How would you like a really good model to make money as a money manager? You would? Great!
What I am going to describe is a competitive business, so you probably won’t grow like mad, but what money you do bring in the door, you will likely keep for some time, and earn significant fees.
This post is inspired by a piece written by Jason Zweig at the Wall Street Journal:?The Trendiest Investment on Wall Street?That Nobody Knows About. ?The article talks about interval funds. ?Interval funds hold illiquid investments that would be difficult to sell at a fair price ?quickly. ?As such, liquidity is limited to quarterly or annual limits, and investors line up for distributions. ?If you are the only one to ask for a distribution, you might get a lot paid out, perhaps even paid out in full. ?If everyone asked for a part of the distribution, everyone would get paid their pro-rata share.
But there are other ways to capture assets, and as a result, fees.
Various types of business partnerships, including Private REITs, Real Estate Partnerships, etc.
Illiquid?debts, such as structured notes
Variable, Indexed and Fixed Annuities with looong surrender charge periods.
Life insurance as an investment
Weird kinds of IRAs that you can only set up with a venturesome custodian
Odd mutual funds that limit withdrawals because they offer “guarantees” of a sort.
And more, but I am talking about those that get sold to or done by retail investors… institutional investors have even more chances to tie up their money for moderate, modest or negative incremental returns.
(One more aside, Closed end funds are a great way for managers to get a captive pool of assets, but individual investors at least get the ability to gain liquidity subject to the changing premium/discount versus NAV.)
My main point is short and simple. ?Be wary of surrendering liquidity. ?If you can’t clearly identify what you are gaining from giving up liquidity, don’t make the investment. ?You are likely being hoodwinked.
It’s that simple.
[bctt tweet=”If you can’t clearly identify what you are gaining from giving up liquidity, don’t make the investment.” username=”alephblog”]
Should a credit?analyst care about financial?leverage? ?Of course, the amount and types of financial claims against a firm are material to the ability of a firm to avoid defaulting on its debts. ?What about operating leverage? ?Should the credit?analyst care? ?Of course, if a firm has high fixed costs and low variable costs (high operating leverage), its financial position is less stable than that of a company that has low fixed costs and high variable costs. ?Changes in demand don’t affect a firm as much if they have low operating leverage.
That might be fine for industrials and utilities, but what about financials? ?Aren’t financials different? ?Yes, financials are different as far as operating leverage goes because for financial companies, operating leverage is the degree of credit risk that financials take on in their assets. Different types of lending have different propensities for loss, both in terms of likelihood and severity, which are usually correlated.
A simple example would be two groups of corporate bonds — ?one can argue over new classes of bond?ratings, but on average, lower rated corporate bonds default more frequently than higher rated bonds, and when they default, the losses are typically greater on the lower rated bonds.
As such the amount of operating risk, that is, unlevered credit risk, is material to the riskiness of financial companies.
Credit analysis gets done on financial companies by many parties: the rating agencies, private credit analysts, and implicitly by financial regulators. ?They all do the same sorts of analyses using similar underlying theory, though the details vary.
Regulators typically codify their analyses through what they call risk-based capital. ?Given all of the risks a financial institution takes — credit, asset-liability mismatch, and other liability risks, how much capital does a financial institution need in order to stay solvent? ?Along with this usually also comes cash flow testing to make sure that?the financial companies can withstand runs on their capital structure.
When done in a rigorous way, this lowers the probability and severity of financial failures, including the remote possibility that taxpayers could be tagged in a crisis to cover losses. ?In the life insurance industry, actuaries have worked together with regulators to put together a fair system that is hard to game, and as such, few life and P&C insurance companies went under during the financial crisis. ?(Note: AIG went under due to its derivative subsidiary and that they messed with securities lending agreements. ?The only failures in life and P&C insurance were small.)
Banks have risk-based capital standards, but they are less well-designed than those of the US insurance industry, and for the big banks they are more flexible than those for insurers. ?If I were regulating banks, I would get a small army of actuaries to study bank solvency, and craft regulations together with a single banking regulator that covers all depositary financials (or, state regulators like in insurance which would be better) using methods similar to those for the insurance industry. ?Then every five years or so, adjust the regulations because as they get used, problems appear. ?After a while, the methods would work well. ?Oh, I left one thing out — all banks would have a valuation actuary reporting to the board and the regulators who would do the cash flow testing and the risk-based capital calculations. ?Their positions would be funded with a very small portion of money that currently goes to the FDIC.
This would be a very good system for avoiding excessive financial risk. ?Dreaming aside, I write this this evening because there are other dreamers proposing a radically simple system for regulating banks which would allow them to write business with no constraint at all with respect to credit risk. ?All banks would face a simple 10% leverage ratio regardless of how risky their loan books are. ?This would in the short run constrain the big banks because they would need to raise capital levels, though after that happened, they would probably write riskier loans to get their return on equity back to where it was.
My main point here is that you don’t want to incent banks to write a lot of risky loans. ?It would be better for banks to put aside the right amount of capital versus varying classes of risk, and size the amount of capital such that it is not prohibitive to the banking system.
As such, a simple leverage ratio will not cut it. ?Thinking people and their politicians should reject the current proposal being put out by the Republicans and instead embrace a more successful regulatory system manned by intelligent and reasonably risk-averse actuaries.
Note to all of my readers before I start on my main topic: on the morning of 3/12?I give a talk to the American Association of Individual Investors in Baltimore. ?If you want to see my slide deck, here it is.
Okay, time for some secular economic and financial heresy, which is always somewhat fun. ?Secondary market liquidity isn’t very important to the functioning of the general economy of the capitalist world, including the US. ?(That said, my exceptions to this statement are listed here.)
Finance has an important role in the economy, aiding business in financing the assets of the corporation, and most of the value of that comes from the debt and/or equity financing in the primary markets, or from loan granted by a bank or another entity.
After the primary financing is done, the company has the cash to enter into its projects and produce value. ?Then the stocks, occasionally?bonds, and rarely bank loans issued trade on the secondary markets if they trade at all. That trading is:
The real action of value creation goes on in the companies — occasionally secondary market investing, through activists, M&A, etc., may find ways to realize the value, but the value was already created — the question was who would benefit from it — management or shareholders.
If you are investing, choosing assets to?buy is the most important aspect of risk control. ?Measure twice, cut once. ?Yes, secondary trading may help you do better or worse, but only if the rest of the world takes up the slack, doing worse or better. ?There is no net gain to the economy as a whole from trading.
I grew up as a portfolio manager for a life insurance company. ?Many assets were totally illiquid — I?could not sell them without extreme effort, and only interested parties might want to try, who knew as much or more than?me. ?Ordinary bonds were still largely illiquid — you *could* trade them, but it would cost you unless you were patient and clever. ?In such an environment you made sure that all of your purchases were good from the start, because there was no guarantee that you could ever make a change at an attractive price.
My contention is that most if not all financial institutions could exist the same way, rarely trading, if they paid attention to their initial purchases, matched assets and liabilities, and did not buy marginal securities. ?Now some trading will always be needed because individuals and institutions need to deploy new cash and raise new cash to meet expenditures.
But I would not give a lot of credence to those in the banks who complain that a lack of liquidity in the financial markets is harming the economy as a whole, and as such, we should loosen regulations on the banks. ?After all, liquidity used to be a lot lower in the middle of the 20th century, and the economy was a lot more perky then.
Don’t let finance exaggerate its role in the economy. ?Is it important? ?Yes, but not as important as the financial needs of the clients that they serve. ?Don’t let the tail wag the dog.
Caption from the WSJ: Regulators don?t think it is the place of Congress to second guess how they size up securities. Fed Chairwoman Janet Yellen said recently that legislation would ?interfere with our supervisory judgments.? PHOTO: BAO DANDAN/ZUMA PRESS
Catch the caption from the WSJ for the above picture:
Regulators don?t think it is the place of Congress to second guess how they size up securities. Fed Chairwoman Janet Yellen said recently that legislation would ?interfere with our supervisory judgments.?
Regulators are not required by the Constitution, but Congress, perverse as it is, is the body closest to the people, getting put up for election regularly. ? Of course Congress should oversee financial regulation and monetary policy from?an unelected Federal Reserve. ?That’s their job.
I’m not saying that the Congressmen themselves understand these things well enough to do anything — but that’s true of most laws, etc. ?If the Federal Reserve says they are experts on these matters, past bad results notwithstanding, Congress can get people who are experts as well to aid them in their decisions on laws and regulations.
The above is not my main point, though. ?I have a specific example to draw on: municipal bonds. ?As the Wall Street Journal headline says, are they “Safe or Hard to Sell?” ?For financial regulation, that’s the wrong question, because this should be an asset-liability management problem. ?Banks should be buying assets and making loans that fit the structure of their liabilities. ?How long are the CDs? ?How sticky are the deposits and the savings accounts?
If the maturities of the munis match the liabilities of the bank, they will pay out at the time that the bank needs liquidity to pay those who place money with them. ?This is the same as it would be for any bond or loan.
If a bank, insurance company, or any financial institution relies on secondary market liquidity in order to protect its solvency, it has a flawed strategy. ?That means any market panic can ruin them. ?They need table stability, not bicycle stability. ?A table will stand, while a bicycle has to keep moving to stay upright.
What’s that you say? ?We need banks to do maturity transformation so that long dated projects can be cheaply funded by short-term savers. ?Sorry, that’s what leads to financial crises, and creates the run on liquidity when the value of long dated assets falls, and savers want their money back. ?Let long dated assets that want debt financing be financed by REITs, pension plans, endowments, long-tail casualty insurers, and life insurers. ?Banks should invest short, and use the swap market t aid their asset liability needs.
Thus, there is no need for the Fed to be worrying about muni market liquidity. ?The problem is one of asset-liability matching. ?Once that is settled, banks can make intelligent decisions about what credit risk to take versus their liabilities.
In many ways, our regulators learned the wrong lessons in the recent crisis, and as such, they meddle where they don’t need to, while neglecting the real problems.
But given the strength of the banking lobby, is that any surprise?
A: I dealt mainly with investment grade credit. ?What’s more, I had a real balance sheet behind me at the life insurance company. ?An ordinary open-end mutual fund has investors that can leave whenever they want — often at the worst possible time for them, or in this case, those that could not get out.
The main difference was that I could never be forced to sell, under most conditions. ?I could buy and hold, and if the eventual credit of the borrower was good, my client would receive all that he expected. ?TFCIX faced significant redemptions, and increasingly had mostly bonds that could not be quickly sold, and thus, were difficult to value. ?That’s why they cut off redemptions — they couldn’t?liquidate assets to give cash to customers on a favorable basis. ?Personally, I think setting up the liquidation trust was the best that could be done. ?That will allow Third Avenue to negotiate with interested buyers of the bonds without being rushed by redemptions. ?The remaining fundholders should be grateful for them doing this now, though it would have been better to act sooner.
Q: But I own shares in?TFCIX and need the money now. ?What can I do?
A: Oh, my. ?My sympathies. ?You can’t do?much. ?There might be some off the beaten track lenders out there that might take it off your hands, but they wear “panky rangs,” as a mortgage borrower once said to me.
Q: Panky Rangs?
A: Pinky rings. ?He was from the deep South. ?I.e., no one is going to give you a decent bid for your shares, even if you could find someone willing to do so. ?First, the value of the bonds is questionable, and the timing of the sales are?uncertain.
A: JP Morgan became too great of a part of the indexed credit derivatives market, and as a result, they lost the ability to value their positions, because they were too big relative to the market in which they traded. ?Their very buying and selling had a huge impact on the pricing. ?Though a value was placed on the positions, the entire situation was impossible to value accurately; ?you couldn’t assemble a group to buy it all.
Some clever hedge funds took note of it, and began taking the opposite positions, thinking that they were overvalued, and fed JP Morgan more of what it was already bloated with. ?Now maybe, if there hadn’t been so much press furor over it, together with the accounting questions that affected the financials of JP Morgan, they could have found a way out. ?JP Morgan’s balance sheet was big enough, and if you left them alone, they would have all self -liquidated. ?They might not have made the money they wanted that way, but it could have been done. ?As it was, they were forced to liquidate more rapidly, and if I recall, they even called upon one of the opposing hedge funds to help them.
In any case, the forced liquidation led to losses. ?Most forced liquidations do.
Q: So, what do think my shares are worth?
A: They are worth the liquidating distributions that you will receive.
Q: That’s no help.
A: Is the Federal Reserve willing to step up and buy the assets as they did with?the Maiden Lane Trusts? ?No one has a bigger balance sheet than they do, oh, oops. ?Maybe they can’t do that anymore… who know where those emergency lending rules go…
Look, I’m sorry that you are stuck. ?The Madoff “investors” were stuck also. ?They had to wait quite a while. ?In the end, they got paid more than most imagined they ever would. ?Subject to credit conditions,?I would suspect that the more time Third Avenue takes to liquidate, the more you will get.
Q: But that’s dribs and drabs over time, and I need it now.
A: Patience is a virtue. ?Make other adjustments; sell something else; scale back plans… it’s no different than most people have to do when they have a loss. ?It happens.
Q: I guess… but it would help to know what it was worth, so that I could estimate tradeoffs.
A: yes, it would, but the timing and amount of liquidations are uncertain, and the “market prices” don’t really exist for the underlying — they are too influenced by Third Avenue’s holdings.
Maybe they could have converted it into a closed-end fund, ?but that would have cost money, and there still would have been the valuation issue. ?People could have gotten paid now if that had happened, but I bet they would have blanched at the size of the unrealized losses. ?I would just accept the payments as they come, that will probably give the best return, subject to future credit conditions.
A: An asset is worth whatever the highest bidder will pay for it at the time you offer it for sale.
After all, if it is worth the liquidating distributions if I wait, maybe you should add, “or the cash flows you receive over time.”
A: I will do that, and that is part of what I have been arguing for here, but the price here and now is not that. ?Just because you can’t sell it now doesn’t mean it doesn’t have value… we just don’t know what that value is.
Anyway, lunch is on me today, because there is another thing that you can’t sell that has value.
This post was triggered by a guy from the UK who sent me an infographic on reducing risk that I thought was mediocre at best. ?First, I don’t like infographics or video. ?I want to learn things quickly. ?Give me well-written text to read. ?A picture is worth maybe fifty words, not a thousand, when it comes to business writing, perhaps excluding some well-designed graphs.
Here’s the problem. ?Do you want to reduce?the volatility of your asset portfolio? ?I have the solution for you. ?Buy bonds and hold some cash.
And some say to me, “Wait, I want my money to work hard. ?Can’t you find investments that offer a higher return that diversify my portfolio of stocks and other risky assets?” ?In a word the answer is “no,” though some will tell you otherwise.
Now once upon a time, in ancient times, prior to the Nixon Era, no one hedged, and no one looked for alternative investments. ?Those buying stocks stuck to well-financed “blue chip” companies.
Some clever people realized that they could take risk in other areas, and so they broadened their stock exposure to include:
Growth stocks
Midcap stocks (value & growth)
Small cap stocks (value & growth)
REITs and other income passthrough vehicles (BDCs, Royalty Trusts, MLPs, etc.)
Developed International stocks (of all kinds)
Emerging Market stocks
Frontier Market stocks
And more…
And initially, it worked. ?There was significant diversification until… the new asset subclasses were crowded with institutional money seeking the same things as the original diversifiers.
Now, was there no diversification left? ?Not much. ?The diversification from investor behavior is largely gone (the liability side of correlation). ?Different sectors of the global economy don’t move in perfect lockstep,?so natively the return drivers of the assets are 60-90% correlated (the asset side of correlation, think of how the cost of capital moves in a correlated way across companies). ?Yes, there are a few nooks and crannies that are neglected, like Russia and Brazil, industries that are deeply out of favor like gold, oil E&P, coal, mining, etc., but you have to hold your nose and take reputational risk to buy them. ?How many institutional investors want to take a 25% chance of losing a lot of clients by failing unconventionally?
Why do I hear crickets? ?Hmm…
Well, the game wasn’t up yet, and those that pursued diversification pursued alternatives, and they bought:
Timberland
Real Estate
Private Equity
Collateralized debt obligations of many flavors
Junk bonds
Distressed Debt
Merger Arbitrage
Convertible Arbitrage
Other types of arbitrage
Commodities
Off-the-beaten track bonds and derivatives, both long and short
And more… one that stunned me during the last bubble was leverage nonprime commercial paper.
Well guess what? ?Much the same thing happened here as happened with non-“blue chip” stocks. ?Initially, it worked. ?There was significant diversification until… the new asset subclasses were crowded with institutional money seeking the same things as the original diversifiers.
Now, was there no diversification left? ?Some, but less. ?Not everyone was willing to do all of these. ?The diversification from investor behavior was reduced?(the liability side of correlation). ?These don’t move in perfect lockstep,?so natively the return drivers of the risky components of the assets are 60-90% correlated over the long run (the asset side of correlation, think of how the cost of capital moves in a correlated way across companies). ?Yes, there are some?that are neglected, but you have to hold your nose and take reputational risk to buy them, or sell them short. ?Many of those blew up last time. ?How many institutional investors want to take a 25% chance of losing a lot of clients by failing unconventionally?
Why do I hear crickets again? ?Hmm…
That’s why I don’t think there is a lot to do anymore in diversifying risky assets beyond a certain point. ?Spread your exposures, and do it intelligently, such that the eggs are in baskets are different as they can be, without neglecting the effort to buy attractive assets.
But beyond that, hold dry powder. ?Think of cash, which doesn’t earn much or lose much. ?Think of some longer high quality bonds that do well when things are bad, like long treasuries.
Remember, the reward for taking business risk in general varies over time. ?Rewards are relatively thin now, valuations are somewhere in the 9th decile (80-90%). ?This isn’t a call to go nuts and sell all of your risky asset positions. ?That requires more knowledge than I will ever have. ?But it does mean having some dry powder. ?The amount is up to you as you evaluate your time horizon and your opportunities. ?Choose wisely. ?As for me, about 20-30% of my total assets are safe, but I?have been a risk-taker most of my life. ?Again, choose wisely.
PS — if the low volatility anomaly weren’t overfished, along with other aspects of factor investing (Smart Beta!) those might also offer some diversification. ?You will have to wait for those ideas to be forgotten. ?Wait to see a few fund closures, and a severe reduction in AUM for the leaders…
A while ago I wrote two pieces called “Easy In, Hard Out.” ?The main idea was to illustrate the difficulties that the Federal Reserve will face in removing policy accommodation. ? In the past, the greater the easing cycle, the harder the tightening cycle. ?I don’t think this time will be any different.
In the last two pieces, I showed three graphs to illustrate how the Fed’s balance sheet has changed. ?I’m going to show them again now, updated to 11/11/2015. ?Here’s the graph showing the liabilities of the Federal Reserve — i.e. what the Fed eventually has to pay back, occasionally with interest:
I’ve added a new category since last time — reverse repurchase agreements (“reverse repos”) because it has gotten big. ?In that category, you have money market funds (etc.) lending to the Fed to pick up a pittance in interest.
As you might note — as the balance sheet has grown, all categories of liabilities have grown. ?The pristine balance sheet composed mostly of currency is no more — it is only around 30% of the liabilities now. ?The biggest increase in reserve balances at the Fed — banks lending to the Fed to receive a pittance in interest, because they have nothing better to do for now.
I’ve considered doing an experiment, and I might do it over the next few weeks. ?I went to my copy of AAII Stock Investor, and pulled out the contact data for 336 banks with market capitalizations of over $100 million. ?I was thinking of calling 10 of them at random, and asking the following questions:
What has the Fed’s ZIRP policy done to your business?
Do you have a lot of money on deposit at the Federal Reserve?
When the Fed raises the short-term interest rate, what do you plan on doing?
Then, the same questions asking them about their competitors.
Finally, who has the most to lose in this situation?
It could be revealing, or it could be a zonk.
One more interesting note: reverse repos and my “all other” category have become increasingly volatile of late.
Here’s my next graph, with the asset class composition of the Fed’s balance sheet:
The Fed has gone from a pristine balance sheet of 95% Treasuries to one of 60/40 Treasuries and Mortgage-backed securities [MBS]. ?MBS are?considerably less liquid than Treasuries, particularly when you are the largest holder of them by a wide margin — I’ve heard that it is 25% of the market. ?The moment that it would become public knowledge that you were a seller, the market would re-rate down in price considerably, until holders became compensated for the risk of more MBS supply.
Finally, here is the maturity graph for the assets owned by the Fed:
The pristine balance sheet of 2008 was very short in its interest rate sensitivity for its assets — maybe 3?years average at most. ?Now maybe the average maturity is 12? ?I think it is longer…
Does anybody remember when I wrote a series of very unpopular pieces back in 2008 defending mark-to-market accounting? ?Those made me very unpopular inside Finacorp, the now-defunct firm I worked for back then.
I see three hands raised. ?My, how time flies. ?For the three of you, do you remember what the toxic balance sheet combination is? ?The one lady is raising her hand. ?The lady has it right — Illiquid assets and liquid liabilities!
In a minor way, that is the Fed now. ?Their liabilities will reprice little as they raise rates, while the market value of their assets will fall harder if the yield curve moves in a parallel shift. ?No guarantee of a parallel shift, though — and I think the long end may not budge, as in 2004-7. ?Either way though, the income of the Fed will decline rapidly, and any adjustment to their balance sheet will prove difficult to achieve.
What’s that, you say? ?The Fed doesn’t mark its assets to market? ?You got it. ?But cash flows don’t change as a result of accounting.
Now, there is one bit of complexity here that was rumored at the Cato Conference — supposedly the Fed doesn’t use a prepayment model with its MBS. ?If anyone has better info on that, let me know. ?If true, the average life figures which are mostly in the 10-30 years bucket are highly suspect.
As a result of the no-mark-to-market accounting, the Fed won’t show deterioration of its balance sheet in any conventional way. ?But you could see seigniorage — the excess interest paid to the US Treasury go negative, and the dividend to its owner banks suspended/delayed for a time if rates rose enough. ?Asking the banks to buy more stock in the Federal Reserve would also be a possibility if things got bad enough — i.e., where the future cash flows from the assets could never pay all of the liabilities. ?(Yes, they could print money together with the Treasury, but that has issues of its own. ?Everything the Fed has done with credit so far has been sterile. ?No helicopter drop of money yet.)
Of course, if interest rates rose that much, the US Treasury’s future deficits would balloon, and there would be a lot of political pressure to keep interest rates low if possible. ?Remember, central banks are political creatures, much as their independence is advertised.
Conclusion?
Ugh. ?The conclusions of my last two pieces were nuanced. ?This one is?not. ?My main point is this: even with the great powers that a central bank has, the next tightening cycle has ample reason for large negative surprises, leading to a premature end of the tightening cycle, and more muddling thereafter, or possibly, some scenario that the Treasury and Fed can’t control.
Before I start on this tonight, let me say that I never begrudge any salesman a fair commission. ?When I was a bond manager, I made a point of never letting my brokers “cross bonds” to me, i.e., at no commission. ?I would raise my purchase price a little to compensate them. ?Had my client known that I did that, he might have objected, but it was in his best interests that I did it. ?As a result of that and other things that I did, my brokers were very loyal to me, and worked to give my client excellent executions whether buying or selling. ?They were also more frank with me about bonds they thought I should sell. ?Fairness begets fairness under most conditions, and suspicion and tightness also have their way of breeding as well. ?Consider that in all of your dealings.
My main reason for writing tonight is to remind investors to think about how the parties you transact with are compensated.
If they are compensated on?transactions, expect to see a lot of buying and selling.
If they are compensated on asset-based fees, expect them to try to get business, and then retain it.
If they are compensated on profits, they will try to get profits. ?Be wary of how much control they might have over the accounting, they will be incented to be liberal if they have any control. ?They will also be incented toward volatility, because volatile assets offer the best possibility of a big score, even if the probability is moderate at best.
The greater the potential compensation, the greater the tendency to act along the incentives offered. ?As a result, if a life insurance salesman has a product offering a high commission, and one offering a low commission, he may act in the following way:
Figure out if you are price-sensitive or not.
Figure out if you are willing to accept a product that has a long surrender charge. ?Long surrender charges lock in business, and allow for high commissions to be paid.
Also analyze how much complexity you are willing to accept — more complex permanent policies and especially ancillary riders are far more profitable because even external actuaries would have a tough time analyzing them.
If you are price-sensitive, bring out the low commission policy that is more competitive.
If you are price-insensitive, bring out the high?commission policy that is less?competitive.
(Note: there are state laws in every state that constrain this behavior for life insurance agents, but it can never be eliminated in entire.)
Now, many agents will act in your interests in spite of their own interests, but some won’t, so be aware. ?Always ask a question like, “This seems expensive. ?Don’t you have another policy that is less expensive that accomplishes only the main goal that I am shooting for?”
You could always ask them what commission is that they will earn. ?Most won’t answer that. ?First, it’s kind of offensive, and second, they will argue that it is not material to your decision.
But it is material to your decision. ?Here’s why:
The size of the commission directly affects the size of the premium that you pay.
It also directly affects?the length and size of the surrender charge that you would pay if you terminate the policy early.
After all, the actuaries or other mathematical businessmen are trying to avoid the risk of paying a commission that they can’t recover under ALL circumstances. ?They will get their fees from you to recoup the commission cost. ?They will either get it from you coming or going, but they WILL?get it from you, at least on average.
If the?salesmen?disagree with you after mentioning this (or showing them this), you can say to them that every actuary knows this is true, don’t argue with the actuaries, they know the math. ?(And its why we tend to buy term and other simple policies. ?Shhh.)
I’ve seen more than my share of ugly products in my time. ?I’m happy I never designed any. ?I did kill a few of them. ?That said, one of the most unpleasant duties I ever had as a life actuary was about 18 years ago when I inherited a department to clean up, and I got the responsibility of talking to the clients that were the most irate, demanding to talk to the man in charge. ?I never created those products, but I was nominally in charge of the division as I cleaned up the pricing, reinsurance, reserving, accounting, and asset-liability management.
I’ll tell you, it is no fun talking to people who conclude that they have been had. ?It is even less fun to be the one who has been had. ?Thus I would tell you to view all salesmen of financial with skepticism. ?It is hard to assure a good result with intangible products that are hard to compare. ?Thus aim for simplicity and lower surrender charge and commission products.
Now, I used life insurance as my example here because I know it best, and it excels in complexity. ?But this applies to all financial products, especially illiquid ones. ?Be wary of:
Brokers who make money off of commissions
Those who sell private REITs and structured notes
Any product where you have a limited ability to liquidate or sell it.
Any product that you can’t understand how the company and salesman are making money off it.
Any product where you can’t understand what the legal form of the investment is (Stock, bond, mutual fund, partnership, derivative, insurance, etc.)
Here are some final bits of advice:
Look for advisers who are fiduciaries, and are responsible to look out for your interests (but still be wary)
Look at the fee structures, and look for lower cost alternatives.
Remember, regardless of what laws exist, you are your own best defender when it comes to your own economic interests. ?Be aware of the economic incentives of those who seek your business with financial products, and be reasonably skeptical.
These are just notes on the proposal so far. ?Here goes:
1) It’s a solution in search of a problem.
After the financial crisis, regulators got one message strongly — focus on liquidity. ?Good point with respect to banks and other depositary financials, useless with respect to everything else. ?Insurers and asset managers pose no systemic risk, unless like AIG they have a derivatives counterparty. ?Even money market funds weren’t that big of a problem — halt withdrawals for a short amount of time, and hand out losses to withdrawing unitholders.
The problem the SEC is trying to deal with seems to be that in a crisis, mutual fund holders who do not sell lose value from those who are selling because the Net Asset Value at the end of the day does not go low enough. ?In the short run, mutual fund managers tend to sell liquid assets when redemptions are spiking; the prices of illiquid assets don’t move as much as they should, and so the NAV is artificially high post-redemptions, until the prices of illiquid assets adjust.
The Commission will consider proposed amendments to Investment Company Act rule 22c-1 that would permit, but not require, open-end funds (except money market funds or ETFs) to use ?swing pricing.??
Swing pricing is the process of reflecting in a fund?s NAV the costs associated with shareholders? trading activity in order to pass those costs on to the purchasing and redeeming shareholders.? It is designed to protect existing shareholders from dilution associated with shareholder purchases and redemptions and would be another tool to help funds manage liquidity risks.? Pooled investment vehicles in certain foreign jurisdictions currently use forms of swing pricing.
A fund that chooses to use swing pricing would reflect in its NAV a specified amount, the swing factor, once the level of net purchases into or net redemptions from the fund exceeds a specified percentage of the fund?s NAV known as the swing threshold.? The proposed amendments include factors that funds would be required to consider to determine the swing threshold and swing factor, and to annually review the swing threshold.? The fund?s board, including the independent directors, would be required to approve the fund?s swing pricing policies and procedures.
But there are simpler ways to do this. ?In the wake of the mutual fund timing scandal, mutual funds were allowed to estimate the NAV to reflect the underlying value of assets that don’t adjust rapidly. ?This just needs to be followed more aggressively in a crisis, and peg the NAV lower than they otherwise would, for the sake of those that hold on.
Perhaps better still would be provisions where exit loads are paid back to the funds, not the fund companies. ?Those are frequently used for funds where the underlying assets are less liquid. ?Those would more than compensate for any losses.
2) This disproportionately affects fixed income funds. ?One size does not fit all here. ?Fixed income funds already use matrix pricing extensively — the NAV is always an estimate because not only do the grand majority of fixed income instruments not trade each day, most of them do not have anyone publicly posting a bid or ask.
In order to get a decent yield, you have to accept some amount of lesser liquidity. ?Do you want to force bond managers to start buying instruments that are nominally more liquid, but carry more risk of loss? ?Dividend-paying common stocks are more liquid than bonds, but it is far easier to lose money in stocks than in bonds.
Liquidity risk in bonds is important, but it is not the only risk that managers face. ?it should not be made a high priority relative to credit or interest rate risks.
3) One could argue that every order affects market pricing — nothing is truly liquid. ?The calculations behind the analyses will be fraught with unprovable assumptions, and merely replace a known risk with an unknown risk.
4)?Liquidity is not as constant as you might imagine. ?Raising your bid to buy, or lowering your ask to sell are normal activities. ?Particularly with illiquid stocks and bonds, volume only picks up when someone arrives wanting to buy or sell, and then the rest of the holders and potential holders react to what he wants to do. ?It is very easy to underestimate the amount of potential liquidity in a given asset. ?As with any asset, it comes at a cost.
I spent a lot of time trading illiquid bonds. ?If I liked the creditworthiness, during times of market stress, I would buy bonds that others wanted to get rid of. ?What surprised me was how easy it was to source the bonds and sell the bonds if you weren’t in a hurry. ?Just be diffident, say you want to pick up or pose one or two?million of par value in the right context, say it to the right broker who knows the bond, and you can begin the negotiation. ?I actually found it to be a lot of fun, and it made good money for my insurance client.
5) It affects good things about mutual funds. ?Really, this regulation should have to go through a benefit-cost analysis to show that it does more good than harm. ?Illiquid assets, properly chosen, can add significant value. ?As Jason Zweig of the Wall Street Journal said:
The bad news is that the new regulations might well make most fund managers even more chicken-hearted than they already are ? and a rare few into bigger risk-takers than ever.
You want to kill off active managers, or make them even more index-like? ?This proposal will help do that.
6) Do you want funds to limit their size to comply with the rules, while the fund firm rolls out “clone” fund 2, 3, 4, 5, etc?
Summary
You will never fully get rid of pricing issues with mutual funds, but the problems are largely self-correcting, and they are not systemic. ?It would be better if the SEC just withdrew these proposed rules. ?My guess is that the costs outweigh the benefits, and by a wide margin.
This article is another experiment. Please bear with me.
Q: What is an asset worth?
A: An asset is worth whatever the highest bidder will pay for it at the time you offer it for sale.
Q: Come on, the value of an asset must be more enduring than that. ?You look at the balance sheets of corporations, and they don’t list their assets at sales prices.
A: That’s for a different purpose. ?We can’t get the prices of all assets to trade frequently. ?The economic world isn’t only about trading, it is about building objects, offering services… and really, it is about making people happier through service. ?Because the assets don’t trade regularly, they are entered onto the balance sheet at:
Cost, which is sometimes adjusted for cost and other things that are time-related, and subject to writedowns.
The value of the asset at its most recent sale date before the date of the statement
An estimated value calculated from sales of assets like it, meant to reflect the likely markets at the time of the statement — what might the price be in a deal between and un-coerced buyer and seller?
Anyway, values in financial statements are only indicative of aspects of value. ?Few investors use them in detail. ?Even value investors who use the detailed balance sheet values in their investment decisions make extensive adjustments to them to try to make them more realistic. ?Other value investors look at where the prices of similar companies that went private to try to estimate the value of public equities.
Certainly the same thing goes on with real estate. ?Realtors and appraisers come up with values of comparable properties, and make adjustments to try to estimate the value of the property in question. ?Much as realtors don’t like Zillow, it does the same thing just with a huge econometric model that factors in as much information as they have regarding the likely prices of residential real estate given the prices of the sparse number of sales that they have to work from.
Q: What if it’s a bad day when I offer my asset for sale? ?Is my asset worth less simply because of transitory conditions?
A: Do you have to sell your asset that day or not?
Q: Why does that matter?
A: If you don’t need the money immediately, you could wait. ?You also don’t have to auction the asset if you think that hiring an expert come in and talk with a variety of motivated buyers could result in a better price after commissions. ?There are no guarantees of a better result there though.
The same problem exists on the stock market. ?If you want the the money now, issue a market order to sell the security, and you will get something close to the best price at that moment. ?That said, I never use market orders.
Q: Why don’t you use market orders?
A: I don’t want to be left at the mercy of those trading rapidly in the markets. ?I would rather set out a price that I think someone will transact at, and adjust it if need be. ?Nothing is guaranteed — a trade might not get done. ?But I won’t get caught in a “flash crash” type of scenario, or most other types of minor market manipulation.
Patience is a virtue in buying and selling, as is the option of walking away. ?If you seem to be a forced seller, buyers will lower their bids if you seem to be desperate. ?You may not notice this in liquid stocks, but in illiquid stocks and other illiquid assets, this is definitely a factor.
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That’s all for now. ?If anyone has any ideas on if, where, or how I should continue this piece, let me know in the comments, or send me an e-mail. ?Thanks for reading.
