be Flesch-tested.? Bank lending agreements should be the same.? If some argue that the poor need access to credit, I will say this: the poor need to get off of credit.? Credit is for the upper-middle-class and rich.? Poor people should not go into debt.
  • Standardized summaries of terms and fees must be created for consumer lending, with large, friendly letters, and simple language that all can read.

What I am saying is that accounting has to be more conservative, and that regulators have to require larger amounts of capital to support their business, particularly at the banks.? Financial products must be made more simple for consumers to understand.? More transparency is needed everywhere, and if the financial companies complain, tell them that they will all be in the same goldfish bowl, so no one will gain an unfair advantage.

Dumb regulation bars certain lending practices, and raises capital levels higher than is needed over the long run.? So be it.? Smart regulation is far more flexible, and trusting that companies and consumers know what they are doing.? Unfortunately, when financial firms fail, there are often larger repercussions.? It is better to limit regulated financial companies to businesses where the risks are well-understood.? Let the less understood risks be borne by those outside the safety net, and bar those inside the safety net from holding any assets in those companies.

A Redacted Copy of the June FOMC Statement

A Redacted Copy of the June FOMC Statement

April 2009 June 2009 Comments
Information received since the Federal Open Market Committee met in March indicates that the economy has continued to contract, though the pace of contraction appears to be somewhat slower. Information received since the Federal Open Market Committee met in April suggests that the pace of economic contraction is slowing. Conditions in financial markets have generally improved in recent months. The FOMC is following trends in the financial markets. The stock market is higher, and credit spreads are tighter, but what of tomorrow?
Household spending has shown signs of stabilizing but remains constrained by ongoing job losses, lower housing wealth, and tight credit. Household spending has shown further signs of stabilizing but remains constrained by ongoing job losses, lower housing wealth, and tight credit. The FOMC sees further signs of stabilization of household spending.
Weak sales prospects and difficulties in obtaining credit have led businesses to cut back on inventories, fixed investment, and staffing. Businesses are cutting back on fixed investment and staffing but appear to be making progress in bringing inventory stocks into better alignment with sales. They view much of the weakness as being an inventory correction that will end soon.
Although the economic outlook has improved modestly since the March meeting, partly reflecting some easing of financial market conditions, economic activity is likely to remain weak for a time. Although economic activity is likely to remain weak for a time, They are more certain that economic conditions have improved.
Nonetheless, the Committee continues to anticipate that policy actions to stabilize financial markets and institutions, fiscal and monetary stimulus, and market forces will contribute to a gradual resumption of sustainable economic growth in a context of price stability. the Committee continues to anticipate that policy actions to stabilize financial markets and institutions, fiscal and monetary stimulus, and market forces will contribute to a gradual resumption of sustainable economic growth in a context of price stability. Materially the same.
In light of increasing economic slack here and abroad, the Committee expects that inflation will remain subdued. Moreover, the Committee sees some risk that inflation could persist for a time below rates that best foster economic growth and price stability in the longer term. The prices of energy and other commodities have risen of late. However, substantial resource slack is likely to dampen cost pressures, and the Committee expects that inflation will remain subdued for some time. They trust that slack capacity will keep inflation low, despite rising commodity prices. They are less worried bout deflation. Stagflation is not a word in their vocabulary.
In these circumstances, the Federal Reserve will employ all available tools to promote economic recovery and to preserve price stability. In these circumstances, the Federal Reserve will employ all available tools to promote economic recovery and to preserve price stability. Identical
The Committee will maintain the target range for the federal funds rate at 0 to 1/4 percent and anticipates that economic conditions are likely to warrant exceptionally low levels of the federal funds rate for an extended period. The Committee will maintain the target range for the federal funds rate at 0 to 1/4 percent and continues to anticipate that economic conditions are likely to warrant exceptionally low levels of the federal funds rate for an extended period. They are trying to lengthen the view of the market on how long the FOMC is able to maintain a low fed funds rate.
As previously announced, to provide support to mortgage lending and housing markets and to improve overall conditions in private credit markets, the Federal Reserve will purchase a total of up to $1.25 trillion of agency mortgage-backed securities and up to $200 billion of agency debt by the end of the year. As previously announced, to provide support to mortgage lending and housing markets and to improve overall conditions in private credit markets, the Federal Reserve will purchase a total of up to $1.25 trillion of agency mortgage-backed securities and up to $200 billion of agency debt by the end of the year. Identical.
In addition, the Federal Reserve will buy up to $300 billion of Treasury securities by autumn. In addition, the Federal Reserve will buy up to $300 billion of Treasury securities by autumn. Identical.
The Committee will continue to evaluate the timing and overall amounts of its purchases of securities in light of the evolving economic outlook and conditions in financial markets. The Committee will continue to evaluate the timing and overall amounts of its purchases of securities in light of the evolving economic outlook and conditions in financial markets. Identical.
The Federal Reserve is facilitating the extension of credit to households and businesses and supporting the functioning of financial markets through a range of liquidity programs. The Committee will continue to carefully monitor the size and composition of the Federal Reserve’s balance sheet in light of financial and economic developments. The Federal Reserve is monitoring the size and composition of its balance sheet and will make adjustments to its credit and liquidity programs as warranted. Much language change; not much substantive change.
Voting for the FOMC monetary policy action were: Ben S. Bernanke, Chairman; William C. Dudley, Vice Chairman; Elizabeth A. Duke; Charles L. Evans; Donald L. Kohn; Jeffrey M. Lacker; Dennis P. Lockhart; Daniel K. Tarullo; Kevin M. Warsh; and Janet L. Yellen. Voting for the FOMC monetary policy action were: Ben S. Bernanke, Chairman; William C. Dudley, Vice Chairman; Elizabeth A. Duke; Charles L. Evans; Donald L. Kohn; Jeffrey M. Lacker; Dennis P. Lockhart; Daniel K. Tarullo; Kevin M. Warsh; and Janet L. Yellen. Identical.

Quick Hits:

  • The FOMC is following trends in the financial markets. The stock market is higher, and credit spreads are tighter, but what of tomorrow?
  • They view much of the weakness as being an inventory correction that will end soon.
  • They trust that slack capacity will keep inflation low, despite rising commodity prices. They are less worried bout deflation. Stagflation is not a word in their vocabulary.
  • They are trying to lengthen the view of the market on how long the FOMC is able to maintain a low fed funds rate.
  • They are projecting calm to all who will listen, but will inflation and the dollar cooperate?? Will economic weakness not deepen from here?? The jury is out.
Stating the Case; No State Prosperity, and National Prosperity is Questionable

Stating the Case; No State Prosperity, and National Prosperity is Questionable

One thing that I watch closely is the health of the finances of the states.? Because they don’t have a printing press, and most of them have to balance their budgets, they are a better read on the health of the economy than national statistics.

As it is, states are cutting their budgets drastically because their tax collection is down dramatically.? California is a leading example here.? Will it refuse to pay, and what of its municipalities?? How many will file for Chapter 9, like Vallejo?? My guess is that many municipalities will file Chapter 9, but that California will avoid nonpayment.

There is one more issue worth pursuing here.? Though states have to run balanced budgets (largely on a cash basis), that says nothing about pensions and other long-dated promises.? I find it fascinating that some states are still trying the gambit of pushing retiree expenses out into the future.? To me, that is a sign of desperation slightly smaller than making significant budget cuts.? It’s just playing for time at a time where delay has few advantages.

That’s one reason among many that I do not see “green shoots” at present.? During a period of debt deflation, many troubles fight prosperity as the financing bubble deflates.? If the states aren’t prospering the nation is not either, regardless of what statistics the national government might dream up.

Systemic Troubles with Systemic Risk Control

Systemic Troubles with Systemic Risk Control

Often when we talk about the Fed, we talk about a dual mandate — low inflation, and low labor unemployment.? But as I suggested at RealMoney many times, there is a hidden third mandate: protect the integrity of the banking system.

Often,? a tightening cycle would end with a bang, with some credit starved entity (Residential Housing, Nasdaq, LTCM, Lesser-developed Asia, Mexico, etc.) dying.? The Federal Reserve would then spring into action and say, “We must fight the threat of unemployment.”? Would they?? No, they would invoke protecting the financial system, which protects the banks.? After all, monetary policy does not work when banks are compromised, as they are today.? No wonder there is Credit Easing.

So when I hear the Fed proposed to be the systemic risk regulator, I have two thoughts:

1) You did a bad job with monetary policy and bank supervision, but you are nice guys, because you do for the US Government all of the things the Treasury Department can’t Constitutionally do.? Now let’s see if you can do better with controlling systemic risk, even though we haven’t granted you control over all the levers necessary to do so.

2)? Maybe this will make them better with monetary policy; it makes the triple mandate explicit.

My view is that the Fed is one of the major creators of systemic risk in our economy through the use of monetary policy to stimulate our way out of bad times.? The temptation that Greenspan succumbed to was to throw liquidity at problems too early, which avoided liquidation of marginal debts, and the debt levels built up.

If the? Fed has to minimize systemic risk in the economy, maybe it becomes less willing to loosen policy profligately.? I would hope it would work that way.

That said, given the lack of success for the Fed on its goals, I suspect that if it were given the task of reining in systemic risk, it would fall prey to political pressure, and fail at that as well.

I go back to my earlier proposal — the Fed would have to keep the US economy under a limit of private debts being less than 2x GDP.? But can you imagine the Fed tightening during a boom to avoid systemic risk, or raising margin requirements?? I can’t, so even though ideally the Fed would be the right player to manage systemic risk, in practice, systemic risk is unmanageable, because there are too many interests that benefit from boom times.? That’s why I don’t expect much from the proposals to manage systemic risk, regardless of who gets the power to do so.

Unchangeable

Unchangeable

When people look at this crisis, they look for simple answers — they want to find one or two parties to blame, not many, a la my Blame Game series.? The economic system is an interconnected web, and it is not easy to change one part without affecting many others.? Intelligent ideas for change consider second order effects at minimum.? This piece, and any that follow under the same title, will attempt to point at things that are not easily done away with.? Some of these will be controversial, others not.

1) Derivatives.? What is a derivative?? A derivative is a contract where two parties agree to exchange cash flows according to some indexes or formulas.? There are some suggesting today that all derivatives must be standardized, and/or traded on exchanges.? That might make sense for common derivatives where there are large volumes, but many derivatives are “out in the tail.”? Not common, and standardization of what is not common is a fool’s errand.

To regulate derivatives fully is to say that certain types of contracts between private parties may not exist without the consent of the government.? Thinking about it that way, what becomes of free enterprise?? Granted, there are some contracts that cannot be considered enforcable, like that of a hit man, arson for hire, etc.? Those are matters that any healthy government would oppose.

What makes more sense is to bring the derivatives “on balance sheet.”? Let the effects of the notional value play out, showing owners what is happening, rather than hiding it.

2) Rating agencies — Moody’s, S&P, and Fitch deserve some blame for what happened, but the regulators needed the rating agencies.? They still do.? The rating agencies make imperfect estimates of relative credit quality for a wide munber of instruments, which then feed into the risk-based capital formulas of the regulators.? To rate such a wide number of instruments means that the issuers must pay for the rating, because there is no general interest for most ratings.

Yes, let more rating agencies compete, but they will find that the “issuer pays” model is more compelling than the “”buyer pays” model.? The concentrated interests of issuers in a rating trumps the diffuse interests of buyers.? Bond buyers need to learn to live with this, and employ buy-side analysts that don’t take the opinion of the rating agencies blindly.? What the analysts at the rating agencies write is often more valuable than the rating itself, though it doesn’t change capital charges.

Rating agencies make the most errors with new asset classes.? Better that the regulators do their jobs and prohibit immature? asset classes where the loss experience is ill-understood.

I don’t think that rating agencies are going away any time soon.? I do think that the government and regulators contemplated this, but concluded that the changes to the system would be too drastic. (Contrary opinions: one, two)

3) Yield-seeking — the desire to seek yield is near-universal.? As a bond manager, I found it rare that a manager would do a “reduce yield, improve quality or certainty” trade.? The pattern is even more pronounced with retail accounts.? They underestimate the value of the options that they are selling, and take a modicum of yield in exchage for lower certainty of return.

Can this be banned, as some are proposing with reverse convertibles?? I don’t think so, there are too many variables to nail down, and too many people in search for a yield higher than is reasonable.? Yield-hogging is an institutional sport, not only one for retail fans to grab.? As one of my old bosses used to say, “Yield can be added to any portfolio.”? How?

  • Offer protection on CDS
  • Lower the quality of your portfolio.
  • Buy all of the dirty credits that trade cheap to rating.
  • Buy securities from securitizations — they almost always trade cheap to rating.? (Ooh! CDOs!)
  • Sell a call option on the securities you hold.
  • Buy mortgage securities with a lot of prepayment or extension risk.
  • Accept the return in a higher inflation currency, assuming that their central bank will tighten.
  • Do a currency carry trade.
  • Lever up.
  • Extend the length of your portfolio.
  • Underwrite catastrophe risk through cat bonds.

Adding yield is easy.? The transparency of that addition of yield is another matter.? Reverse convertibles have been the hot issue recently since this article.? Here is a small sample of the articles that followed: (one, two, three).? Reverse convertibles, and other instruments like them give bond-like performance if things go average-to-well, and stock-like performance if things go badly.? The inducement for this is a high yield on the bond in the average-to-good scenario.

What to do?

I have three bits of advice for readers.? First, don’t buy any financial instruments tht you don’t understand well. This especially applies when the party selling them to you has options that they can exercise against you.? Wall Street excels at products that give with the right hand and take with the left, so beware structured products sold to retail investors.

Second, don’t buy any financial product that someone appears out of the blue and says, “Have I got a deal for you!”? Stop.? Take your time, ask for literature, maybe, but say that you need a month or more to think about it.? Haste is the enemy of good financial decision-making.? Instead, do your own research, and buy what you conclude that you need.? Consult trusted advisors in either case.

Third, don’t be a yield hog.? Yield is rarely free.? There are times to take risk and accept higher yields, but those are typically scary times.? At other times, make sure you understand the portfolio of risks that you accept, and that you are being adequately paid for those risks.? Better to have a ladder of high quality noncallable debt, and take some risk with equities than to take risk in a series of yieldy and illiquid bonds that you don’t understand so well.? At least you will be able to know what risks you have, and that is an aid to asset management.

Final Question

This article began as a discussion of things that are very hard to change in the current environment.? I thought of several here:

  • The continuing need for derivatives, and the impossibility of full standardization
  • The continuing need for rating agencies
  • Human nature makes us yield hogs.
  • Wall Street builds traps for investors off of that weakness.

What other things are very hard to change in the current environment?

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