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Posts categorized "Investment Banking"
Transparency Regulation is not Transparent.
Decent FT article on the problems with the transparency of stress testing of financial institutions in Europe.
Posted by Brian Sentance | 9 July 2010 | 3:31 pm
The Humans Between Risk and Data
Some of my thoughts on risk management, data management and human behaviour, are to be found on page 20 of the Inside Reference Data Special Report "Managing Risk"
Posted by Brian Sentance | 21 June 2010 | 2:22 pm
A Crisis Needs a Utility?
I heard Francis Gross of the ECB speak at one of the panel events at the XTrakter Conference last week, and found that I couldn't avoid asking him whether the aims of the "Data Utility" initiative by the ECB could be better separated from the means by which the ECB proposes to solve them. At the moment, reference data issues for the industry and the data utility seem to be presented as a single "package". I can't say that the response to my question was a clear one to my understanding; however I would say that Francis was helpful after the panel had finished and provided a recent presentation of their ideas, of which you can find a copy here.
Looking through the presentation, the motivations put forward for why the industry needs a data utility seem to include:
- Data processing must be done in an automated manner, since data volumes have moved beyond the capabilities of manual processing.
- can't see anyone arguing with this - Data is a major bottleneck, with multiple providers/sources each with the own "data dialect"
- agreed and to some extent what keeps data/data management vendors in business, but sounds sensible to standardise if possible as there are plenty of other problems to address - These data dialects lead to increased cost, operational risk and reduced responsiveness
- agreed, mainly a cost aspect I would suggest - The recent crisis was not helped by weak data management in the industry
- but nor was it the cause, so not a great premise for a data utility -
- lack of transparency of data
- "transparency" is an over-used word at the moment, but certainly clarity and quality were/are needed - systematic risk could not be assessed due to the availability of data
- using terms like "systematic risk" seems to imply the regulators could calculate something, whereas this discipline is new so I guess we are really talking about simply knowing who is exposed to who and how.
- lack of transparency of data
- fundamentally agreed but also good to qualify with what you propose to be calculated - having a set of "numbers" doesn't seem to have helped much recently...
I started the above bullet point list by saying it contains the motivations for "why the industry needs a data utility" but I guess looking at the above list they really point to the more general aim of "why we need better industry-level data management". In the presentation the above points are then used to state:
"We all need the same good basic reference data. Why build more than one infrastructure?"
Maybe "Why build more than one infrastructure?" should really be changed to say "Why maintain more than one infrastructure?" given that Bloomberg, Thomson Reuters, Six Telekurs, Interactive, Markit and all the other vendors already infrastructure to do this. Not sure if I should read anything into the wording but more logical leaps of faith are to follow.
The presentation then moves on to state that shared reference data standards are a must, to which I cannot see many consumers of data disagreeing with that statement. Not sure I agree though with the overly simplistic statement that "Data will be good for all users or good for none". Trying telling that to the accountancy and risk departments for example but I suppose what we are talking about here is basic reference data not the more subjective price and valuation data. Reference data on instruments and entities is either right or wrong, and the presentation makes the good point that no amount of "data cleaning" can help this i.e. if wrong, the data needs to be re-captured from an accurate source.
The call for the establishment and use of reference data standards in the presentation then seems to be used to "slide "into a call for a standard reference data infrastructure. Unless I am very much mistaken, these two things are not necessarily the same thing and so it seems a logical leap has been taken here. The presentation talks about the possible necessity of "top down" legal compulsion for the industry, again something that I could agree and see the need for, but both the issues and legal compulsion do not automatically drive us to a "data utility" as the only option? Why couldn't legal compulsion be applied to the existing data vendors to standardise on common IDs for instance? ISIN is proposed as a standard in the presentation, but I can only assume that this is due to the ECB being mainly focussed on the bond world where to a large degree ISIN's work (i.e. are unique), whereas in the world of equities ISIN needs a lot of qualification (currency, exchange, share class...) before it uniquely identifies a quoted equity.
In summary, the presentation starts with showing how great the ECB's Centralised Security DataBase is (7 million securities, 3 million record updates/day etc...) and it does look good. The data issues for the industry seem clear, although I think the "crisis" is a bit of a red herring to the aim of data cost reduction, however the logical jump from industry need to effectively "we must have a data utility" is an interesting one, one where I would prefer that more options were discussed. It seems ironic that in these days of "transparency" it is not at all that transparent to me why more alternative solutions are not being discussed and a choice justified. Talking of choice and as a final thought, I am also not sure why the data vendors are not up in arms about this initiative - are they frantically lobbying behind the scenes? - do they simply think the utility won't go ahead? - or are they afraid of upsetting the EU? Any insight is very welcome, and maybe more of update from me when I get chance to speak with Francis in more detail.
Posted by Brian Sentance | 4 June 2010 | 8:00 am
XTrakter Conference
I went along to the XTrakter Annual User Conference in London on Thursday - Good event with some great speakers. Angela Knight, CEO of the British Bankers Association, gave a talk to start off the day. Angela seemed a lot less on the defensive than when I have heard her on national radio here in the UK, usually being interrogated by some journalist who wants answers to difficult questions on the financial crisis and the banks role within it.
Angela said that we were in year 3 of the "crisis" with 2008 being about the banks, 2009 being about governments and politics and 2010 being the year of sovereign debt. I guess she enjoyed saying this but that everyone is blaming "Anglo Saxon Banking" for our problems and yet it was not the banks that contributed to the fundamental problems that Greece is facing.
One major theme of her talk was decidedly Euro-Sceptic in tone, which was that the UK idea of internationality and international trade was different from that of Europe. She perceived that in the UK one of our trading parties is Europe, whereas international trade in Europe was more about inter-European and not world-wide trade - I think that there are elements of truth in this but not sure that Germany industry for example would agree that it is not conscious of truly "global" trade? She said that she was concerned by the rules and regulation being put up by governments, particularly in respect of there being too much and in too short a time.
Angela was an engaging speaker and at the very least her opinions prompt reaction, however I have to end this quick post with the best quote of the morning from Anthony Belchambers, CEO of the Futures and Options Association. Anthony said that current frenzy around political and regulatory initiatives to control the financial markets remind him of:
"A bar room brawl, where the brawlers don't punch the person that started the fight, they punch the person they have always wanted to punch..."
Posted by Brian Sentance | 24 May 2010 | 4:11 pm
Accountants, Prices and Upsidedown Elastic...
I am sure I am not the only one who has had to suffer the boredom of a economics lecture on price elasticity, but my interest in this old topic was sparked by an article by Tony Jackson in the FT on Monday, providing a very simple and clear explanation of how mark-to-market accounting (see earlier post) can conspire with leverage to turn price elasticity on its head, so the more something goes up in price, the more in demand it becomes...perhaps I should have paid more (or less?) attention to what the dusty prof was saying...
Posted by Brian Sentance | 31 March 2010 | 12:35 pm
The Value in Product Control
Good post from Robert Peston on the BBC website on part that the Product Control Group did (or rather didn't?...) play in the problems at Lehman's, according to the official US bankruptcy report on Lehman's by Anton Valukas.The post highlights the report's findings that the Product Control Group did not have the quant experience to keep up with CDO trading desk.
Interesting findings on Lehman's, but variants on this theme seem to be elsewhere too. A contact who knew Merrill's New York trading operation in the run up to the crisis recently asked me how many quants did I think used to work on the CDO trading desk. The surprising (?) answer was not one...
Posted by Brian Sentance | 21 March 2010 | 5:22 pm
Data models are not what they used to be...
AIM have released the results from their 2009 survey on reference data management which is worth a look, particularly given the 2008 results are also shown for comparison. Seems like Mike Atkin and the EDM Council have their work cut out in getting the Semantics Repository adopted if the survey is anything to go by, with the number of institutions using standards-based data models having dropped significantly when comparing 2009 to 2008. What is going on there in these heady days of the finance industry sorting out its data problem through adopting standards? - In cash starved times, maybe it costs more to conform to a standard? - Is the survey data not broad enough? Any ideas appreciated!
Posted by Brian Sentance | 18 March 2010 | 8:09 pm
How not to do marketing #1
I ran into this very funny post on the rebranding of Fortis into "ageas". Worth reading (and learning from it)! Also don't miss some of the comments posted for how other banks in the news could be renamed - join the debate and enter your suggestions too!
Posted by Sara Verri | 11 March 2010 | 3:43 pm
One man's speculation is another man's insurance...
The current finanical crisis in Greece has prompted an outburst of entertaining discussion at the FT about CDS contracts, initiated by a feature article by Wolfgang Munchau who advocates that naked CDS contracts should be banned. The main argument used is that you should not be able to insure against a risk that you do not face e.g. buying insurance on somebody else's house then arranging to have the house burnt down. In support of Mr Munchau, one reader letter points out that insurance without interest in the insured item has been illegal since 1746, which on the face of it seems a long enough time to be a credible point in the discussion.
However, in using this argument then Mr Munchau seems be to attacking the whole of the derivatives industry not just CDS, for example the same argument could be used to ban the use of naked index puts to hedge equity market risk. I guess he is also helping some of the politicians in the EU direct attention away from Greece's financial mismanagement more towards the "evils" of the derivatives markets and hedge funds.
Some good letters in response, for instance this one with a good illustration of what hedging would be like without intermediaries to buy and sell risks that they do not own, plus another more direct one from the Association of Corporate Treasurers.
Whilst talking of Greece and credit, the FT Alphaville team also poked some fun at Anatole Kaletsky, the economist of the London Times Newspaper, who has recently done some interesting articles in the paper concerning his predictions about the stresses being suffered by Greece and the Euro. From their post, it would seem that Mr Kaletsky also runs a credit related fund, so it is implied that some of his newspaper views need to "calibrated" against his own vested interests...
Posted by Brian Sentance | 9 March 2010 | 2:40 pm
Data Management Panel
Thomson Reuters held a panel event on data management at their London offices on Tuesday last week, with speakers from Barcap, LCH.Clearnet, DB, Mizuho and Citi. This event was held in follow up to their recent report "Beyond Golden Copy". Below are some of my notes on the summary points the panelists made:
- The Value of Data - Kris Bhattacharjee of Barcap said that there were currently two main drivers behind the perceived business value of data; i) Regulators are expecting more information, adding additional requirements and conducting more adhoc reporting requests. ii) Business users/decision makers want more granular understanding of trading and risk management data, in order to decide how best to allocate scarce capital to what trading positions.
- Data Metrics - Kris said that the metrics were many but timeliness of data was becoming a key metric - over the past two years regulators have moved from allowing say 2 months as a reporting timeline down to 10 days recently. Additionally timeliness is again vital as regulators demand adhoc reporting in response to market events.
- Accuracy/Completeness - Again regulators are driving this, with the "bad numbers in, bad numbers out" as the main motivation. Unsurprisingly, counterparty data is also being required at a new level of detail and accuracy down to a portfolio level in light of the crisis.
- Granularity of Data - Deeper granularity of data being driven by scarce capital and the need to understand how efficiently it is being used. Basel II has also driven greater granularity over Basel I. Reflecting what I have heard from some our clients, Kris added that the data associated with securitised products had increased greatly as people need to understand exposure/risk and pricing in more detail (rather than assume blanket statistical behaviour for a whole basket of assets).
- Stress Scenarios - Kris again mentioned the understanding of counterparty exposure driving the need for new data sets, as had the initiative of banks having "living wills" to allow a bank to be wound down in an orderly manner.
- Everybody has Left the Building! - Martin Taylor of LCH.Clearnet was a great speaker and said that the biggest new problem that the collapse of Lehman's created was that ordinarily there are people around to help with extracting from systems what the exposure is to the various counterparties. In the Lehman's case there was nobody around to help, making the process very difficult and leading to the need for changes to address this problem.
- Mandating Data Integrity - Martin added that data security, integrity and auditabiliy were vital, and in particular put emphasis on the people that are running the systems that they have their own form of integrity so that an institution knows that the people can trusted but is also capable to deal with a situation where the people are not around to help. Martin felt that this level of data management should be mandated on the industry and that there was an awful lot that finance could learn from industries such as Pharmaceuticals in terms of product approval and management/robustness of data.
- Data with No Cost or Value - Neil Fletcher of DB was another good speaker who started his talk by saying that pre-crisis people thought of data as project based, otherwise dealt with it on an adhoc basis and considered data as having no cost or value. Institutions had a spaghetti approach to data, with systems/projects being process not data based i.e. the systems get only the isolated data sets they need only when they need it.
- Quality is Now the Data Driver - Neil said that 18 months on from the crisis, then whilst ROI is still important for data projects then quality of data is the key driver.
- Sponsorship and Ownership of Data - Neil added that quality data is an asset as are the systems that produce data quality, and to ensure success data management projects needed high level business sponsorship, but also ongoing and clearly defined ownership of all data sets and their quality.
- Enterprise Data Virtualisation - Neil said that DB were embarking on a long term project to ensure that all systems get data from the same logical place on a global basis, and that they were investing heavily in data virtualisation technology as a key means of achieving this goal. DB are starting with reference data, moving to transactional/positional data and on to other data types. For each type/category of data ownership would be clearly defined across all systems and would enable real-time transformation of the data into whatever format it is needed in.
- Enterprise Data Model - Neil said that as a result of this virtualisation approach then you have to invest in putting together an enterprise data model for all data used in an institution. From my point of view this could be interpreted as a move back to "big EDM" (with all the project risk that implies) but I guess it is being approach on a more staged manner.
- Lip Service to Data has Ended - Neil summarised by saying that lip service to data management has ended with the start of the crisis and that 18 months on the enthusiasm for dealing with the data problem has not diminished.
- Publish/Validate/Subscribe - Simon Tweddle of Mizuho echoed a lot of what Neil said in approach to global data management and ownership, but added that he believed that the model of publish/subscribe needs to change to publish/validate/subscribe to ensure data quality.
Most of the panelists agreed that bringing in experience from external industries (Pharma, Oil & Gas, Internet Search etc) would be beneficial since we should not assume that the financial market has the expertise to get data management right first time (take a look at this article from the FT for a related idea). Martin of LCH.Clearnet was convinced that mandated data management would come and would be beneficial, which some of other panelists did not agree with and suggested that the industry needs to get ahead of the regulators to head this possibility off. Simon said that the focus on complex data/products was wrong given that the basics (what is our exposure to this counterparty?) were not being done (not sure I agree with this totally, both are needed given the losses from CDOs etc). Overall it was good panel with some interesting debate and speakers.
Posted by Brian Sentance | 8 March 2010 | 2:30 pm
Beyond Golden Copy?
Interesting reading in a survey put together by Lepus and Thomson Reuters and publicised on Finextra this week. Summary findings:
- Data management budgets are increasing, with 77% of firms intending to increase spend on data quality and consistency and 32% saying spend would increase significantly.
- Tearing down data silos is a key initiative, 70% of firms are looking to revise data management solutions as a result of the crisis, and 31% of firms cited data quality and consistency as the most important driver.
- Data management for risk is the top concern, with 87.25% of firms looking to integrate data repositories in risk, and 62.5% saying that they were close/very close.
This seems to be consistent with another article on Finextra this week, with Deloitte predicting a much greater spend on risk management projects. Putting the marketing aspects aside for a moment, I don't think it is abundantly clear from the actual content of the Lepus survey as to why the title includes the phrase "...Beyond Golden Copy" other than the type of data management they refer to seems to have more emphasis on global/firm-wide data integration than your traditional EDM golden copy data warehouse approach.
It is also interesting to hear so much about consistent data across the entire enterprise (driven by risk and regulation) which seems to echo the "big EDM" projects of old that did prove that successful, and to some degree is at odds with what the likes of Golden Source and Asset Control are currently saying about choosing smaller projects to bite off on rather than the enterprise approach. I would suggest however that there is no issue in having smaller projects in mind so long as they are compatible with the overall goal.
The integration and consistentency of data across front, middle and back office was also interesting, and in particular the front office integration echos some of the things I have been saying about the need for analytics management and the management of front office data as part of the data management process, not something to be ignored in the hope it sorts itself out.
Posted by Brian Sentance | 5 March 2010 | 3:28 pm
More Products, Less Complexity?
Decent article(and title!) explaining ETFs in FTfm today - growth of the market sounds impressive, from $40bn in the year 2000 to over $1,000bn under management now. Seemed like a bit of a day for new financial products in the FT, with the LSE announcement of opening up direct bond trading to retail investors through offering corporate bonds issued in sizes well below the usual £50,000 size (and catching up with more usual practice in Europe). Whilst not a retail product (I guess some of us already have life insurance?), longevity derivatives seem to continue their rise too in liability driven investment.
Meanwhile over on Linkedin, Structured Products magazine are asking just what constitutes a "complex" product? A decent question since complex products are not necessarily risky, but certainly "complexity is in the eye of the beholder" is most likely answer in my view - echoing a growing problem in finance, regulation and economics at the moment; there are too many people searching for the unique "right" answer to questions that simply do not have one. Maybe we should stick to the answer to everything being "42" and give up the search for the question?...
Posted by Brian Sentance | 2 February 2010 | 1:51 pm
RiskMinds - VaR as simple as chartism?
Interesting panel debate at RiskMinds Wednesday morning, entitled "Sophisticated Complex Models vs. Crude Robust Risk Measures".
Riccardo Rebonato of RBS started off the debate in (untypically?) controversial style by saying that he thinks that the risk management models (mostly VaR) used in financial markets are peculiar. Peculiar in that coming from a physics background he is used to models that have "causal" links between inputs and outputs, whereas VaR is based simply on the P&L distribution of a portfolio i.e. all the information is contained in the data itself. Riccardo said the obvious analogy was with chartism, where decisions are made on the observed market data itself without any reference to external (exogenous) factors at all (perhaps he should have a discussion on endogenous risk with Jean-Phillippe Bouchard at Quant Invest). Riccardo suggested that in the range of models from those that are "over specified" with two many inputs to those in "reduced form", then VaR was far too much at the reduced form end.
In response to Riccardo's proposal that risk models should involve more causal ("factor") effects, Andreas Gottschling of Deutshe Bank countered with the quote from Harry S. Truman "Give me a one-handed economist! All my economists say, On the one hand on the other.". To which Riccardo acknowledged that maybe Economists and Econometrics were less suited to trading/analyst reports (e.g. give me a single view of what the prospects/returns will be) and more suited to risk management (e.g. give me a range of scenarios with supporting assumptions for each).
Chris Finger of RiskMetrics moved on to put forward an argument for standardisation of risk reporting, saying that it was impossible to say what methodology was behind the VaR numbers disclosed by major financial institutions. He proposed that risk reporting needed to be standardised and obligatory, but emphasised that risk management should not standardised. Paul Shotton of UBS agreed, saying that whilst micro-prudential risk of Pillar I had decreased risk on an individual institution level, it had increased systematic (macro) level risk and this was an area of failure for the regulators. On this the panel agreed, echoing a lot of what Avinash Persaud said in proposing the more diversity of risk management was highly desirable.
On standardisation, Riccardo noted that many banks had switched from using 10-day to adjusting up a 1-day VaR, and as a result presenting a less risky picture to analysts and regulators, regardless of how risky the "tail" of each institutions' P&L distribution is. Riccardo also proposed that there should be "constructive ambiguity" over what is asked of the banks by the regulators - put another way he suggested the regulators should come up with the "curriculum" for risk but not the "questions", as definitive questions encourage arbitrage.
Andreas then brought the debate back to its title, and put forward that maybe VaR should be replaced by simpler measures such as limits on notional traded. Paul suggested that VaR was only good for simpler products and portfolios, under "normal" market conditions. He said that he had been an advocate of more stress testing for a long time as a complimentary approach to VaR, but also combined with the simpler approach of limits.
It was an interesting debate, particularly with Riccardo's proposal on VaR being too simple a measure based on statistics, and wanting a more "causal" model to be developed. Using the example of June 2007, Riccardo said that everyone knew something big was about to happen but this was not reflected in VaR calculations since they are statistically based and inherently backwards-looking and not predictive. The lack of prediction is a very valid point, but putting forward a counter-view, then I get the argument about economists giving a range of outcomes, but surely these should be fed into the scenario engine rather than trying to develop econometric models of relationships between market variables. Econometric models are just as vunerable as any other to the mis-behaviour of markets (anyone seen a stable correlation lately?).
A few of the other risk managers there expressed other views, from the more buy-side folks who were more comfortable with factor-based modelling, to risk managers who said that VaR was already "structural" with explicit relationships between valuations and interest rate inputs for example. It would be good to understand more of Riccardo's ideas on this, since it appeals from making risk a more "forward-looking" process but I find it difficult to quite grasp what "causal" model you can have of markets that is itself robust to changes in market behaviour.
Posted by Brian Sentance | 11 December 2009 | 4:52 pm
RiskMinds - The Failure of Risk Models
Avinash Persaud of Intelligence Capital gave the opening talk of the morning at RiskMinds (see first of set of posts from last year here) and put forward a lot of the very good ideas that he has contributed to in the recent Warwick Commission Report. Main points that Avinash made:
- Regulators were admirably quick in working out where past regulation had gone wrong in focussing too much on micro (individual institution) rather than macro (whole market)/systematic risk.
- The regulators then came out with promising papers on counter cyclical regulation and other positive ideas.
- These new ideas do not win votes however and do not satisfy the public's desire to punish someone - Avinash called this the "Bad Apple" policy, with "bad bankers, bad products, bad jurisdictions" being the perceived guilty parties.
- All past crises have resulted in demands for three things: i) more risk management; ii) more regulation; and iii) more transparency.
- These are fine as demands but evidently do not prevent financial crises.
- Avinash recalled his work back at JPMorgan in the early 90's when the 4:15 report was produced for Sam Weill, which eventually led to VAR reporting becoming widespread.
- He then fast forwarded to the Asian crisis of 97 where he saw the failings of VAR (or rather its widespread use) first hand with all players using VAR which when volatility increased caused an increase in VAR causing JPM (and all) to sell causing markets to fall, increasing vol causing more selling, increasing correlation and leading to what is called the "loss spiral".
- In light of the recent crisis, Avinash said the public perception is that bankers created a load of toxic bombs (products), through them at an unsuspecting public and ran away...
- ...and in his opinion the reality is that banks created a load of toxic bombs and ran straight towards them i.e. this was a failure of risk management where bankers did not understand the risks they were buying and selling.
- He then took us back to the 1950's and the formation of modern portfolio theory with Markowitz and Danzig working at the RAND Corporation.
- At that time banks and insurers were still separate, with FX and capital controls still in place meaning that not only could the "efficient frontier" of investment portfolios be observed but it could also be acted upon.
- Now everyone has the same information everyone can observe the efficient frontier of investment opportunities but cannot exploit or act upon it, since usually everyone moves in (the "herd") and the value observed is changed by this crowded participation in the market. Here he seems to be echoing a lot of what Bob Litterman said at QuantInvest last week over the "crowded trade" and that the barriers to market knowledge and our ability to act on this knowledge have been lowered forever.
- Avinash put forward that many of the models we use today assume the statistical independence of decision making process whereas the reality is that the market is homogenous (everyone is thinking/acting the same) and hence these models are invalid in this "crowded" context.
- In light of this, the problem of risk management is not about exogenous risk (risks from outside the market, from Black Swan events to normal distributions) but more about endogenous risk i.e. peoples behaviours upon seeing opportunities cause strategic risks. (Interesting given Jean-Phillippe Bouchard at QuantInvest commenting on what makes prices move). Put another way, behaviour is the issue not the financial instruments themselves.
- Avinash proposes that risk capacity (the ability of an institution to absorb a particular type of risk) shoudl be thought through more fully, with for example insurance and pension institutions with long-term liabilities having a much greater capacity to absorb liquidity risk than banks, and banks with short term funding being a better position to manage a loan book.
- He pointed out that regulation that uses market prices to protect us against movements in market prices is doomed to failure before it starts.
- Booms occur due to some perceived "paradigm shift" technolgy leading to dramatically improved risk/return ratios - he cited things such as cars, electricity, rail, dotcom and the mantra from those involved that "This time it is different..." (see "bubble" post from last year)
- Avinash thinks the regulators are significantly to blame for the last crisis since they themselves said the latest financial innovations in credit derivatives were making us safer through sharing out risk in the system.
- He said that there is no theory for making a complex system "safe" as a whole and that the regulators did not/do not "get" this idea.
- Diversity of approach and risks in a large systems (macro financial markets) is our only current defence and regulatory "best practice" has driven conformity not diversity in the market, making systemic risks higher not lower.
- So the regulators are themselves creating a homogenised market.
- In terms of solutions, he proposes that risk and audit committees need separating so that risk management does not become a "tick box" exercise.
- He further proposes that the risk management function is given some capital so that it can place hedges at a macro level for institution (i.e. looking at the resulting risk when divisional risks have been aggregated) - here is proposing moving to risk "management" as opposed to the much more common risk "reporting" found in many institutions.
- One risk management indicator idea he proposed was to put a portfolio management model together that was linked to VAR in order to see where the "herd" is moving to (e.g. low vol, high return Asian markets of the past etc) and to move or hedge against this.
- He is concerned that applying Basel II regulation to the Insurance industry with Solvency II will mean that all players will be dancing to same VAR tune which will introduce more risk as more institutions are forced to react in the same way to market movements and volatility.
- On the same lines, Credit Rating Agency regulation will create barriers to changes in ratings methodology in response to endogenous market risk, again meaning that everyone will be forced to behave and act in the same ways.
- He summarised that "endogenous risk" (movements in the market caused by the market) and not statistical distributions that are the key issue and diversity is the only solution.
Entertaining speaker with some interesting ideas that fly in the face of much of what is being done by the regulators today, and generally well received by many of the risk managers present. Behavioural finance and the "crowded trade" (i.e. everyone doing the same thing in the market causing movements within the market) seem to be key themes occuring in a lot of what academics and practitioners have said on risk management recently. Now what to do about it? Not sure that less (not more) regulation will find many fans at the moment...answers on a postcard please!
Posted by Brian Sentance | 8 December 2009 | 10:04 pm
It's in the hormones...
Taking the discussion on behavioural finance and news analytics a scientific step further, then this article in the FT today on how increased testorone equals an increased appetite for risk taking is interesting. Apparently experience of trading is also a big help in increasing a trader's Sharpe ratio, from which the authors suggest that markets are not efficient and the EMH does not hold. Now if only they could find a hormone that was correlated with increased returns, then I think they'd really have something...
Posted by Brian Sentance | 25 November 2009 | 7:12 pm
Views on Fair Value...
Busy week last week for events in London, this time over at the Goodacre / Six Telekurs on Thursday morning. Guy Sears of the IMA was chair of the event, and the event did have a "buy-side" focus to it. Richard Newbury of Six Telekurs started the event and made the following points on the current state of regulation:
- UCITS IV - Richard cited the stats that there are around 37,500 funds in the EU with average value of approximately $180M each as compared to only 8,000 funds in the US with average value over $1B. Richard said that such a proliferation of funds was costly and the more EU could standardise funds and their ability to be transacted everywhere in the EU the better.
- Reg NMS - Richard took a little humorous dig at US regulators when he reminded us that Congress authorised the SEC to form a "National Markets System" in 1975 and so this had taken around 30 years to implement. Whilst Reg NMS is often compared to MiFID, he said that Reg NMS had led to consolidation in the US while obviously MiFID has led to fragmentation in the EU.
- Hedge Funds - Both EU and US regulators are looking at the hedge fund industry. He mentioned the battle the UK was having with some of the (misguided?) regulation that the EU is trying to introduce with over 30,000 HF related jobs in London. The new regulation is likely to increase reporting requirements leading to more need for regular, standardised fair value reporting.
- Credit Rating Agencies - Richard mentioned how there will be more ratings and more ratings types, and the regulation introduced to ensure the CRA do not fall into the conflict of interest trap.
- Data Management - He mentioned the importance of data management within what is happening in the industry and noted how the profile of data management was on the increase.
Mike Jenkins of Ernst & Young tried his best to make the accountancy treatment of derivatives interesting and didn't do too bad an effort but I only took the following few notes from his talk:
- Unlike US GAAP with FAS 157 there is no single standard Fair Value (FV) definition in IFRS, and unsurprisingly IASB are addressing this.
- Mike spent some time mentioning Level 1(quoted), Level 2 (observable) and Level 3 (unobservable) pricing inputs for securites, taken from the IASB exposure draft ED/2009/5 (also see Rowe in earlier post)
Matthew Cox of BoNY Mellon Security Services then gave his presentation on the difficulties/challenges of providing a valuation service to their asset management clients:
- His division often have a "2 hour" window to produce valuations for NAV reporting, often for a 12 midday valuation
- Data exceptions for investigation went through the roof this year due to increased volatility (comment: didn't get chance to ask whether the validations set were "normalised" for market volatility i.e. a price movement threshold would not be fixed but rather be multiplied by a factor relating to recent volatility levels)
- Matthew was very complimentary about the efforts his team put in to cope with this increase in data exceptions.
- He mentioned how many of his clients of established "Fair Value Committees" over the past couple of years, comprised of staff from compliance, risk management, portfolio management etc.
- Matthew mentioned the importance of time zones in valuation and the timeliness of data, with the availability of intraday CDS prices contrasting with bonds who price only from the evening close of the day before.
The panel debate was moderated by Guy Sears, and included the above speakers plus Nigel Reynolds from TD Waterhouse):
- Matthew said that his division sometimes shared the "consensus" price from other clients when one client is looking for some guidance.
- He mentioned that a key timeframe in establishing FV was establishing what is a "reasonable" time frame for sale of a security.
- Nigel Cox said that "suspended stocks" had been a real issue over the past year, where the client "context" (position, situation etc) would very much determine what value a client would want assigned to a holding.
- Guy Sears suggested that valuations should be provided with a confidence interval and not just as a single price
- Mike of E&Y said that this is what full disclosure now requires, other memberrs of the panel suggested this was realistic but not what clients (humans?) expect to receive - they want a single number.
- Guy wondered whether it was an issue that one entity might value an asset at a value X whilst another would value the liability at Y (not equal to X)
- Mike of E&Y pointed out that this was an issue in that current accountancy rules allow a security to be reclassified from "fair value" pricing to "historic cost" basis - this discretion is being removed in future rule implementations
- One member of the audience pointed out that Bloomberg, Reuters and Markit were all trying to extract more revenue from data used for valuation purposes.
- Matthew advocated that the market needed more competition between niche data vendors such as Markit and SuperDerivatives to ensure innovation in service and more competitive pricing.
- The audience asked Guy of the IMA whether the association should have offered more guidance on fair valuation process and best practice.
- Guy said they have provided some, but he advocated that trade associations should not have opinions, since it was not healthy to have the asset management industry collectively herding towards the same valuations.
Well attended event with some good speakers, particularly Guy Sears as host was funny, knowledgeable and kept the other speakers on their toes. I would say the most interesting point was still that "opinions" form prices, opinions formed in the investment/funding "context" of the party with an interest in valuing a security - conceptually this seem to make the asset servicing companies a little uncomfortable since what they are contracted to do is to provide the "right" set of numbers by their clients. Human beings feel more comfortable fixating on a single number than a range of possible outcomes/results it would seem!...
Posted by Brian Sentance | 17 November 2009 | 10:48 am
Shipping Fair Value...
...seems like the shipping industry is as about as confused as the finance industry about establishing "fair value" for assets according to this article in the FT.
Posted by Brian Sentance | 29 October 2009 | 9:13 am
Pricing Model Validation: Mitigating Model Risk
I managed to catch some of the day yesterday at the "Pricing Model Validation: Mitigating Model Risk" conference. I thought it would be worthwhile going along since firstly the past 12-18 months have made model risk very topical (take a look at previous posts from Riskminds, the Modeller's Manifesto and Wilmott/Rowe).
Secondly more of our clients are looking at managing and centralising pricing models/curve calculators in addition to just managing the underlying data (see this Insight Investment client case study for a recent public example). I am calling this "Analytics Management" which is the business-focussed technology stack that combines pricing models/calculators/analytics with all of the "Data Management" underneath. But enough of my thinly-veiled positioning statements...and on with some of the (hopefully) useful content from the conference outlined below - maybe scan the headings in bold below for those talks of interest but I would particularly recommend the ones by Tanguy Dehapiot and Yuyal Millo...
Model Risk 2009 defining and forecasting. First speaker was Professor Phillip Sibbertsen of the University of Hannover on defining and measuring model risk. Phillip started by saying that "Model Risk" was a new category of risk within the confines of "Operational Risk", and that operational risk as defined by the regulators does not yet currently include the "model risk" of market risk and credit risk, nor the "model risk" of the operational risk model itself. (I am sure I could write that up better!...). Phillip put forward that model risk is not formally a "risk" since it has no probability distribution and that he suggested it should be thought of as "model uncertainty". He also clarified that model risk applies both at the large, portfolio scale (e.g. choice of VAR model etc) and at the smaller, instrument level scale (i.e. pricing of derivatives).
Additionally in terms of measuring model risk then he excluded human failure from model risk measurement since in his view this was difficult to quantify - this approach did not meet with the approval of some of the audience were questioning how this could be excluded from a practical point of view. Phillip's colleague, Corinna Luedtke, then presented some work they had done on calibrating different GARCH models to observed data and showing how even a poor model could produce reasonable forecasts of risk if the time period was short. The work was interesting but again the audience highlighted that the human choice (failure?) in choosing the set of models to try was part of "model risk" and should not be excluded from the definition of model risk.
Is a model accurate? Testing the implementation of a model. Second speaker was David Chevance, Head of Equity & FX Model Validation at Dresdner Kleinwort. David outlined the different sorts of model risk: mathematical errors, missing risk factors, divergence from industry practice, model inconsistencies and implementation risk. He then outlined the sources of these risks: bugs, approximations, numerical precision, numerical boundaries and limitations on numerical methods (e.g. Sobol numbers in high dimension monte-carlo simulations).
David said a key area to start with in validating a model implementation was the front-office documentation of the product, its inputs and payoffs, its pricing model but also details of calibration methods used/needed etc. He made the point here that the documentation can sometimes specify just the deal, but sometimes can express the pricing methodology and pricing parameters. The emphasis was on completeness, accuracy and making use of all of the information available in the documentation. Obviously the ability to review the code used to implement the model was also necessary.
He discussed the trade-offs between a simple validation approach in terms of speed and efficiency of resources against the more time-consuming, resource hungry but more accurate approach of full replication of the model. He also suggested that in choosing a method of validation it was important to balance resource demands against what is actually being validated: payoffs from a single trade, a type of pricing model or a family of financial products. Desired accuracy of the validation was also important, given the trade-off between accuracy and effort, and the fact that small bugs are much more common than large.He finally discussed model version control, the necessary discipline of documenting changes and regression tests for new models, and the regular cycle of model review. Overall it was an interesting talk with a good practical focus.
Practical aspects of valuation model control process. One of the most entertaining and interesting speakers of the day was Tanguy Dehapiot, Head of Validation and Valuation, Group Risk Management at BNP Paribas. He started by referring to a few documents "Supervisory guidance for assessing banks’ financial instrument fair value practices", April 2009 (BCBS 153) which was then implemented within “Enhancement to the Basel II framework” (BCBS 157). The first part of his presentation was around these documents and what the regulators expect to be in place, so I guess the best approach is to read them (the BCBS 153 document content is only 12 pages long, quite short for a regulator!)
Tanguy pointed out that in his view "Mark to Market" and "Mark to Model" are often misleading as both are often required. He prefers the term "Valuation Methodology". He proposed four valuation modes: Direct Price Quotation, Use of Similar Instruments, Risk Replication, Expected Uncertain Cashflows (NPV) and categorised a useful hierarchy/matrix of which financial products fit into which valuation mode and for what purposes. Within model risk, he split off judgemental errors (choice of model etc) as part of market risk and credit risk and operational errors (model implementation and coding) as more definable and avoidable parts of operational risk.
He had some interesting slants on data, saying that he had been surprised that even getting all of the static data necessary to price simpler instruments like bonds had proven difficult. He outlined how model parameters are often stored across a variety of systems (curve definitions in one place, pricing methodology somewhere else) implying to me that this is sometimes difficult to pull together and needs some centralisation to improve transparency around this.
His opinion on market parameters (both observed prices and derived data such as implied volatility surfaces) were often stored in a larger central database but warned that this market parameter database needs to be reviewed as part of the model validation process since some of its data is derived (i.e. calculated, maybe using a model!) and as such should not be taken as perfect for all time and for all purposes. He said that it was important to categorise the origin of data and suggested the following types:
- Quoted on an active exchange
- Actual private transaction in an active market
- Tradable broker quotes
- Consensus prices from market makers
- Non-binding indicative prices from market makers
- Counterparty valuation, collateral valuation
- Actual transactions in inactive market
Tanguy proposed that there should a valuation matrix for each instrument, where there might a different valuation methodology used for end of day valuation verses intraday, for risk or for trading, for pricing individually or within a portfolio reval. I guess here the rational is appropriateness, efficiency and transparency about what needs to used when. He also added that he disliked the term "Model Validation" since it seemed to imply that a model was "valid" and preferred "Model Approval" to cover the decision to use a model and "Model Review" to cover model analysis. He said he found managing the "stock" of existing models (and keeping up with when to review them) more difficult than managing the "flow" of new models and products.
Overall Tanguy was a very interesting and funny speaker with lots of practical insights and a fair amount of opinion thrown in, which is always good in my view.
The usefulness of inaccurate models: Financial risk management "in the wild". This talk was given by Dr Yuval Millo of the London School of Economics and he focussed on the evolution of the use of the Black Scholes Merton (B-S-M) model at the CBOE and how the model came to be the means by which the whole options market "communicated". Yuyal is a social scientist and prefaced his talk by stating that "Social Sciences are good at predicting the past"
First thing I didn't know (amongst the many things I do not know...) is that the B-S model was not published until a couple of weeks after the CBOE started trading stock options in April1973. Yuyal said that initially the B-S-M derived prices were not accurate at all (around 25% off the market price on CBOE) and that the model was based on assumptions that plainly were not the case on the exchange (only calls available, no short selling, no continuous trading). The model was used by local Chicago trading firms and the story goes that Fischer Black sold large paper "sheets" of option pricing matrices to these traders (there being no calculators/PCs/mobiles around at the time).
As the markets developed, larger East Coast banks entered the market with stocks being held and traded in New York and options being traded in Chicago, so trading became geographically dispersed. This started the need for "early morning meetings" to discuss the market and the B-S-M model and its parameters became the "lingua franca" or means of communication of options market participants.
He described the first years of the Options Clearing Corporation (OCC) which was set up to ensure that the financial obligations of options and buyers were met. Around 1979-80 the OCC worked overnight to calculate margin requirements, based on the (now?) arcane idea that different margin amounts should be associated with different option strategies (straddles, butterflies etc) and the job of the OCC was to take a portfolio of Option and optimise which combination of strategies would minimise the margin required for the whole portfolio. He said that there were disputes between traders and the OCC around margin levels and difficulties for the SEC with updating their Net Capital Rules as each new option strategy was created. Eventually, the OCC adopted the B-S-M model and implied volatility as the means of calculating margin against market value which enabled them to move away from the operational difficulty of strategy optimisation.
So the B-S-M became the way in which traders communicated about the market but also the model became vital operationally within clearing for the market. By 1987 B-S-M had become the de-facto standard for the market, with the model driving the market in turn driving use of the model. During the Oct '87 crash the model proved to be very innaccurate but the use of the model did not diminish - maybe pschologically the market participants needed a model (even a wrong model) to make communication easier.
I found this talk very interesting and members of the audience asked whether any similar analysis was going to be done on the Gaussian Copula model used to price CDOs. Yuyal said that one of his colleagues was undertaking this research currently. Given that he seemed to be very positive about the use of the B-S-M model within options markets I asked whether he had any opinions on Taleb's criticism of fiancial engineers and modelling. Yuyal said that he and Nassim were friends and agreed to disagree on certain topics...
Stress testing modelling parameters. Next up was Peirpaolo Montana, Head of Model Validation at West LB. Having joined the finance industry out of a career in mathematics and then at a regulator, Pierpaulo began by saying that back in the heady days of 2004 the banks thought that their own risk management systems and practices were well ahead of the regulators. He said that in light of the crisis this proved not to be the case but he now feels that this is now more evenly balanced (not sure I would agree, still lots of catchin to do for some institutions I would suggest).
He said that whilst regulators require the validation of risk models and pricing models, and that stress testing of a portfolio is required, that the stress testing of a pricing model is not a requirement and has received much less attention and in his view was not done to much degree before 2007. His point here was that pricing models should work under stress too, otherwise they are a weak foundation for building other risk measures such as stressed VAR.
Whilst focussing on pricing models, he mentioned that risk models also need to be carefully chosen and appropriate to the institution and the types of trading activities it undertakes. As an example he put forward that a simple VAR calculator might be appropriate for a long only equity fund but completely innappropriate for a relative value portfolio.
He said that stress testing had recently received much more attention as a risk management tool and cited the BIS document "Revisions to the Basel II market risk framework" where stressed VAR is introduced as part of the regulatory capital charge calculation. He also mentioned that in order to avoid "standard model" treatment of complex securitised products an institution must be able to demonstrate that its VAR model can cope with these products under times of market stress.
Pierpaulo then described the stress testing of base correlation in CDO pricing, and how even moving the base correlation from its usual level of 70% to 99% would not have predicted the valuations observed in the recent crisis. In this way he says that stress testing of models can detect implementation problems and some model weaknesses, but it cannot assist in coping with structural breaks in the market. He also discussed how the B-S-M model is used everywhere (even places it should not really be valid for) since it is a robust model based on the no-arbitrage hypothesis - in contrast the CDO base correlation and other models are not so robust since they are not arbitrage free.
(end of post!)
Posted by Brian Sentance | 18 September 2009 | 5:30 pm
Regulatory moves and moods
Seems that the latest EU and Basel Committee proposals on banking regulation cannot make everyone happy (now there's a surprise...). Whilst many seem very happy at the incremental nature of the proposals to increase capital requirements for securitisations and proprietary trading, some of those in the Glass-Stiegal/banking utility camp are less than impressed. I am with the incremental camp myself, but have to acknowledge that the sceptics are not short of ammunition when saying that we are heading back to the future...meanwhile over in hedge fund land, London is currently in a very bad mood with the EU...
Posted by Brian Sentance | 15 July 2009 | 7:02 pm
Lessons for Risk Management - Wilmott and Rowe
Great event organised by PRMIA and IAFE last night at Goldman's London offices with a long title:
"A Little Thought Goes A Long Way and Lessons for Risk Management from the Current Crisis".
The event was moderated by Giovanni Bellossi of FGS Capital, and featured speaking slots by Paul Wilmott and David Rowe of Sungard. Here are my notes on the evening, please forgive any innaccuracies, and please persevere through some of the techy quant stuff, as their general points are well worth understanding.
- Giovanni quoted from Nassim Taleb about how VAR is invalid and that mainstream financial mathematics should be banned (or words to that effect, see earlier post on Taleb)
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He added that whilst what Taleb says cannot be ignored, he said that despite the current crisis and its causes that we should not "throw the baby out with the bathwater" and added that Taleb "...is not only able to recognise a cow but also knows how to milk one."
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Giovanni said that financial mathematics has much to offer and that whilst VAR is simply a number, one of its great benefits has to make one measure of risk simple and compelling enough to get traders and risk managers talking.
Paul Wilmott then took the floor and put forward his thoughts:
On Taleb and the Black-Scholes Model
- Paul mentioned that he and Taleb were great friends, and whilst he agreed with much of what Taleb says he has areas of disagreement, particularly over the use of the Gaussian distribution in finance and its implications for "fat tail" events
- Paul Googled "Taleb" and found more entries for Taleb than for Stephen Hawkin which shows how much attention had come his way due to the "Black Swan" debate
- He thinks that he and Taleb are the "Marmite of finance" (for those of you not in the UK who do not know Marmite, it is a sandwich spread that you either love or hate, never anything inbetween)
- He suggested that every quant needs a much more fundamental and practically grounded understanding of financial mathematics.
- Paul refered to some work (mentioned by Giovanni) that Peter Carr of Bloomberg had done on discrete daily hedging that showed that this option replication technique could remove up to 85% of the risk and that all quants should know about this 15% error term when trying to calculate an option price to the Nth decimal place.
- He described how in the past he had set up a volatility arbitrage hedge fund, wanting to improve upon the flawed assumption of the Black-Scholes (B-S) model that volatility is constant and to build the world's best volatility model for option pricing.
- Paul said that he did build the world's best volatility model (?!), but soon found it took too long to calculate, so he reverted back to B-S and has become an unfashionable fan of the model and its assumptions.
- He added that many of the variants on B-S to overcome its limitations have made the model worse and harder to calibrate.
- In some part due to Taleb's opinions on fat tails of distributions, B-S and other models are now very unpopular but Paul claims that not many people have actually bothered to robustly test the B-S model or take a practical, evidence based approach such as that adopted by Peter Carr.
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Paul then showed some example charts and said that with a limited number of opportunities for regular time-period hedging it was not valid to use risk-neutral pricing whereas if the same number of hedges could be used optimally (implying at irregular time periods) then risk-neutral was valid and hedging could be more effective. He emphasised that this was the kind of practical stuff that a quant should know and that quants show know less about esoteric complex financial mathematics.
Correlation
- Paul said that of all of the issues that need addressing in mathematical finance, the one that he has very few answers on is correlation.
- He showed that even basic questions about correlation are poorly understood, even by quants - a question he asks some quants was that if two asset prices both start out at 100, and they have a correlation (of returns) of 1 (perfect correlation) what is the price of the second asset after a year if the first moves to 200. The answer is not 200, and he showed how assets could diverge in overall direction but still have a correlation of 1 or rise together with a perfect negative correlation of -1.
- Paul illustrated how correlation was a very blunt measure that is mis-used by people to summarise the highly complex and historically unstable relationships between assets driven for example by industry sector success (leading to +ve correlation) or competitive success (leading to -ve correlation)
- As a result, he said that financial products whose value depends on correlation should not be transacted in any great size and moved on to the example of CDOs, where a CDO with 1,000 underlying mortgages has been modelled with 1/2 million correlations all assumed to be 0.6. Why this assumption should be made was his main point.
Sensitivity to Parameters
- His main point here was that a constant should not be varied, otherwise it is not a "constant", in particular focussing on volatility used in the B-S model and the calculation of Vega as prices are moving.
- Paul added that sensitivity measures may apply locally and is such may look comparible from one situation to another, but quants need to understand how outputs respond over a wider range of inputs, and not to be inhibited by accepted practices and beliefs.
Complexity
- Models need to be robust and transparent, and that quants should aim for the mathematical sweet spot.
- Paul put forward the following analogy that at least when driving an old car over a long distance, you knew that the car was likely to break down at least once, but you also knew that it was likely that you could fix it. Contrast this with driving a modern sports supercar and finding that it has (unexpectedly?) broken down - you don't know how to fix it, you do not complete your journey and it costs you an ordinate amount of money to put things right...
Self-Referential Feedback
- Paul described here how the hedging of derivatives contracts in the underlying markets can cause price movements in underlying markets that cause derivatives contracts to re-price that cause more hedging in the underlying markets...
- He was critical of credit derivative pricing as being too complex and too "mathsy" (...but had to admit that he had also endorsed some of this work at the time)
Calibration
- Paul said that model parameter calibration is the devil's work...
- He refered us to inverse problems in mathematics as a background to this issue in mathematical finance.
- He emphasised how markets and price behaviour is fickle and driven by human opinions and behaviours
- He said that on-going and regular re-calibration of a model is very, very likely to mean that the model is wrong (he had a particular example of calibrating a particular model he hates where vol is a function of underlying price and time.
David Rowe, Sungard's specialist spokesman on risk management, then took over from Paul and set out his five topics for discussion:
Some further notes from David's talk:
- AAA rating should imply a failing once every 10,000 years, with some super senior CDO tranches being rated as better than AAA - David pointed out that even as recently as the early 1990s there were problems in the US housing market that indicated that AAA did not mean what it was taken to mean.
- On structural imagination, David said that quants and risk managers must look for unrepresented variables in a model and track them early to monitor their effects
- On feedback he cited an example where increased returns drove product innovation which drove up (CDO) volumes, which caused underwriting standards to fall, that allowed further complexity, that then led to unreliable risk estimation which then led to more product innovation... and so on.
- He suggested that quants adopt the "second means of valuation" mantra in a similar way to credit specialists always having the mantra when assessing credit of "what is the second means of repayment" (e.g. a lien on a house) when the primary means (mortgage payments) goes away.
- David showed a nice classification from an IASB paper on classifying financial instruments:
Level 1: fair values measured using quoted prices in active markets for the same instrument.
Level 2: fair values measured using quoted prices in active markets for similar instruments or using other valuation techniques for which all significant inputs are based on observable market data
Level 3: fair values measured using valuation techniques for which any significant input is not based on observable market data
David additional proposed the interesting level of "Level ?" for some products, and said that obviously more attention needs to spent on Level 2 and 3 instruments under conditions of reduced (non-existant?) market liquidity.
Summary Session:
Paul and David then answered some questions from the audience:
- Paul said that some risk managers lacked the imagination necessary for good risk management, being confined in standard procedures, beliefs and ways of doing things. He wants risk managers who are good at thinking laterally.
- Paul said that risk management was often an afterthought, not part of the trading process.
- David said that VAR has proven useful despite its weaknesses, in his opinion preventing failures from non-extreme events regardless of the recent extremes
- David said that in answer to Taleb's criticism of using history in modelling, it quite frankly is all we have to go on. He quoted Mark Twain in that:
"History does not repeat itself but it does rhyme"
The talks were interesting, and even on points that have been discussed elsewhere both speakers had some interesting slants and good analogies. But maybe I am biassed, as the wine afterwards wasn't bad either!...
Posted by Brian Sentance | 3 July 2009 | 12:28 pm
Over The Counter Arguments
George Soros has waded back into the current saga concerning OTC derivatives in his article last week in the FT. The main part of the article focusses on financial markets reform, but ends with a vehement attack on derivatives, building upon some of his earlier ideas (see post) and seemingly going much further:
"Finally, I have strong views on the regulation of derivatives. The prevailing opinion is that they ought to be traded on regulated exchanges. That is not enough. The issuance and trading of derivatives ought to be as strictly regulated as stocks. Regulators ought to insist that derivatives be homogenous, standardised and transparent."
He ends by saying that "CDS are instruments of destruction that ought to be outlawed.". To the extent that Mr Soros attracts press/political attention is probably something the OTC markets should worry about, although it would seem his views are already consistent with many involved in influencing the US financial markets policy - take for instance the submission by Christopher Whalen to the US Senate on OTC Derivatives:
"Simply stated, the supra-normal returns paid to the dealers in the closed OTC derivatives market are effectively a tax on other market participants, especially investors who trade on open, public exchanges and markets."
Fortunately however there are also some more balanced views around - I found the following post on the "(in)efficient frontiers" blog, which references the earlier Senate submission by Richard Bookstaber on OTCs. Mr Bookstaber starts by saying that derivatives can improve financial markets, allowing investors to shape returns, exactly meet contingencies and package risk. Mr Bookstaber also puts forward a very clear summary how participants have also over recent years use derivatives to game the system to achieve tax avoidance, investment mandate avoidance, speculation and to hide risk-taking.
So back to the Soros article, there was a letter in response a few days later from a partner at the legal firm Ashurst's, saying that unfortunately risk does not confirm to a standard. In this I agree, standardising contracts can lead to increased complexity - there was a recent example given by a swaps dealer at JPMorgan who said that a corporate with particular cashflows to be hedged does want to be dealing with the basis risk and admin of using standardised contracts - the corporate treasurer wants something that matches the exposure they have and takes it away, end of story. Again this is an example of derivatives "risk" not being just about the product type, but also about which institution is holding the contract and what they are using it for (see earlier post).
Not sure however how much the Ashurst's partner who wrote the response letter is worried about lucrative legal fees for OTC derivative contracts dying off if Soros-like standardisation occurs - it is a world of vested interests at the moment, never more vested than in a crisis...
Posted by Brian Sentance | 2 July 2009 | 8:26 am
Liquidity Derivatives - the next OTC?
Given the drive the FSA is making in forcing financial institutions to implement "Liquidity Risk Management" (see background on JWG-IT site) are we going to see renewed interest in the creation of "Liquidity Derivatives" to hedge liquidity risk? I found the following post on the subject applied to hedge funds but not much information else where, although Tony Jackson did an interesting article on liquidity in the FT last week, indicating that liquidity derivatives have been tried before with little success.
I was thinking of the advent of credit derivatives being driven in no small part by Basel II regulation on capital charges for credit risk. Maybe given the current battle going on around OTC regulation (see FT feature today) there are institutions working on liquidity derivatives but nobody in the finance industry wants to admit that they are already creating the next "innovative" OTC to nullify regulatory charges?
Mr Geithner better watch out, innovation will always beat "rules" in my view...
Posted by Brian Sentance | 21 May 2009 | 7:20 am
What Investment Banking is all about?
I admire the boldness and openness of Richard Jory, Editor of Structured Products Magazine, for asking the serious and under-answered question whether it is a problem or not that the likes of the equity derivatives division of BNP Paribas lose 1.5 billion Euro in one quarter after making around 15 billion over the past five years? Certainly there is an automatic rush to condemn such losses given their size and the current context of the global financial crisis.
The first sentence of Richard's article should be framed as an excellent and apt piece of prose - I am not sure he is behind the times or predicting a future return to investment banking normality:
"Losing a lot of money in one year, or one quarter after making a whole truckload of money in the preceding five years is, frankly, what investment banking is all about."
Not sure he will find many regulators backing his view, but let's see...
Posted by Brian Sentance | 5 February 2009 | 7:21 am
Challenging Fair Value
Concise letter on the continuing debate on fair value accouting to the FT from Hugh Shields, Chief Economics Advisor to the Institute of Chartered Accountants of Scotland.
It seems that most commentators come down positively on the side of fair value accounting from what I have read, with the two main points of:
- Don't blame the messenger
- Pro-cyclical behaviour is driven by the regulatory calculation based on fair value accounting, not by fair value accounting in itself
A recent paper "The Fair Value Controversy: Ignoring the Real Issue" and survey "Reactions to an EDHEC Study on the Fair Value Controversy" by EDHEC seem to support this view, with only 25% of respondents believing that any amendments are necessary, and 75% believing that changes will only lead to more problems.
Unfortunately, it would seem that the SEC in the US has produced 250 pages of suggested tweaks to fair value accounting (see Lex article). Maybe the desire for preventative rules and the political need to be seen to be "doing something" are too strong for regulators to resist...
Posted by Brian Sentance | 21 January 2009 | 11:18 am
Originative sin
Very balanced article in the FT by John Plender on innovation in financial markets, quoting Merton Miller as saying in 1986 that "the major impules to successful financial innovations have come from regulations and taxes". Apart from a good narrative on the current crisis, Plender ends by suggesting that as both taxes and regulation are likely to increase in the near future, it may be unwise to call the death of financial innovation just yet.
Posted by Brian Sentance | 6 January 2009 | 6:43 am
Independent No More?...
John Gapper article again from the FT - this time announcing the death of the independent investment bank (click here). Thought it was worth noting this one as a benchmark for where people's thoughts are now...
Posted by Brian Sentance | 17 September 2008 | 10:13 am
Never ending liquidity for FX?
FX volumes grow from $99,000bn in 2007 from $71,000bn in 2006 - growth driven by automated trading, cheaper execution leading to more and more participants. How fluid can the market become? Article link:
http://www.ft.com/cms/s/0/10fc4512-2c4f-11dd-9861-000077b07658.html?nclick_check=1
Posted by Brian Sentance | 28 May 2008 | 10:02 pm
Investment banks after the crisis...
FT questioning what the investment banking industry will look like once the credit crisis has passed, in particular whether big name "stand alone" investment banks can continue to prosper when faced with competition from broader based institutions with a strong retail base:
http://www.ft.com/cms/s/0/80b3cbac-24ff-11dd-a14a-000077b07658.html
Posted by Brian Sentance | 20 May 2008 | 8:54 pm