Sunday, January 06, 2008

Transparency and the Fed: How the Culture of Risk Was Created

6 January 2008

Henry Kaufman has written a profound piece that thoroughly deconstructs the chaos that has been unleashed by permissive US government institutions which have fostered a culture of ever-increasing risk-taking for the purposes of fee-generation and market penetration in the mushrooming industry of so-called financially inovative "derivative security creation" (in fact, this financial house of cards is almost entirely about ways to repackage ever-more questionable debt and sell it to the highest bidder as a "premium," higher-interest-rate product in a Fed-created artificially low interest-rate environment).

As Mr. Kaufman's article is entered as a blog "message," I am reproducing it here (in full) for posterity.

Transparency and the Fed
January 3, 2008

Transparency is a hallmark of modern capitalism, and Federal Reserve Chairman Ben Bernanke has made transparency a hallmark of his new regime. Yet among our leading financial institutions, opacity, not financial transparency, has been on the rise.

The combination -- increasingly opaque financial markets and increasingly transparent monetary policy -- has created a dangerous brew of financial excesses. Unless both trends are reversed,
financial stability will remain elusive.

The explanation for increasingly opaque financial markets lies chiefly in securitization -- the conversion of non-marketable assets into marketable obligations -- which has accelerated dramatically in recent decades.

In theory, securitized markets are supposed to operate on the basis of accurate and readily available prices, the clear assessment of credit quality, and objective analyses of these obligations by rating agencies and those engaged in trading and underwriting them. These virtuous mechanisms presumably have been reinforced by a host of new credit instruments, especially financial derivatives that mitigate risk taking. Securitization also has been supported by a dazzling array of new quantitative analytical techniques that are capable, according to practitioners, of defining risk probability down to decimal point levels.

So what went wrong? In the broadest sense, the structural changes in the financial markets encouraged participants to become short-term oriented.

Financial intermediaries quickly recognized that the process of securitization held the potential for enormous profits -- from underwriting, distributing and trading the newly commodified obligations, as well as from managing them for others. To many, the profit potential seemed virtually unlimited, because it stretched well beyond non-marketable assets (like a mortgage) and was global in scope. Thus securitization drove a massive wave of credit creation and helped lift the level of
financial-market transactions to record levels.

The new credit entrepreneurship paid off handsomely. For nearly a decade -- up to mid 2007 -- financial profits outpaced the growth of profits in the broader markets.

But the fervor for profits from securitization also ushered in a host of less apparent, and less cheery, institutional shifts. Senior managers at a growing number of leading financial institutions either lost control of risk management or became its captives. In some cases, this happened as managers struggled to understand the dazzling complexity and diversity of the risks assumed by
their financial conglomerates. And every institution, of course, felt growing competitive pressure to take on risk in order to maintain market share.

The glamour and profit of risk-taking insured that the risk-takers themselves gained more and more power within the structure of financial institutions. With the eclipse of partnerships on Wall Street, investment banks and other financial institutions are now owned by absentee stockholders, the vast majority of whom lack the information and the analytical skills needed to judge the risk portfolios of their institutions. In any case, it is the rare shareholder who will voice displeasure during favorable markets.

Power and decision-making increasingly resided in the middle ranks of leading financial
institutions. Unlike top managers, who are supposed to take the long view and think strategically, those in the middle ranks -- traders, investment bankers and managers of proprietary activities -- compete in arenas that are by nature focused on the near term. They are the rainmakers. They and their institutions thrive on profits from securitized markets and on ever-expanding asset markets. They are biased to pursue ever greater levels of risk.

Incentive systems within financial institutions offer few restraints. It is possible, though rare, for top managers to be removed from office. But even then, judging by recent events, compensation packages for the deposed are more than generous. Middle managers are sometimes dismissed, but they too typically received generous termination payments as part of their contractual arrangements. Such arrangements are net losses for employers, for there are no claw-back
provisions to recoup any of the losses incurred by the former managers.

As financial markets have become opaque and risk-laden, the Federal Reserve has touted its own growing transparency. Yet the central bank has made no real effort to compel financial institutions to follow suit.

When the Fed failed to put into place new disclosure requirements or otherwise penetrate market opacity, market participants took note and devised new ways to camouflage risk and create additional excessive credit.

Some of the Special Investment Vehicles (SIVs) that contributed to the recent hemorrhaging of the money market were an off-balance-sheet activity of bank holding companies -- and therefore subject to Federal Reserve supervision. But the Fed seemed satisfied to allow them, as long as it determined that the value-at-risk procedure employed by these holding companies fell within generally accepted parameters.

Rather than focus on the threat posed by the lack of transparency, the Fed has focused on mechanical deficiencies in the market. For instance, regulators tried to insure that the huge volume of trades would be cleared quickly and with correct documentation. This is worthwhile, but by itself cannot forestall credit abuses. By failing to acknowledge and attack risks posed by opaque
financial practices, the Fed encouraged them.

Ironically, the Fed's own transparency -- as demonstrated by the new tenor of the central bank's open market pronouncements in recent years -- has tended to foster rather than dampen financial excesses. Perhaps nothing better illustrates the Fed's lack of pre-emptive restraint than what has become known in the investment community as the "Greenspan Put."

Briefly stated, this is the now-prevailing view that monetary authorities do not know when a full-blown credit bubble is upon us, but that they do know what to do once a bubble bursts. I have long argued this approach condones excessive credit growth. Massive infusion of new funds following a major market collapse can provide temporary relief, but it does not repair the long-term political, social and economic damage caused by the meltdown. How can this monetary approach not reduce market discipline before the collapse, or incite a quick return to speculative activities after the Fed rescue?

Consider another example of the Fed's transparency policy that is likely to backfire. In November 2007, the Fed announced that it will "increase the frequency and content" of its economic projections released to the public. Rather than twice a year, the Fed will announce them quarterly;
and it will extend the forecast horizon to three years from two.

At first blush, these might seem like moves in a positive direction. But will they actually diminish market opacity or restrain market activity within prudent bounds?

This is highly unlikely. That is the case, at least, for the Fed's first, more-detailed economic pronouncement, which predicted moderate economic growth for the next three years, inflation to remain within acceptable bounds, and high resource utilization, as measured by the unemployment rate. In contrast, if the Fed were to project a significant escalation in the inflation rate or a sharp cyclical turn to a business recession, financial markets would recoil, and the central bank would be blamed for damaging the economy.

What would be more helpful is what is currently missing from the Fed's current repertoire: the central bank's assessment of financial developments for the next three years, and the specific interest rate range needed if the Fed is to achieve its economic targets.

At the heart of the Federal Reserve's diminished influence as a positive economic influence is its ambivalent core philosophy. During his long tenure as Fed chairman, Alan Greenspan ostensibly was an economic libertarian. This means not only that the market knows best, but that the market should decide winners and losers.

I say "ostensibly," because, like Mr. Greenspan and the central bank that continues in the shadow of his legacy, most Americans applaud competition while being uncomfortable with certain kinds of personal and institutional failure. There is no better example than our attitudes about the failure of large financial institutions.

With huge liabilities resting on a thin capital base, they are vulnerable giants. Yet they are the custodians of the public's temporary funds, savings and investments. They cannot be allowed to fail. The costs -- financially and economically, socially and politically, domestically and internationally -- are unacceptable.

So many economic libertarians such as Alan Greenspan live uncomfortably with the doctrine of too-big-to-fail. Nevertheless, one cannot be a true advocate of the philosophy by adhering to it when monetary ease is the order of the day, and abandoning it when market discipline punishes those who have committed financial excesses.

Even out of office, Mr. Greenspan continues to want it both ways. His best-selling memoir reasserts his laissez-faire philosophy, but in a recent pronouncement he advocated giving funds directly to needy subprime mortgage borrowers to permit them to meet their contractual mortgage obligations.

This would have three consequences. It would alleviate the immediate pain of the borrowers (who should not have been allowed to borrow in the first place). It would keep the façade of the financial system in place without disciplining excessive lending practices. And it would socialize the cost of the problem by raising the government's budget deficit.

Today, a shrinking number of huge, integrated financial conglomerates dominate markets. They offer a full range of financial services -- commercial banking, investment banking, insurance, credit cards, asset management, mutual funds, pension funds and so on. But annual reports, 10-K reports and other currently required reporting tools give us little idea of the true extent of their risk-taking activities.

My own preliminary efforts to calculate, for a book in progress, the proportion of risk exposure to tangible financial assets within these institutions suggests a ratio of dozens of dollars at risk for each one in hand. Our economy would be better off if the Federal Reserve focused its campaign for greater transparency on those leveraged giants, rather than making the kinds of pronouncements that encourage them to take on even more risk.

Mr. Kaufman is president of Henry Kaufman & Company Inc., an economic and financial consulting firm, and author of "On Money and Markets: A Wall Street Memoir" (McGraw-Hill, 2001).

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