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On Current Credit Conditions

Friday, July 18th, 2014

This should be short.  Remember that credit and equity volatility are strongly related.

I am dubious about conditions in the bank loan market because Collateralized Loan Obligations [CLOs] are hot now and there are many that want to take the highest level of risk there.  I realize that I am usually early on credit issues, but there are many piling into CLOs, and willing to take the first loss in exchange for a high yield.  Intermediate-term, this is not a good sign.

Note that corporations take 0n more debt when rates are low.  They overestimate how much debt they can service, because if rates rise, they are not prepared for the effect on earnings per share, should the cost of the debt reprice.

It’s a different issue, but consider China with all of the bad loans its banks have made.  They are facing another significant default, and the Chinese Government looks like it will let the default happen.  That will not likely be true if the solvency of one of their banks is threatened, so keep aware as the risks unfold.

Finally, look at the peace and calm of low implied volatilities of the equity markets.  It feels like 2006, when parties were willing to sell volatility with abandon because the central banks of our world had everything under control.  Ah, remember that?  Maybe it is time to buy volatility when it is cheap.  Now here is my question to readers: aside from buying long Treasury bonds, what investments can you think of that benefit from rising implied volatility and credit spreads, aside from options and derivatives?  Leave you answers in the comments or email me.

This will sound weird, but I am not as much worried about government bond rates rising, as I am with credit spreads rising.  Again, remember, I am likely early here, so don’t go nuts applying my logic.

PS — weakly related, also consider the pervasiveness of BlackRock’s risk control model.  Dominant risk control models may not truly control risk, because who will they sell to?  Just another imbalance of which to be wary.

Questions from Readers

Thursday, May 29th, 2014

Miscellaneous questions post — here goes:

Thank you very much for your blog! I am hooked since I found it and have been getting smarter by the day!

I like Safety Insurance Group, found it through your blog, noticed you were no longer long. They don’t do life insurance, just cars and houses – I know you say not to mix because they are sold and underwritten differently. They had a rough Q1 but a good 2013, seems like the winter Mass weather might have done it. They are over Book of 1 so there are other insurers that are cheaper, but they look like a good compliment to NWLI (also found through you and like very much) in the auto space, in a small (and thus dominate-able) market. 

Am I missing something about SAFT? 

Many sincere thanks David!

I like the management team at Safety Insurance.  When I met with them years ago, they impressed me as bright businessmen competing well in one of the most dysfunctional insurance markets in the US — Massachusetts.  Most major insurers did not write auto and home insurance there as a result.  But then the state of Massachusetts began to loosen up their tight regulations, and some of the bigger insurers that stayed away have entered — GEICO, MetLife, Liberty Mutual, etc.

When the market was more closed, SAFT had strategies that allowed them to profitably take market share Commerce Group [now Mapfre].  With more competition in Massachusetts, Safety’s earnings have suffered.  I can’t get excited about a short tail P&C insurer trading above book at 13-14x forecast earnings.

Maybe people are buying it for the 4%+ dividend.  I don’t use dividend yield as an investment criteria, for the most part.  I would avoid Safety Insurance.  It’s well-run, but the price of the stock is too high.  If it drops below $35, it would be a compelling buy.

Hi David,

I was interested in your comment on Normalized Operating Accruals as an indicator of accounting quality.

Why is this?

I tend to view changes in accruals as an indication of the underlying strength of a business, but would appreciate your insight on this.

Thanks

The idea behind net operating accruals is that accrual entries represent future cash flows, which are less certain than cash flows that have already happened.  Companies that report high levels of accounts receivable, inventories, etc., as a fraction of assets or earnings, tend to offer negative earnings surprises, because many of those accruals will not convert to cash as expected.

Here is how I measure Net Operating Accruals:

(Total assets – Cash  - (Total liabilities – Short-term debt – Preferred stock – Long-term debt))/Total assets (or earnings)

An apology here, because the term commonly used is “net operating accruals” and I messed up by calling it “normalized.”

Companies with conservative accounting (fewer accruals) tend to have stronger earnings than those that are more liberal in revenue recognition.

Dave, you and I are too old school. We need to move into this century. The way that most people seem to get into the investment industry has nothing to do with what you talk about. It is far easier to become a “financial advisor” that pushes annuities on the 60+ crowd. You don’t really have to learn anything about investing. All you need to know is about salesmanship. Offer a free lunch/dinner and reel them in!

I honestly think that more folks are going this route instead of the “hard way” you have outlined. . .

Maybe you can do a sarcastic post: “How to NOT be valuable, but make a lot of money in the Investment Business.”

Personally I find the annuity and non-traded REIT pushers very repulsive. At the same time, I know several of them that have done very well . . .

There are two factors at work here — yield and illiquidity.  The need for yield is driven by monetary policy.  Particularly with a sizable increase in retirees, many of whom can’t make enough “income” when interest rates are so low, they take undue risks to get “income,” not realizing the risks of capital loss that they are taking.

When I was an analyst/manager of Commercial Mortgage Backed Securities, there was a key fact one needed to understand: safe mortgages do not depend on whether the businesses leasing the properties operate well or not.  Safe mortgages have no operational risk, and thus avoid theaters, marinas, etc.  Stick to the four food groups: Multifamily, Retail, Office, and Industrial.

There will be negative events with insecure investments offering a high yield.  You may not get the return of your money, as you try to get a high return on your money.

Then there is the illiquidity — that is what allows the sponsors the ability to pay high commissions to those who sell the annuities and non-traded REITs.  Because the investors can’t leave the game, the income stream of the sponsor is very certain.  They take a portion of the anticipated income stream, and pay it in a lump sum to their agents as a commission.  And that is why the agents are so highly motivated.

Eventually, the demand for yield will be disappointed.  Uncertain yields will fail in a crisis, and reset much lower.  Income that stems from dividends, preferred dividends, MLPs, junk bonds, structured notes, etc., is not secure in the short-to-intermediate run.  It is far better to invest to grow value than to invest for income.  They can pay you a yield, sure, but if the underlying value is not growing, you will eventually get capital losses, and after that, much less yield.

Look for safety in yield investments.  If you are going to take risks in investing, take risk, but ignore the income component.  Don’t stretch for yield.

Classic: Changes in Corporate Bonds

Wednesday, May 21st, 2014

This was a two part article that was published at RealMoney July 19-20, 2004:

=-==–==-=-=-=-=-==-=–==–=-=-==-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=-=

Two changes have taken place in the corporate bond market in recent years. The first change deals with credit default swaps, which I’ll discuss in today’s column. In Part 2 I’ll talk about how corporate bonds are analyzed differently now.

Surviving the Loss of a Major Class of Investor

There used to be a tendency for Wall Street to hold a supply of corporate bonds to sell to the buy side. That changed when credit default swaps were, or CDS, developed. A credit default swap is a transaction where one party buys protection against the default of a corporate credit from another party. The party selling protection receives a constant payment over the life of the transaction so long as the corporate credit does not default.

These swaps were developed in the mid-1990s, but they remained somewhat tangential to investment banks until the negative side of the credit cycle hit in 2000-2002. Many banks did a huge business in CDS, but they traded cash bonds and CDS separately. Typically, the cash bond side of the house was net long corporate bonds, and the CDS side was typically flat credit risk. From late 2001 through 2002, a major change rippled through the “bulge bracket” firms on Wall Street. They got the bright idea to trade cash bonds and CDS together as a group.

This had several desirable outcomes:

  • It enabled them to hold a larger inventory of corporate bonds with less risk.
  • It enabled them to be flat the corporate bond market in a period of severe stress. (However, it must be noted that most of those that instituted programs like this had the trough of the corporate bond market.)
  • It allowed them to trade more rationally. There were new trades that could be done by comparing the cash bond market and CDS market, going long one and short the other. (Note: Here’s how to make money on corporate trading desks: You have more flow in the market than most people you trade with. When clients offer you mispriced trades in your favor, you trade with them and then buy or sell the offsetting positions in the intradealer market at a fair price. With CDS, you have more options for laying off the risk.)

This had the unfortunate effect of removing a seemingly natural buyer from the corporate bond market at a time when the corporate bond market could least afford it. It is my guess that that was part of the reason why the corporate bond market bottomed out in October of 2002, rather than July of 2002. Pressure on the corporate bond market from CDS-related selling did not abate until mid-November of 2002.

As a result, there is only one major buyer of long-term corporate credit risk left in the U.S. economy: life insurance companies. Pension funds play a role in this market, as do foreign institutional buyers. So when corporate bonds do badly or well, life insurance companies are disproportionately affected.

In one sense, we are in a brave new world for both life insurance companies and the corporate bond market because the life insurance industry alone is not big enough to purchase all of the corporate bonds outstanding. Perhaps foreign institutions have filled the gap at present; if so, it will be interesting to see whether foreign capital is as patient as the life insurance industry if we have another downturn in the credit markets.

An Additional Implication of CDS

CDS unify the debt capital structure of debt-issuing companies. In the old days, companies that borrowed money from banks, or issued debt, did so in marketplaces that were separately priced. That separation allowed corporations a greater degree of wiggle room when financial times got tough. Even if the bond market temporarily shut down after a company was downgraded to junk, typically banks would still lend to them, even if the terms were more onerous.

But with the advent of CDS, the banks might lend, but they will lay all the risk on the CDS market. As more risk gets laid off, the credit default swap spreads rise. As the credit default swap spreads rise, an arbitrage opportunity appears against cash bonds.

This leads the corporate bond market default in tandem with rising credit default swaps spreads. Finally, because of arbitrage between equity prices, equity volatility, corporate bond spreads and credit default swap spreads, even a dislocation in the equity markets can lead to trouble in the debt markets and vice versa.

Here is an example of how the world has changed. In late 2000, Xerox (XRX) was under threat of downgrade from both ratings agencies. A downgrade from either agency would make Xerox unable to sell commercial paper, which it needed to finance its deteriorating business. The company tried to issue more commercial paper, but the auction failed, which forced it to exit the commercial paper market. To make up for the cash flow shortfall, Xerox went to its banks to tap its CP backup credit lines. The banks, distressed that what was previously considered free money for them was actually going to be put to use, went to hedge their risks in the CDS market as the CP backup lines got drawn down. The massive buying demand for Xerox CDS led the CDS spreads to widen, which spread into the corporate bond market through arbitrage and eventually led the price of Xerox common equity downward. This happened in a matter of a few days, although the effects rippled for weeks afterward.

Thus, in a panic situation, every market that provides capital to corporations fights against the corporations in a unified manner. This is very different from how the markets behaved 10 years ago. The implication for equity investors is that if you’re buying the equity of debt-issuing corporations, you must be aware that in a crisis they will be more volatile than they were in the past.

Since the bottom of corporate bond market in the 2002, corporations have enjoyed stronger profits and free cash flow. Many corporations have deleveraged. This would be reason alone for corporate spreads to tighten. But there is another factor at play here that is less known outside of the corporate market.

Two Methods of Analysis

There are two distinctly different ways to analyze corporate bonds. The first way is the old standard, which relies on fundamental analysis of a company’s financial statements. The second way relies on contingent claims theory (options theory, Merton’s model) and primarily uses market-oriented variables like stock prices and option volatility.

The basic idea behind the latter method is that the unsecured debt of a firm can be viewed as having sold a put option to the equity owners. In an insolvency, the most the equity owners can lose is their investment. The unsecured bondholders (in a simple two-asset-class capital structure) are the new “de facto” equity holders of the firm. That equity interest is most often worth far less than the original debt. Recoveries are usually 40% or so of the original principal.

Under contingent claims theory, spreads should narrow when equity prices rise, and when implied volatility of equity options falls. Both of these make the implied put option of the equity holders less valuable. Equity holders do not want to give the bondholders a firm that is worth more, or more stable.

So what’s the point? Over the last seven years, more and more managers of corporate credit risk use contingent claims models. Some use them exclusively; others use them in tandem with traditional models. They have a big enough influence on the corporate bond market that they often drive the level of spreads.

Because of this, the decline in implied volatility for the indices and individual companies has been a major factor in the spread compression that has happened. I would say that the decline in implied volatility, and deleveraging, has had a larger impact on spreads than improved profitability has.

Wider Implications for the Markets

Contingent claims models are not perfect, but they are quite good. To ignore them is foolish, but understanding their weaknesses is helpful.

Contingent claims models have a tendency to overestimate the risk of default with corporations that are overleveraged but have a long maturity debt structure. In many of these cases, the indebted corporation has a great deal of “breathing room” and often can maneuver its way out of the situation. This can offer real opportunities for buy-and-hold investors because they can buy the debt or equity at depressed levels and hold it through the apparent crisis. Doing this requires careful fundamental analysis, so if you invest in any of these situations, make sure you do your homework thoroughly.

Finally, the combination of contingent claims theory and the existence of CDS can produce other anomalies. It becomes theoretically possible to hedge CDS against common equity. Some hedge funds do this. They analyze bank debt, corporate bonds, convertible bonds, preferred and common stocks, options, warrants and other financing instruments, to find the cheapest aspect of a company’s credit structure and buy it, and find the richest aspect and sell it.

The full set of implications for the asset markets from this is unknown, partly because funds that do this are small relative to the markets as a whole. If the hedge funds that did this were too large for the markets, it would create too many feedback loops that have not yet been tested, which would have a tendency to amplify price moves in a crisis.

I can’t tell where such a crisis might lurk. The markets are relatively optimistic now. But being aware that these feedback loops could exist, can give you an edge in a crisis. The main upshot is this: Having a strong balance sheet is worth more today than it was in the past. It’s one of many reasons why I continue to focus on higher-quality companies in my equity investing.

Why it is Hard to Win in Investing

Saturday, April 26th, 2014

Before I start this evening, I want to say something about many investment books that I have been reading of late.  In terms of information toward the stated goal of the book, there is often a lot of build up, some of it necessary, some not, some of it interesting, some not, occasionally some unique insights, but most of the time not.  Much of it is filler that could be eliminated.  And, if you eliminated the filler, and boiled down the part of the book that attempts to prove the stated goal, you would have something the size of a long-form blog post.  That’s why there is the filler — you would have a hard time selling a single chapter book, even though that contains the real value of the book, and would save your reader the time of wading through filler material.

Also, when I review books, I read them in entire.  If I don’t read them in entire, I state that plainly at the beginning of the review, along with why I thought I could review the book without reading it.  But after some of the books I have read lately, editing to condense the volume and stick to the topic at hand would be a help.

Finally, if the author doesn’t prove his case in an ironclad way, maybe the book shouldn’t be written.  I often get to the end of a book disappointed, because the author promised a significant result, and did not deliver.

Onto tonight’s topic:

When is the best time to invest?  When everyone else is scared to death of investing.  It’s when friends come up to you and say, “I’m never investing in stocks ever again.”  When the magazine covers proclaim “The Death of Equities,” it is time to invest.

Guess what?  Very few people do invest then.  It’s too painful to contemplate throwing away your money when nothing is going right, and losses are cascading.  Remember, we are not rational, we are mimics.

When do people like to invest?  When it’s popular to do so. When prices have been rising for a while, and the lure of “free money” is in the air.  Books on easy money flipping homes proliferate, and there is a brisk business in seminars teaching an easy road to riches.  It’s that time when people say, “Let the market pay your employees.”

I’ve talked about the fear/greed cycle many times before.  I’ve also talked about time-weighted vs dollar-weighted returns before. I’ve talked about vintage years in lending before, and about absolute return investors before.  I’ve talked about industry rotation before, as well as long-term mean reversion.  These are all manifestations of the same phenomenon in investing — it is best to invest in any given area when few are doing so, and worst to invest when almost all are doing so.

Let me give a bunch of parallel examples to make this clear.

Why do great mutual fund managers cease to be great?  When they are great, they have less money to manage than their ideas could bear managing.  But money follows performance because we are not rational, we mimic.  Eventually enough money comes in  such that the talented investor no longer has good places to put incremental money, and can’t just leave some of the money in cash, or an index fund… from a business angle, it would not fly.

Lest you think that this does not happen to passive investing, money follows performance there also.  It also happens in open-ended index funds, ETPs, and closed-end funds of any sort (expressed through the premium or discount).

This also applies to quantitative investment strategies — even those with broad themes like momentum and valuation.  Let me illustrate this with a slide from a presentation I have done before a large CFA Society:

Efficient Markets versus Adptive Markets

 

And this applies to lending whether securitized or direct.  When money is being thrown at a sub-asset class, like subprime RMBS in 2006-7, or manufactured housing ABS in 2000-1, the results are bad.  The best results occur when few are lending, and only the best deals are getting done.  But that means that few get those high returns.  That is the nature of the markets.

The same applies to corporate bonds.  It is wise to avoid the area of the market where issuance is well above average.  When I was a corporate bond manager, I sold out my auto bonds, and my questionable telecom bonds, amidst much issuance.  I had many brokers puzzle over why I would not buy their deals, even though they were cheap relative to their ratings.

The same applies to private equity.  When a lot of money is being applied there, it is a time to avoid it.  As it is now, private equity is throwing money at promising companies, many of which hold onto the money for safety purposes, because they don’t have place to invest it.  That doesn’t sound promising for future returns.

Finally, we have a few absolute return investors like Klarman, Grantham, and Buffett.  They are reducing allocations to risk assets, at least in relative terms.  Opportunities are not as great, and so they wait.

Summary

The intelligent investor estimates likely returns, and invests if the returns are worth the risk.  I am reducing my risk positions, slowly, as I see best for my clients and me.

Most profitable investing takes an uncomfortable view versus the consensus, and buys when the market offers good deals.  If there are no good deals, profitable investing sits on cash, and waits for a better day.

Sorted Weekly Tweets

Friday, April 18th, 2014

Stocks & Industries

  • Invest In Stubs, Spin-Offs And Liquidations For Alternative Returns http://t.co/ccezep0K9Y Cites a Gabelli article http://t.co/xTrqEfmQeq $$ Apr 19, 2014
  • Real Estate Management Better Than Owning Real Estate? http://t.co/IFaDLiwTRa Sometimes yes, sometimes no. Definitely adds more leverage $$ Apr 19, 2014
  • Wells Fargo Securities Lending Lawsuit Ends in Settlement http://t.co/w3lSY4Cw8D Low margin business that can go badly wrong in a crisis $$ Apr 19, 2014
  • Makani, a $GOOG subsidiary makes an airborne wind turbine that dramaticlly increases power generation efficiency http://t.co/0Fug49o7gC $$ Apr 18, 2014
  • Google to Buy Titan Aerospace as Web Giants Battle for Air Superiority http://t.co/HjJ8wKtnjM Makes me think $GOOG has 2much $$ 2spend Apr 18, 2014
  • Profit Tastes Like Chicken in Hunt for Cheaper US Meat http://t.co/drgQbwEiKR With recent rise in beef & pork prices people substitute $$ Apr 18, 2014
  • Roads Versus Rail:The Big Battle Over Public Transportation http://t.co/ydBxEglexC Makes case that American will own fewer cars in future $$ Apr 18, 2014
  • Barclays Ups $LNC To Buy, Says $MET , $PRU Are Undervalued – Stocks To Watch http://t.co/c7yNaVZqdp Stock Market sensitive insurance cos $$ Apr 18, 2014
  • Bidding War Looming for Aspen? Analysts Say Don’t Count On It http://t.co/iMotqyAgHv Offer 4 $AHL looks pretty full 2me, dont look4more $$ Apr 18, 2014
  • Biggest LBO Demise Poised to Put Oncor in Play http://t.co/d30djwOa5M Buffett is unlikely 2 enter into bidding in a competitive sale $$ Apr 18, 2014
  • Target of Naked Short Sellers Is Angry, Confused http://t.co/I3ZZDn5JNp @matt_lavine takes on imaginary naked shorting in $LPHI $$ Apr 18, 2014
  • Radioactive Waste Is North Dakota’s New Shale Problem http://t.co/BiMkO0ZdgK Significant amounts of low level radiation from radium $$ Apr 18, 2014
  • The death of mortgage lending http://t.co/u8uQBvZCuS Loan yields must rise in order to compensate for higher required capital at banks $$ Apr 19, 2014
  • Kochs’ Flood Insurance Opposition Becomes Campaign Issue http://t.co/b1iuvoVhZK 1 of the few businesses the Kochs’ aren’t in is insurance $$ Apr 18, 2014
  • Office Markets Strengthen Where Tech, Energy Jobs Are http://t.co/sESuHUeAVr Helps explain the spottiness of commercial RE prices $$ $CMBS Apr 18, 2014
  • Labor Shortage Threatens to Bust the Shale Boom http://t.co/R1TctaTelD Can’t find a job? Consider learning to weld; monotonous but pays $$ Apr 18, 2014
  • Koch Brothers Net Worth Tops $100B as TV Warfare Escalates http://t.co/XgH0M6CNIR Almost as wealthy as extended Walton family $$ $WMT $SPY Apr 18, 2014
  • Big Banks Ramp Up Business Lending http://t.co/83dMAPIQia Signs of life spotted in big corporations, but r they just buying back stock? $$ Apr 18, 2014
  • How Can Yahoo Be Worth Less Than Zero? http://t.co/sr3owwkyNE @matt_levine argues a breakup of $YHOO makes sense even if core biz loses $$ Apr 18, 2014
  • Wal-Mart Undercuts Rivals With New U.S. Money Transfer Service http://t.co/a4vq0HYALi Useful if u need 2 transfer $$ inside the US $WMT $SPY Apr 18, 2014
  • How Chick-fil-A Spent $50M to Change Its Grilled Chicken http://t.co/Q9kpXoSIbF The marinade matters, but the grill design was the key $$ Apr 15, 2014
  • Small US Colleges Battle Death Spiral as Enrollment Drops http://t.co/nHRhO4Gc1R Too much capacity & affordability is a problem $$ $APOL Apr 14, 2014

Outside the US

  • China GDP Gauge Seen Showing Deeper Slowdown http://t.co/ntIxxdXcpO If China increases consumption GDP growth will fall faster still $$ $FXI Apr 18, 2014
  • Housing Trouble Grows in China http://t.co/Z4tKUuqLFd Overbuilding by Real-Estate Developers Leaves Smaller Cities W/Glut of Apartments $$ Apr 18, 2014
  • Suddenly, Europe Is Taking a Harder Line on Russia Sanctions http://t.co/MnzxvMP3pe Nations can solidify when they face a common threat $$ Apr 18, 2014
  • Las Bambas Copper Mine Purchase Shows China’s Still in the Hunt for Commodities http://t.co/h1cqGERGCu China may not b changing much $$ Apr 18, 2014
  • Forgetting How to Speak Russian http://t.co/D0UwT6unki Among former Soviet republics knowing Russian is less important for business $$ Apr 18, 2014
  • The Middle East War on Christians http://t.co/BW1NwCAXuH Israeli Ambassador 2 UN argues Israel is tolerant of Christians, not like some $$ Apr 18, 2014
  • Britons Struggle to Save for Home Down Payments as Prices Surge http://t.co/M6vH0vDlDs Space is constrained in London & foreigners buy $$ Apr 18, 2014
  • US Said to Warn Money Managers of More Russia Sanctions http://t.co/rB8AUQTsnc Putin knows Iran survived worse sanctions; Russia tougher $$ Apr 18, 2014
  • China Sentences Four Activists on Disturbing Public Order Charge http://t.co/Tx95rrhWsb Mostly, US has rule of law, China has rule by law $$ Apr 18, 2014
  • US govt isn’t perfect, but in principle the govt is subject to the Constitution & laws, & not merely able 2 use law 2 enforce its will $$ Apr 18, 2014
  • Frontier Fund Buyers Find It Pays To Look Under The Hood http://t.co/JQ6khwYllJ 2much $$ is being thrown @ frontier mkts; crowded trade $FM Apr 18, 2014
  • Why iShares’ ‘FM’ Is About To Get Better http://t.co/4FiqlfW0YS Diversifies out of Middle East, but frontier market vals r stretched $$ $FM Apr 18, 2014
  • Putin’s 21-Year Quest to Be Russian Guardian Began in Estonia http://t.co/5oelLBHCmN Father was betrayed by Estonians in WWI, almost died $$ Apr 15, 2014

Market Dynamics & Fundamentals

  • Bridgewater Founder Says 85 Percent Of Pensions will Go Bankrupt http://t.co/YknEmyGgfJ 9% pension returns required, 4% is most likely $$ Apr 19, 2014
  • The Fitch Fundamentals Index Dashboard http://t.co/OzI6KWUFfs Interesting little utility 4 understanding where we are in the credit cycle $$ Apr 19, 2014
  • Rich Start-Ups Go Back for Another Helping http://t.co/ZbFbpLVgmM When capital is plentiful, bad decisions get made. expected returns low $$ Apr 18, 2014
  • Stumbling S&P 500 Reaches Worst Stretch of Election Cycle http://t.co/zgJTynu2od Interesting timing, wonder whether past is prologue? $$ Apr 18, 2014
  • How a 56-Year-Old Engineer’s $45K Loss Spurred SEC Probe http://t.co/3HfdH2aqxK Always read the risk factors in the prospectus or 10K $$ Apr 18, 2014
  • High-Speed Traders Said to Be Subpoenaed in NY Probe http://t.co/2qxmrxeVd7 What level of technology is legitimate 2 gain an advantage? $$ Apr 18, 2014
  • Nuggets of Corporate Governance Wisdom From Charlie Munger http://t.co/gMFIE9jlRM Also c this paper: http://t.co/033v0bgdYr $$ $BRK.B $SPY Apr 18, 2014
  • Global stock rally: World market cap reached record high in March, &is $2.4T above pre-recession, pre-crisis level http://t.co/iMq0IoBhch $$ Apr 18, 2014
  • Speed—the only HFT advantage? Not so fast—Flash Boyshttp://www.cnbc.com/id/101586488 Algorithms may also be an advantage w/price patterns $$ Apr 18, 2014
  • Investor Alert – Exchange-Traded Notes—Avoid Unpleasant Surprises http://t.co/NqhUr2whsJ A helpful reminder 2b wary of exotic ETNs $$ $SPY Apr 18, 2014
  • Americans Sold on Real Estate as Best Long-Term Investment http://t.co/La4UROU0ie Helps explain y retail investors lose on average $$ $GLD Apr 18, 2014
  • Destroying Smart Beta 2: Ground Rules http://t.co/uecYqZLCEe Smart beta is a trendy but vapid concept, factors should be part of alpha $$ Apr 18, 2014
  • Gross Loses to Goldman in Hot Bond Strategy as Pimco Lags http://t.co/VWv7UC72bS Series of bad bets makes Pimco a laggard as AUM flees $$ Apr 15, 2014
  • Trillion-Dollar Firms Dominating Bonds Prompting Probes http://t.co/RXZNkNwtFs Concentrated markets can lead to bond pricing distortions $$ Apr 15, 2014

US Politics & Policy

  • What’s the Matter With Illinois? http://t.co/wmDiyWDN1e They r the exemplary state for shortsightedness & corruption $$ Apr 19, 2014
  • Heartbleed Hackers Steal Encryption Keys in Threat Test http://t.co/dYfezfXe8A >6 people were able to extract private key of a website $$ Apr 19, 2014
  • Elijah Cummings, W/IRS, Targeted Tea Party Group True The Vote http://t.co/TE5A1zTM0y I live in his gerrymandered district; kick him out $$ Apr 18, 2014
  • Yellen Lays Groundwork for Rules on Short-Term Credit Markets http://t.co/z03MWlpsqI Fed doesn’t regulate the banks well, y try 4 more? $$ Apr 18, 2014
  • Schooling on a ‘Debit Card’ http://t.co/wwixbB0pqy Arizona created a program so that special needs kids can get specialized schooling $$ Apr 18, 2014
  • IRS Among Agencies Using License Plate-Tracking Vendor http://t.co/HTs5aEMNtK Howard County Police use it & catch people 4 old crimes $$ Apr 18, 2014
  • Wealth Effect Failing to Move Wealthy to Spend http://t.co/R3vfD5i94J Wealth effect, if it exists, is small, FOMC is pursuing illusions $$ Apr 18, 2014
  • NSA Said 2 Exploit Heartbleed Bug for Intelligence for Years http://t.co/9XvcLX9ZTE NSA quietly knows security vulnerabilities; uses them $$ Apr 15, 2014
  • The Wall Street second-chances rule: scandal makes the rich grow stronger http://t.co/8HhscWJjMN What does not kill us makes us stronger? $$ Apr 14, 2014

Practical

  • How well do you know your insurance policy? http://t.co/szp3G8H4kN Know what is covered & what isn’t, how much is covered & options $$ Apr 19, 2014
  • Attention Shoppers: Fruit and Vegetable Prices Are Rising http://t.co/MMdPOLry9A As are meat prices & most food prices $$ #agflation Apr 18, 2014
  • How to start investing http://t.co/yGyziE8Tac Good advice from a credible source $$ Apr 18, 2014

Other

  • El Nino Signs Detected, Presaging Global Weather Change http://t.co/D1uDLS9aJ0 El Nino exists 2 give us something 2 blame when frustrated $$ Apr 18, 2014
  • More People Pick Elimination Diets to Discover Food Sensitivities http://t.co/ftQkzs3PxP Fad and Science of Not Eating Entire Food Groups $$ Apr 18, 2014
  • SAT Adopts Real-World Questions and Jettisons Obscure Words http://t.co/Mspw9EG3OV In 2016, changes from intelligence to achievement test $$ Apr 18, 2014
  • Scientists Make First Embryo Clones From Adults http://t.co/e5qlwyiWwj Cloned cells 2create early-stage embryos, matching DNA tissue $$ Apr 18, 2014

Comments, Replies & Retweets

  • RT @howardlindzon: Funds still paying up (I say silly overpay) for private over public, this is spooking IPO ‘s for sure http://t.co/mclSd9… Apr 15, 2014

The Good ETF, Part 2 (sort of)

Friday, April 18th, 2014

About 4.5 years ago, I wrote a short piece called The Good ETF.  I’ll quote the summary:

Good ETFs are:

  • Small compared to the pool that they fish in
  • Follow broad themes
  • Do not rely on irreplicable assets
  • Storable, they do not require a “roll” or some replication strategy.
  • Not affected by unexpected credit events.
  • Liquid in terms of what they repesent, and liquid it what they hold.

The last one is a good summary.  There are many ETFs that are Closed-end funds in disguise.  An ETF with liquid assets, following a theme that many will want to follow will never disappear, and will have a price that tracks its NAV.

Though I said ETFs, I really meant ETPs, which included Exchange Traded Notes, and other structures.  I remain concerned that people get deluded by the idea that if it trades as a stock, it will behave like a stock, or a spot commodity, or an index.

What triggered this article was reading the following article: How a 56-Year-Old Engineer’s $45,000 Loss Spurred SEC Probe.  Quoting from the beginning of the article:

Jeff Steckbeck didn’t read the prospectus. He didn’t realize the price was inflated. He didn’t even know the security he read about online was something other than an exchange-traded fund.

The 56-year-old civil engineer ultimately lost $45,000 on the wrong end of a volatility bet, or about 80 percent of his investment, after a Credit Suisse Group AG (CSGN) note known as TVIX crashed a week after he bought it in March 2012 and never recovered. Now Steckbeck says he wishes he’d been aware of the perils of bank securities known as exchange-traded notes that use derivatives to mimic assets from natural gas to stocks.

“In theory, everybody’s supposed to read everything right to the bottom line and you take all the risks associated with it if you don’t,” he said this month by phone from Lebanon, Pennsylvania. “But in reality, you gotta trust that these people are operating within what they generally say, you know?”

No, you don’t have to trust people blindly.  Reagan said, “Trust, but verify.”  Anytime you enter into a contract, you need to know the major features of the contract, or have trusted expert advisers who do know, and assure you that things are fine.

After all, these are financial markets.  In any business deal, you may run into someone who offers you something that sounds attractive until you read the fine print.  You need to read the fine print.  Now, fraud can be alleged to those who actively dissuade people from reading the fine print, but not to those who offer the prospectus where all of the risks are disclosed.  Again, quoting from the article:

Some fail to adequately explain that banks can bet against the very notes they’re selling or suspend new offerings or take other actions that can affect their value, according to the letter.

[snip]

“My experience with ETN prospectuses is that they’re very clear about the fees and the risks and the transparency,” Styrcula said. “Any investor who invests without reading the prospectus does so at his or her own peril, and that’s the way it should be.”

[snip]

The offering documents for the VelocityShares Daily 2x VIX (VIX) Short Term ETN, the TVIX, says on the first page that the security is intended for “sophisticated investors.” The note “is likely to be close to zero after 20 years and we do not intend or expect any investor to hold the ETNs from inception to maturity,” according to the prospectus.

While Steckbeck said a supervisor at Clermont Wealth Strategies advised him against investing in TVIX in February 2012, he bought 4,000 shares the next month from his self-managed brokerage account. The adviser, whom Steckbeck declined to name, didn’t say that the price had become unmoored from the index it was supposed to track.

David Campbell, president of Clermont Wealth Strategies, declined to comment.

Steckbeck, who found the TVIX on the Yahoo Finance website, doesn’t have time to comb through dozens of pages every time he makes an investment, he said.

“Engineers — we’re not dumb,” said Steckbeck, who founded his own consulting company in 1990. “We’re good with math, good with numbers. We read and understand stuff fairly quickly, but we also have our jobs to perform. We can’t sit there and read prospectuses all day.”

If you are investing, you need to read prospectuses.  No ifs, ands, or buts.  I’m sorry, Mr. Steckbeck, you’re not dumb, but you are foolish.  Being bright with math and science is not enough for investing if you can’t be bothered to read the legal documents for the complex contract/security that you bought.  I read every prospectus for every security that I buy if it is unusual.  I read prospectuses and 10-Ks for many simple securities like stocks — the managements must “spill the beans” in the “risk factors” because if they don’t, and something bad happens that they didn’t talk about, they will be sued.

In general I am not a fan of a “liberal arts” education.  I am a fan of math and science.  But truly, I want both.  We homeschool, and our eight kids are “all arounds.”  They aren’t all smart, but they tend to be equal with verbal and quantitative reasoning.  Truly bright people are good with both math and language.  Final quotation from the article:

“The whole point of making these things exchange-traded was to make them accessible to retail investors,” said Colbrin Wright, assistant professor at Brigham Young University in Provo, Utah, who has written academic articles on the indicative values of ETNs. “The majority of ETNs are overpriced, and about a third of them are statistically significant in their overpricing.”

So, I contacted Colby Wright, and we had a short e-mail exchange, where he pointed me to the paper that he co-wrote.  Interesting paper, and it makes me want to do more research to see how great ETN prices can be versus their net asset values [NAVs].  That said, end of the paper errs when it concludes:

We assert that the frequent and persistent negative WDFDs [DM: NAV premiums] that appear to be driven by uninformed return chasing investors would not exist to the conspicuous degree that we observe if ETNs offered a more investor-driven and fluid system for share creation. We believe the system for share creation is ineffective in mitigating the asymmetric mispricing investigated in our study. Hence, we recommend that ETN issuers reformulate the share creation system related to their securities. Specifically, we recommend the ETN share creation process be structured to mirror that of ETFs. At a minimum, the share creation process should be initiated by investors, rather than by the ETN issuers themselves, as we believe profit-motivated investors will be more diligent and responsive in creating ETN shares when severe mispricing arises.

Here’s the problem: ETNs are debt, not equity.  To have the same share creation system means that the debtor must be willing to take on what could be an unlimited amount of debt.  In most cases, that doesn’t work.

So I come back to where I started.  Be skeptical of complexity in exchange traded products.  Avoid complexity.  Complexity works in favor of the one offering the deal, not the one accepting the deal.  I have only bought one structured note in my life, and that was one that I was allowed to structure.  As Buffett once said (something like this), “My terms, your price.”

To close, here are four valuable articles on this topic:

So avoid complexity in investing.  Do due diligence in all investing, and more when the investments are complex.  I am astounded at how much money has been lost in exchange traded investments that are designed to lose money over the long term.  You might be able to avoid it, but someone has to hold every “asset,” so losses will come to those who hold investments long term that were designed to last for a day.

On Rising Rate Funds, or, Who Remembers ARM Funds in the Early ’90s?

Saturday, April 12th, 2014

In the early 90s, there were not many investment actuaries.  One of the Holy Grail ideas of the early-to-mid ’90s was creating floating rate funds with yield so that floating rate Guaranteed Investment Contracts could be profitably written.  I chronicled my efforts there in this article.

One avenue that I went down and rejected was ARM [Adjustable Rate Mortgage] funds.  There was a minor craze for them in the early-to-mid ’90s, and there were not enough ARMs issued to meet the demand for high floating rates.  As such, the prices for blocks of ARMs rose above par, sometimes significantly.

One truism of buying mortgages at a premium in the ’90s was that the ability to refinance got sharper and sharper.  Those willing to buy mortgage securities above par usually took losses as rates fell.

Thus when I read articles about rising rate ETFs, which either invest short-term, or short the bond market synthetically or actually, I think “we’ve been here before.”  It is difficult to gain incremental yield on short duration instruments without taking on risks like:

  • Credit, including weak covenants
  • Structure (another form of credit & illiquidity)
  • Negative optionality

So be wary here.  Pay more attention to the return of your principal than the return on the principal.

Best of the Aleph Blog, Part 23

Thursday, April 3rd, 2014

Before I start this evening, I would like to explain some of the reasons for these “Best of the Aleph Blog” articles.  I write these no closer than one year after an article was written, so that I can have a more dispassionate assessment of how good they were.  I write these for the following reasons:

  • Some people want a quick introduction to the way I think.
  • Some publishers on the web want additional copy, and I let them republish some of my best pieces.
  • One day I may bundle a bunch of them together, rewrite them to improve clarity, and integrate them to create a set of books on different topics.
  • One of my editors at RealMoney once shared with me that I was one of the few authors there whose articles got re-read, or read after a significant time had passed.  This is meant to be mostly “timeless” stuff.
  • New readers might be interested in older stuff.
  • I enjoy re-reading my older pieces, and sometimes it stimulates updates, and new ideas.

Anyway, onto this issue of the “Best of the Aleph Blog.”  These articles appeared between August 2012 and October 2012:

On Credit Scores

Why credit scores are important; make sure you guard yours.

Retail Investors and the Stock Market

On the pathologies of being an amateur investor when there are those who will take advantage of you, and you might sabotage yourself as well.

On the Poway School District

Goes through the details of how a school district outside San Diego mortgaged the future of the next generation who will live there, if any will live there.

Using Investment Advice, Part I

Using Investment Advice, Part II

Using Investment Advice, Part III

Using Investment Advice, Part IV

A series of articles inspired by what I wrote at RealMoney, encouraging people to be careful about listening to advice in the media on stocks, including those recommended by Cramer.

The Future Belongs to Those with Patience

On why patience and discipline are required for good investing.

What Caused the Crisis?

A retrospective, if somewhat controversial.

On the International Business Machines Industrial Average

Replace the DJIA with a new cap-weighted index of the 30 largest capitalization stocks.

How Warren Buffett is Different from Most Investors, Part 1

How Warren Buffett is Different from Most Investors, Part 2

You have to understand Buffett the businessman to understand Buffett the investor.

Volatility Analogy

How an interview I messed up led to an interesting way to explain volatility.

Spot the Gerrymander

Eventually we need to eliminate gerrymandering — hey, maybe we can do that at the future Constitutional Convention.

Reforming Public School Testing

Creating exams where you can’t study for the test; you can only study.

Carrying Capacity

Governments imagine that they can shape outcomes, and in the short-run, they can.  In the long-run, the real productivity of the economy matters, and only those that can make it without government help will make it.  Whatever government policy may try to achieve, eventually the economy reverts to what would happen naturally without incentives.  There is a natural carrying capacity for most activities, and efforts to change that usually fail.

Actuaries Versus Quants

On why Actuaries are much better than Quants

Neoclassical vs Austrian Economics

Applying math to economics has been a loser.  Who has a consistently good macroeconomic model?  No one that I know.  Estimates of future GDP growth and inflation are regularly wrong, and no one calls turning points well.

The Dilemma of Adding Yield

A quick summary of risk in bonds, and why additional yield is often not rewarded.

The Dilemma of Adding Yield, Redux

On working out the pricing between discount, premium, and par bonds.

Too Much Investment

Investment is a good thing, overinvestment is a bad thing.

Got Cash? (Part 2)

On Buffett and others carrying cash to give themselves flexibility.

Set it and Forget it

On what uneducated investors should do.

Forest Fires and Central Banking

Short piece pointing out that small crises are needed to prevent huge crises.

Match Assets and Liabilities

Total Return Versus Long Liabilities

Cash flow matching has often been sneered at as an investment policy.  I explain why such a view is naive, not sophisticated, and definitely wrong.

The Rules, Part XXXIV

“Once something is used for hedging purposes, it becomes useless for predictive purposes.”

Why I LOVE Blogging

On the downsides of blogging, and why they aren’t so bad.

Higher Taxes, Inflation, Default (Choose One)

Coming to a country near you, and soon!

On the Virtue of Hard Questions for Young Analysts

How young analysts toughen up through hard competitions.

Dealing in Fractions of Sense

On how to reform High Frequency Trading

Yield is the Last Refuge of Scoundrels

Far from offering high price appreciation, it is far easier to cheat many people by offering a high yield, because average people look for ways to stretch their limited resources with a tight budget.

Book Review: Treasure Islands

Tuesday, April 1st, 2014

9780230341722

Tax havens exist to lower taxes and regulations on corporations and wealthy individuals.  But doing this involves significant complicated legal and accounting work.  The average person could not benefit because the fixed costs are high.  You need to have a lot of assets to benefit from tax havens.

So why do the wealthy governments of the world tolerate tax havens?  Why don’t they “use NATO to blockade these places, and tell them to end their tax-avoidance-facilitation policies, or else.”  Sadly, the wealthy have disproportionate power over politicians, and the majority of politicians are wealthy.  They like the system as it is.  You can make the tax code as progressive as you like; you will not end up taxing the intelligent wealthy much more.

This book confronts transfer pricing, where profits get shifted to low-tax countries by clever accountants.  Very difficult to police.

The is an amusing section in the middle of the book about the City of London Corporation, which has unique rights in the UK.  It is the home of most financial activity n London, and is mostly unaccountable to the UK.

In general, I believe that taxation should be the same regardless of the structure of the entity being taxed, its location, etc.  To that end, I think that corporations should be taxed on their global income as expressed to its owners.  Or, don’t tax corporations, but make all taxation like limited partnerships, and tax the individuals that own them.

There are other possible solutions.  There can be limits on corporate structure.  Israel limits subsidiaries such that the depth from the holding company cannot exceed two.  There could be consolidation and/or non-recognition of  subsidiaries in tax havens.

Additional Resources

Longreads article

Book website (those reading at Amazon, come to Aleph Blog to get links)

Quibbles

The book makes its last chapter about how tax havens helped cause the financial crisis, but it makes a very weak case.  Individuals and Banks overlevered themselves as asset prices rose, creating a bubble — not much different than the 1920s.  Tax havens played little role, even if they aided securitization in a few ways.

The book argues for capital controls, but those controls often create incentives for greater corruption.

My main problem with the book is that it does not offer any workable solutions to the problems.  My secondary problem is that the problem is not so much with the tax havens, which we could easily marginalize, but with the politicians, who do not do the hard work of seeing that taxation takes place, regardless of the corporate form or location.

Who would benefit from this book: You have to be willing to endure complex arguments to benefit from this book.  If you want to, you can buy it here: Treasure Islands: Uncovering the Damage of Offshore Banking and Tax Havens.

Full disclosure: I borrowed it at my library.

If you enter Amazon through my site, and you buy anything, I get a small commission.  This is my main source of blog revenue.  I prefer this to a “tip jar” because I want you to get something you want, rather than merely giving me a tip.  Book reviews take time, particularly with the reading, which most book reviewers don’t do in full, and I typically do. (When I don’t, I mention that I scanned the book.  Also, I never use the data that the PR flacks send out.)

Most people buying at Amazon do not enter via a referring website.  Thus Amazon builds an extra 1-3% into the prices to all buyers to compensate for the commissions given to the minority that come through referring sites.  Whether you buy at Amazon directly or enter via my site, your prices don’t change.

Classic: Know Your Debt Crises: This Too Shall Pass

Thursday, March 27th, 2014

The following was published at RealMoney on August 6th, 2007:

Editor’s Summary

The illiquid debt instruments at the heart of the current crisis are subject to regime shifts.

  •  We’re in a periodic repricing of illiquid debt instruments.
  • Look for the time when the bulk of the losses will be reconciled.
  • Stick with the companies that have strong balance sheets.

I appreciated Cramer’s piece Friday morning, which picks up on many themes that I have articulated for the last four years here on RealMoney.  Here are a few:

  • Hedge fund-of-funds demand smooth returns that are higher than that which a moderate quality short-term fixed-income fund can deliver.
  • This leads to the creation of hedge funds that seek yield through arbitrage strategies.
  • And the creation of hedge funds that seek yield through buying risky debts, unlevered.
  • And the creation of hedge funds that seek yield through buying less risky debts, levered.
  • And the creation of hedge funds that seek yield through buying risky debts, levered.

In the short run, yield-seeking strategies work.  If a lot of players pursue them, they work extra-well for a time, as late entrants to the trade push up the returns for early entrants, with greater demand for scarce, illiquid securities with extra yield.  Pricing grids are a necessity for such securities, because the individual securities don’t have liquid secondary markets.  The pressure of demand raises the value not only of the securities being bought, but also of those securities that are like them.  (Smart managers begin to exit then.)

I’ve been through regime shifts in the markets for collateralized debt obligations (CDOs), asset-backed securities (ABS), residential-backed securities (RMBS) and commercial mortgage-backed securities (CMBS).  Something shifts at the back of the chain that forces everything to reprice.  For example:

1989-1994: After the real estate boom of the mid-1980s, many banks, savings & loans and insurance companies get loose in their lending standards and real estate investment, leading to a crisis when rent growth can’t keep up with financing terms; defaults ensue, killing off a great number of S&Ls, some major insurance companies and a passel of medium and small banks.

Late 1991-early 1993: The adjustable-rate mortgage market, fueled by demand from ARM funds, overbids for ARMs in an effort to provide a high floating rate yield.  As the FOMC loosens monetary policy, higher than expected prepayments force losses onto the ARM funds

Late 1993-late 1994: The FOMC threatens to, and does, start raising interest rates, which throws the residential mortgage-backed market into crisis.

Mid-1998-mid-1999: Long Term Capital Management blows up, forcing all manner of exotic ABS, CMBS and RMBS into the market for bids.  The bids back up, until the entire market reprices and then tightens in the space of one year.

1998-1999: Home equity ABS blow up, as defaults threaten to, and then do, emerge at levels far higher than anticipated.  Almost no originators survive.

1999-2001: Cruddy high-yield bonds reveal their true value as defaults threaten to, and then do, emerge.

2002-2003: The manufactured-housing ABS market blows up, as originators don’t take initial losses but roll borrowers over into new loans that reduce payments and extend payment terms, technically keeping the loans current.  The system collapses when the buildup of bad debts and repossessed homes becomes too great to roll over.

(Of the existing large securitization markets, only the CMBS market so far has not faced a real crisis, partly due to the influence of the B-piece buyers cartel: six or so firms that buy the junk-rated debt of deals and enforce credit quality standards on the individual loans by kicking out poorly underwritten loans.  But who knows?  Even that could be overwhelmed under the right circumstances.)

In each of these situations, there was a boom-bust cycle.  The markets did not adjust slowly and evenly to changing conditions; the transitions between “boom” pricing, and “bust” pricing were swift.  This is the nature of markets, particularly when enough debt is employed to amplify the process.

There is no conspiracy necessary to make the shift happen (though often the media will make it seem like there was one); the bubble pops when the financing proves insufficient to carry the assets.  After the bubble pops, it becomes a question of what the underlying assets can be liquidated for, allocating losses mercilessly according to the loan documents and bankruptcy priority.

Today the crises are nonprime lending, leveraged buyouts and other high-yield debt and over-leverage in the CDO market.  These will get worked out, as all other crises do, handing losses to those who speculated unwisely and allowing those who financed properly to prosper on the other side of the crisis.

As you invest, look for the time when more than half of the losses will be reconciled.  That will be near the bottom for homebuilders and housing finance.

That time may not come for another two years or so, but there will be money to be made once the crisis is mostly reconciled.  Just stick with the companies that have strong balance sheets.

Disclaimer


David Merkel is an investment professional, and like every investment professional, he makes mistakes. David encourages you to do your own independent "due diligence" on any idea that he talks about, because he could be wrong. Nothing written here, at RealMoney, Wall Street All-Stars, or anywhere else David may write is an invitation to buy or sell any particular security; at most, David is handing out educated guesses as to what the markets may do. David is fond of saying, "The markets always find a new way to make a fool out of you," and so he encourages caution in investing. Risk control wins the game in the long run, not bold moves. Even the best strategies of the past fail, sometimes spectacularly, when you least expect it. David is not immune to that, so please understand that any past success of his will be probably be followed by failures.


Also, though David runs Aleph Investments, LLC, this blog is not a part of that business. This blog exists to educate investors, and give something back. It is not intended as advertisement for Aleph Investments; David is not soliciting business through it. When David, or a client of David's has an interest in a security mentioned, full disclosure will be given, as has been past practice for all that David does on the web. Disclosure is the breakfast of champions.


Additionally, David may occasionally write about accounting, actuarial, insurance, and tax topics, but nothing written here, at RealMoney, or anywhere else is meant to be formal "advice" in those areas. Consult a reputable professional in those areas to get personal, tailored advice that meets the specialized needs that David can have no knowledge of.

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