Xenomorph Blog - Regulation

Posts categorized "Regulation"

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

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

Counterparty Event

I went along to a morning panel on counterparty data management on Tuesday, sponsored by GoldenSource, Avox and Interactive Data, and hosted by Virginie O'Shea of the A-Team. Counterparty data obviously has a very high profile currently in light of recent events, however the advice from the panel fundamentally seemed to be get the basics of data management right (ownership, control, consistency, quality, transparency), rather than anything radically new.

There was some debate about the possible extension of BIC (Bank Identifier Code) to be used more generally as a standard for a unique business entity identifier - this seemed to be received well but there were concerns that such an initiative would not solve the problem but rather become an addition to the already complex entity-mapping process.

The "Data Utility" from the ECB was also debated, and it was refreshing to here some negative (realistic?) things said about it, such as the concern raised by Interactive that this might involve huge public spend without necessarily understanding why a new government sponsored entity would be able to do better than existing data providers. Obviously a data provider would say that, but I have to agree, it seems there is too much focus on having a data utility and not looking at the different options for solving industry data issues (one option obviously being a data utility, but lets not pre-package the problem with a solution but more of that in later posts...).

For more detail on the event, then take a look at Virginie's blog post.

Posted by Brian Sentance | 21 May 2010 | 10:56 am

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

Risk, Data Transparency and the MBS Market

I spent the morning yesterday over at the FIMA USA event in New York, and caught the panel discussion chaired by Neil Edelstein of GoldenSource. Stand out speakers were Amy Hawkins of BNY Mellon and John Bottega of the Federal Reserve.

Neil started the panel by asking the panel for their thoughts on the current drive to improve "data management for risk". Transparency and quality were mentioned a lot unsurprisingly, with John Bottega adding that he was aware that a lot of banks were now focussed on the data that in the past had been "not available" for risk management, not just the quality of data that is readily accessible. All panelists focussed on the need to manage risk across the whole institution, not just by product silo.

On the topic of data standards and transparency, John referred the audience to testimony on the Mortgage Backed Securities (MBS) market presented to the US Government by the XBRL group. Apparently the filing process for mortgages allows free format filing and so is of little use from an automated processing point of view. John also pointed out that a key piece of data in assessing risk is that the "first time buyer" flag was found to be present in only 15% of the filings.

John also mentioned that if loans and mortgages could be given standard identifiers, then this would enable new levels of risk management - for instance it should be able to extract those obligations against a specific region that for example is experiencing economic recession. These would be the benefits of getting data standards in place.

As was later expanded upon in a later talk by Kay Vicino of Northern Trust, there was a lot of panel discussion on organisational data governance and the management structures needed to achieve it. On the governance side of things then whilst it is not an exciting topic, it is obviously vital - main point seems to be establishing data ownership and responsibilities which brings me back to the point that a lot of (most?) data management issues are down to managing people and organisational politics, not just down to good technology (although it helps!).

Overall a reasonable panel, and the XBRL testimony looks worth a more detailed read (if the testimony link doesn't work then go to the www.xbrl.org site and search for a report called "Using Standards for Transparency")

Posted by Brian Sentance | 17 March 2010 | 4:42 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

When is a trade, not a trade?...

...er, when it is a hedge? Adding to my current confusion over just how the Obama administration is going to define just what is and is not "proprietary trading", Gillian Tett of the FT today has put together a good article on some of unexpected effects that such a ban may have - my advice is don't mess with the all-powerful "Law of Unintended Consequencies"...

Posted by Brian Sentance | 19 February 2010 | 2:58 pm

"Cut and Paste" Valuation Services

You can talk about more robust modelling, more stringent scenario testing and even moving everything onto an exchange, but unless we move the principles of good data management (in my view: consistency, security and quality of all types of data) into the front office then we will continue to get front-office mis-marking as described in this article in the FT.

Thanks to Ralph Baxter from Cluster7 for highlighting this article for me and those of you interested in this topic of operational risk and spreadsheet mis-use should maybe go along to EuSpRiG this year, and maybe take a look at a paper Xenomorph presented at a previous conference.

Posted by Brian Sentance | 4 February 2010 | 9:49 am

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

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

High Frequency Trading vs Flash Trading

Economist Tim Worstall has an distinction to make on the differences between high frequency trading and flash trading in a recent article.

Essentially it is the difference between getting your orders in quicker than every one else, and having a peek at what everyone else is doing before putting your money down. The SEC appears to be conflating the two and has concerns.

With the world condition in banking, could we see some poorly thought out legislation rushed through so that regulators can be seen "doing something"? Or would it level the playing field a little so that those trading operations that cannot afford the overhead of super fast computers and networks are not excluded?

Posted by Dean K | 2 October 2009 | 3:51 pm

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

Tick Size Harmony...

...in a rare show of co-operation (I wonder what is the carrot or (regulatory) stick here to motivate this?) European exchanges and MTFs seem to have agreed on standardising tick sizes (or at least to have two standards rather than twenty five!). Extract from article on AutomatedTrader:

"From the perspective of each trading venue, strong incentives exist to undercut others in terms of tick sizes, which is not in the interest of market efficiency or the users and end investors. This might, in turn, lead to excessively reduced tick sizes in the market. Excessively granular tick sizes in securities can have a detrimental effect to market depth (i.e. to liquidity). An excessive granularity of tick sizes could lead to significantly increased costs for the many users of each exchange throughout the value chain; and have spillover costs for the derivatives exchanges' clients."

Posted by Brian Sentance | 9 July 2009 | 9:11 am

Das's Dazzling Derivatives

Satyajit Das adds an interesting contribution the debate on OTC derivatives and the drive towards CCP in his article in the FT today (see earlier post for background). The opening paragraph sets the tone:

'US and European Union proposals for over-the-counter derivative regulations are consistent with H.L. Mencken's proposition that "there is always a well-known solution to every human problem - neat, plausible and wrong".'

Main points from the article:

A single CCP would certainly qualify for "too big to fail"
The success of CCP depends on collateral and collateral valuations may underestimate risk and value since these are usually based on historical volatility
Cross-margining exposes the CCP to correlation risks in offset methodologies
CCP depends on valuing contracts that depend upon liquid markets
CCP margining requirements may communicate market stress to more participants and in turn create more stress
Regulators are missing the point with CCP and should look addressing the core issue of innovation and complexity hiding excessive profits in derivatives

As a related aside, probably also worth taking a look at the following article on the return of securitisation.

Posted by Brian Sentance | 8 July 2009 | 3:52 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

Risk in the Hands of the Holder?

Given the ongoing debate about "too big to fail" and whether we should head back to the days of the Glass-Steagal Act, then here is a slightly different slant on the problem of systematic risk put forward in an article by Avinash D. Persaud.

In the article, Avinash makes the very good point that increasing capital requirements across the board is not the only response that regulators should consider, and that the risk of a financial product cannot be determined in isolation of who is holding it:

"At the heart of modern regulation is the erroneous view that risk is a quantifiable property of an asset. But risk isn't singular. There are credit, liquidity, and market risks, for instance—and different parts of the financial system have different capacities to hedge each. Thus, risk has as much to do with who is holding an asset as with what that asset is. The notion—popular in the U.S. Congress—that there are "safe" instruments to be promoted and "risky" ones to be banned is deceptive."

Obviously the last point is very relevant to the OTC markets at the moment. Avinash suggests that capital requirements should be tailored to what type of organisation is holding a risk and that organisations ability to hedge it, and outlines past mistakes made by regulators:

"By requiring banks to set aside more capital for credit risks than nonbanks must, regulators unintentionally encouraged banks to shift their credit risks to those who wanted the extra yield but had limited ability to hedge this type of risk. By not requiring banks to put aside capital for maturity mismatches, they encouraged banks to take on liquidity risks they couldn't offset. Moreover, by supporting mark-to-market asset valuations (which make institutions value holdings at their current price) and short-term solvency requirements, regulators discouraged insurers and pension funds from taking the very liquidity risks they are best suited for."

On banks and credit risk, then for those interested there is a good regulatory arbitrage example for credit risk described in the following article. Fundamentally I think the paragraph above illustrates some of the reasons why it is right to worry about rushing in new regulation too quickly - certainly things need to change but when dealing with large and complex systems (i.e. in this case Financial Markets) changes should be introduced incrementally in order to understand how the system responds.

Given the political imperative to "do something" then regulators find it all too tempting to stick their noses in everywhere, even in areas that did not lead us to the current crisis - take for instance the regulatory initiatives over the past year in short selling, hedge fund regulation and more recently the dangers of "dark pools" (at least dark pools sound scary I guess?). Where will the next "bogey man" appear on the regulator's radar and what will be the unintended consequences of government pressure on regulators to keep us all "safe"?

Posted by Brian Sentance | 2 July 2009 | 7:00 am

Liquidity Risk

Our think-tank friends at JWG-IT organised a great event yesterday, with several of the top banks coming together to share their thoughts on what is currently causing them the most pain in implementing the FSA liquidity risk requirements (see FSA Consultative Paper CP08/22 for background).

A few points I took from the meeting:

FSA is moving from a "principles" based approach to regulation to "outcomes" on to "proof of judgement" as the basis for assessing financial institutions
What liquidity stress tests the FSA wants the financial institutions to perform is still far from clear
The above uncertainty is not helping when combined with an implementation deadline of this October
Whether liquidity risk must be managed at the branch or group level is a key unanswered question which has enormous implementation implications
The data requirements are enormous and since a group-wide issue requirements greater central access to data across all departments - unlike traditional market risk which is currently more siloed within each business division
The granularity of data required (down to transactions, detailed cashflows for complex derivatives) is very challenging
Management of intraday liquidity requires real-time cash transaction reporting which is currently not being done/is difficult to do
"Ownership" of liquidity risk implementation typically resides within a bank's treasury function but awareness, ownership and involvement of all departments (e.g. market risk) could be greatly improved

A lot more interesting issues and detail on this meeting plus survey results will be available from JWG-IT soon (see their liquidity risk site)

Posted by Brian Sentance | 22 May 2009 | 3:41 pm

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

Regulating OTCs Out Using Capital?

Following on from the warnings on over-regulation in my post last week on the OTC markets in London, Larry Tabb of the analyst firm the Tabb Group is pointing towards increased capital requirements as the stick the regulators will use to move the finance industry away from the perceived dangers of the OTC markets (see article here).

Posted by Brian Sentance | 8 May 2009 | 5:58 pm

Fight-back by the OTC Market?

An FT article I read earlier this week put me on to an interesting report on the OTC derivatives market commissioned by the City of London and written by a consultancy Bourse Consult. The report seems to be have been commissioned in defence of OTC industry against the predictable knee-jerk of regulatory proposals following the current financial crisis. Main points from the report are:

The OTC market is global and very large, much larger (by notional I guess) than either the exchange traded market or the cash markets
London accounts for 43% of the OTC market, with 24% in the US
It clarifies and emphasises that CDOs on ABS sold into off balance sheet special investment vehicles are where the main losses in the current crisis have been incurred
The CDS market and the OTC market in general did not cause the current crisis
Being seen to be "doing something" is driving much stricter regulation for CDSs and the whole of the OTC market, not just for the CDO products at the heart of the crisis
Those arguing that OTCs must be traded on exchanges are mistaken since the OTC market and the exchanges are complimentary and need each other to thrive and develop new products
Many OTCs could by cleared centrally by a CCP without requiring listing on an exchange
However desirable, there are certain types of OTCs that are not suitable for a CCP
The current crisis was caused by mistakes by the ratings agencies, poor risk management by the banks and a lack of questioning of these participants by the regulators
Fundamentally this is a people-led not product-led crisis
Pressues to set up regional CCPs are mis-guided as the OTC market is a globally one and ultimately it will decide which CCPs succeed.

The report is well written and well worth a read. However, to suggest that the current financial crisis is purely people-led and that financial products are blameless is not completely the case in my view. I guess it depends upon your interpretation of whether regulation should directly limit the types of financial products created and their usage, or simply focus on regulating the people who are creating and using them. Given the current focus on getting CCPs set up for CDSs and other OTCs, it seems like governments and regulators are taking the approach of directly addressing perceived issues with financial products in addition to the more obvious (but more difficult?) people issues.

Also sounds like there is some work to be done in the EU, US and elsewhere if London is to remain the global centre of the OTC market - given the current performance of the UK Government this is not an encouraging prospect for London.

Posted by Brian Sentance | 1 May 2009 | 10:09 am

High Performance Spreadsheets

Another article about the operational risk generated by the usage of spreadsheets within the financial markets (see earlier posts), appeared in the April issue of Waters Magazine.

The articles highlights how spreadsheets are largely used within financial institutions and suggests that the current regulation requirements for more transparency and ad-hoc risk management might push the proliferation of spreadsheets even further. The articles also refers to the progress and improvements made by Microsoft in recent versions of Excel to increase the security of spreadsheets.

Xenomorph has worked closely with Microsoft on hosting its time series database within SQL Server 2008. The case study we have written together describes how SQL Server 2008 offers integration within Office Excel 2007 so that whilst the spreadsheet is still the end-user viewing tool, operational risk is reduced by engaging Excel 2007 as an analytics and reporting tool and not as a mean of storing data.

Our TimeScape solution offers more than 700 easy to use add-in functions to Office Excel 2007 and we are currently working on the use of Excel Services, part of Microsoft Office Share Point Server 2007, to further enhance the centralized approach to spreadsheet.

If you are interested in how Xenomorph solves the problem of spreadsheet management, then take a look at our (newly updated) website. Here we explain how to solve the problem and how Xenomorph Spreadsheet Inside technology can bring unstructured spreadsheet data and complex calculation within a centralized data management system, increasing transparency and reducing operational risk.

Posted by Brian Sentance | 8 April 2009 | 2:35 pm

Capital requirements for Asset Managers

Article in the FT today saying that the Financial Services Authority (FSA) has criticised asset managers for poor risk management, and that these failures might force it to impose higher capital requirements on some institutions.

The Investment Management Association (IMA) countered by saying that the FSA guidelines on capital requirements for asset managers were unclear, but also added that as asset managers did not hold client-owned assets on their balance sheets they did not need to hold capital against these assets unlike the banks.

I understand this last point by the IMA, but surely given an institutions fees (aka revenues) derive mainly from fees for managing these assets, surely the IMA is not doing itself any favours by effectively suggesting that the (currently volatile) value of these assets are not relevant from a institutional risk point of view? Poor investment performance leads to redemptions, leads to reduced fees, leads to concerns over institutional stability, leads to more redemptions etc, etc.

Anyway, interesting that this is receiving some regulatory attention and maybe buy-side risk management will soon be moving beyond helping to market and sell the latest investment product...

Posted by Brian Sentance | 30 March 2009 | 11:38 pm

Regulatory Camouflage

My faith in government institutions and the people working for them has been restored by Martin Wolf of the FT when he pointed out an excellent paper "Why Banks Failed the Stress Test" by Andrew Haldane of the Bank of England. Reading this is a complete contrast to my experience at the FSA presentation on stress and scenario testing the other week (see earlier post).

The paper ends by putting forward five proposals for improving risk management:

Better Scenario Definition - Regulators defining multi-factor scenarios for the industry that are truly representative of extreme tail events.
Regular Scenario Evaluation - A common set of scenarios evaluated and reported upon to the regulators on a regular basis.
Second-Round Stress - Making sure that the consequencies of stress testing for individual institutions can be evaluated for system-wide risk.
Active Management of Risk - Ensuring that management take and can explain actions that provision for the risks identified, and do not simply passively report on risk levels.
Transparency - Access to institutional stress testing results by regulators and potentially by the market as a whole through annual report and accounts.

In addition to solid content, Andrew Haldane writes a good story, and I love the usage of "regulatory camouflage" in the serious point below:

"...is that stress-testing was not being meaningfully used to manage risk. Rather, it was being used to manage regulation. Stress-testing was not so much regulatory arbitrage as regulatory camouflage."

Posted by Brian Sentance | 23 February 2009 | 7:11 am

Data management, derivative analytics and the spreadsheet

Interesting article out doing the rounds on the newswires announcing a forthcoming report called "The Enterprise Spreadsheet: Pushing towards Transparency" by the analyst firm the Tabb Group. It is great to see an analyst firm acknowledging the importance of spreadsheets within the markets, particularly in the area of combining data and analytics together in OTC derivatives management (see earlier post).

Adam Sussman of the Tabb Group reckons that despite its shortcomings, Excel is a valuable tool: “Spreadsheets, either alone or in conjunction with other components, can meet the same requirements as a business application.” In this he seems to be agreeing with the UK Regulator the FSA, who have been recently advocating that spreadsheets and spreadsheet data needs actively managing as an institutional resource. The findings of the Tabb Group on management also seem to echo a recent report called "Buy-Side Data Management in a Changing Landscape" done by Lepus for Asset Control (registered link to report here).

Spreadsheets are a great tool and fulfil a real need in the market to pull together pricing models and data quickly, easily and with a timeframe that is meaningful to the business (see earlier post for some work by Xenomorph in this area). Spreadsheets are a big problem to manage, but they are also the symptom of failings in core systems that are not able to rapidly support new instrument types and pricing models. An institution that ignores analytics, spreadsheets and spreadsheet data within any EDM transparency initiative has already failed before it begins, and so to paraphrase the author Aldous Huxley:

"Spreadsheets do not cease to contain data because they are ignored."

Posted by Brian Sentance | 13 February 2009 | 2:54 pm

The Respect Scenario from the FSA?

The presentation by the FSA last night on their consultative paper called "Stress and Scenario Testing (CP 08/24)" was a real disappointment last night. The presentation was at best average, not adding any more value than what you could get from scanning their paper. However, what was worse was the Q&A session at the end, with a variety of questions from the audience being answered by the FSA representative with "Thanks, that was a very good question and I will get back to you on it...".

The organisers (ISDA and PRMIA) had managed to get around 200 risk managers to attend which was an impressive turn-out with only standing room left as the event started. I would suggest if the FSA want more feedback from the industry it would be better if they would send someone along who is at least able to add value to the conversation. Their representative last night was doing his best but was just too junior, too inexperienced and lacked the confidence to answer questions in a meaningful manner.

Regulators are telling everyone to "raise the bar" on standards at the moment - they would find it helpful if they would apply this mantra to themselves and the people they put out as representing their views and expertise.

Posted by Brian Sentance | 11 February 2009 | 10:07 am

Risk Proposal from Roubini

Article in the FT today by Lasse Pedersen and Nouriel Roubini (somewhat accurate predictor of some of our current problems) on regulatory captical and prevention of another crisis. Pedersen and Roubini say that current regulation focuses too much on individual bank risk and does not consider the systematic risk that could be caused by the failure of an individual bank. They propose the introduction of a new systemic capital requirement and systemic insurance programme, although in this article do not present too much detail on the mechanics of the "systemic risk" calculation. More detail can be found at their NYU Stern project on restoring financial stability.

Posted by Brian Sentance | 30 January 2009 | 2:18 pm

CDS Asymmetry not for Soros

Interesting views in an article by George Soros in today's FT. Whilst dealing with the current crisis and the difficulty of its remedy in general, Soros spends a little time on short selling and continuing his warnings about CDS contracts and other OTC derivatives.

In contrast with short selling, where upside is limited but downside risk is not (and increases as more losses are incurred), he explains that effectively shorting a stock through buying a CDS contract has the reversed asymmetry of risk. On buying a CDS, the downside risk is limited (to the premium), whilst the upside risk is unlimited (not sure I agree, maybe practically unlimited is better used). Using this asymmetry in risk profile, he joins John Dizard in railing against what he perceives as the instability caused by the CDS market and "toxic" OTC derivatives.

He suggests that shorting is an acceptable market practice (I guess he would, have made a lot of money from shorting) but that some market constraints might be sensible in re-introducing rules such as no naked short-selling and allowing shorting only on an up-tick.

Most controversially rather than just accepting the common view that CDS contracts need to be traded and cleared within regulated markets, he advocates a more stringent process where OTC derivatives would need to go through a very formal and regulated "issuance" process similar to that undertaken when issuing a new stock on an exchange. Given history and the market's economic need for innovation I struggle to see this happening on a large scale, even in light of the crisis - but I guess nothing is to be ruled out in current times.

Posted by Brian Sentance | 29 January 2009 | 11:07 am

Underrated, Overrated

More flak for the ratings agencies in the FT today with the article "Warning: rating agencies can do you harm", suggesting that agencies have moved from under-assessing risk (and causing financial damage in the process) to now cautiously over-assessing risk (and causing financial damage in the process).

The recent downgrading of Greece, Spain, Portugal (and potentially Ireland) won't gain them any political friends in the EU review of their role in the markets - all recent news seems to lead to "tails you lose, heads you lose" for these institutions and points to further trouble ahead...

Posted by Brian Sentance | 23 January 2009 | 3:31 pm

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

RiskMinds - DB on reforming the financial markets

Hugo Banziger, CRO of Deutsche Bank, gave a presentation on his ideas on how best to reform "The Global Financial Architecture".

He started by emphasing:

The economic imperative to resolve the current crisis for the benefit of all people, not just the financial markets.
That the current crisis is very close to the crisis of the 1930s (he did his PhD on the Great Depression, so he should probably know).
He has been involved in the rescue of 3 banks recently, and said that one major German financial institution was only 6 days away from insolvency before it was saved.
His opinion that letting Lehman go was a bad decision that has worsened the crisis.
That without goverment help the financial markets would have gone into meltdown and that this state of affairs is totally unacceptable for the industry.

He proposed action in three areas:

Monetary Policy - Governments and central banks should pay more attention to the interaction between monetary policy and global capital flows. Central bank policy should also consider targetting how to prevent asset price bubbles as well as more standard measures such as inflation (Comment: maybe my bubble index idea wasn't so stupid?). Emergency liquidity provision also needed a rethink in light of past failures.
Regulation and Supervision - Capital requirements should be increased and capital calculations need redesigning to reduce pro-cyclical aspects so as to provision in the good times for the bad (Spanish regulator had already done this apparently). Capital calculations should be calculated over longer time periods (30 yrs?) using the worst of events from the past. Scenarios need adding into the capital calculations so they are not just probabilistic in nature. Regulators should insist upon better transparency and disclosure, in particular on valuation methods and the methods of the Credit Rating Agencies. Ultimately, regulation needs be co-ordinated on a global basis given the global nature of the markets.
Private Insitutions (the Banks) - Appalled by the lack of integrated risk management at many banks, and clear governence of the risk is essential. IT systems should be robust and centralised access to data to calculate exposure is essential. A typical cost of $200m to implement Basel II indicates to him that basic technology infrastructure is not in place and good risk management cannot be being done. Having data in spreadsheets and reporting to regulators with a 3 month timeframe is not good enough and the industry needs to get the infrastructure in place to properly handle and report in a timely manner upon the risks it is taking. He proposes that each bank needs to get a diversified and stable funding base in place - DB issued long term funding recently to reduce dependence on short-term sources and has $65b in reserves, so (maybe at the risk of sounding smug) he believes DB is well positioned.

Interesting talk, Hugo risked coming across as a little smug in the presentation but did admit that DB had faced problems too (but just not as bad as most other institutions though!).

Posted by Brian Sentance | 11 December 2008 | 1:37 pm

RiskMinds - insurers on the crisis, risk managers (and suicides...)

Panel debate amongst CROs from some of the big insurers and the FSA. Main points:

Summarised the current crisis as "A collective failure of imagination over the scenarios of what is possible by risk managers and regulators"
Insurers are doing better than the banks in the current crisis, and this is due to learning from the bad experience insurers had in 2002 following the collapse of the dot com bubble.
Quants are not to blame for the current crisis - they are involved but the current liquidity crisis is not a quant issue (Comment: but surely the collapse in asset prices from poor modelling is what led to the collapse in confidence and onwards to the liquidity crisis)

Joachim Oeschlin, CRO of Munich Re said that at a recent panel event he asked a group of risk managers what had been the failings of risk management, was it:

Risk managers enjoyed the credit party like everyone else?
Risk managers did not see the bubble coming?
Risk managers did not have enough power?

The response from the risk managers was the latter (unsurprisingly!) but he favours the first two explanations above. Joachim said that Munich Re had been looking at how their company performed in the Great Depression of the 1930s. It seems that we should be thankful that we have personal bankruptcy laws these days, as one thing he noted was a great increase in suicides in the 1930s as people who owed too much money simply killed themselves...maybe we haven't got it so bad after all. Crisis? What crisis?

Posted by Brian Sentance | 11 December 2008 | 1:24 pm

RiskMinds - Model Risk and Variable Dependency Assumptions

Professor Paul Embrechts gave the opening talk this morning on quantitative risk management. Main points:

Paul thinks the largest recent failing is to take VaR for granted - he says that it is only a statistical estimate that has a range of values based upon what assumptions are made.
Related to the above, whilst improving quantitative risk management is vital he states that risk management is about human judgement.
He sees "pricing model uncertainty" - the risk that a model for pricing an instrument is badly formed or based on poor assumptions - as a key risk to be addressed going forward (echoing VaR post yesterday)
On pricing model uncertainty, he pointed out what the regulators are proposing with the recent consultative document from the Basel Committee on fair value calculation practices (click here). This covers things like assessing model sensitivity under periods of market stress, challenging of models, understanding of suitability and appropriateness etc.
On the incremental risk capital charge guidelines from the Basel Commitee (click here) he raised concerns that a calculation for market risk with a VaR of 99.9% over one year was both very difficult to model and very difficult to backtest (without lots of good data being available, which is not usually the case).
He ended by spending some time on the re-occuring theme of variable dependency (leading to a lack of expected diversification) and illustrating it with a simple example concerning summations of VaR levels from different business lines at a bank.

Good speaker - main points/concerns were the validity of pricing models and dependency assumptions between variables.

Posted by Brian Sentance | 11 December 2008 | 12:55 pm

Stress-Testing Consultation by the FSA

The FSA published a consultation paper on stress-testing yesterday (click here to view).

Posted by Brian Sentance | 11 December 2008 | 5:39 am

RiskMinds - VaR is not dead at Citi

Very good and refreshingly open presentation given by Alan Smillie of Citi Group on whether Value at Risk (VaR) has been discredited as a risk management tool (see earlier post for Taleb on VaR).

He started by generically describing VaR as being composed of both:

A statistical model of the market
Pricing models/sensitivities to translate the market movements to P&L

He said that much of the recent losses/write downs at Citi are in ABS CDOs at levels of 10x/100x larger than those predicted by the VaR models that they use. He summarised by saying that whilst VaR has not performed well, it should not be dismissed since their experience is that their losses (and inaccuracies in VaR calculation) were not (mainly) due to failings in the statistical model of the market, but rather in major failings in the pricing methodology for pricing ABS CDOs.

It seems that the traders and risk managers at Citi regarded ABS (Asset Backed Securities, mainly mortgages) as equivalent to a bond, and so they regarded an ABS CDO as equivalent to a CDO of bonds. In fact the ABS was itself a securitised product, so effectively they were dealing with a CDO of CDOs (CDO^2). This did not offer the diversification of risk to justify the AAA rating given to the ABS CDOs - apparently the ABS prices in each CDO were 90% correlated. Alan clarified that given the problem was in the pricing model, not in the model of the market, better scenario analysis would not have helped Citi to avoid these losses either.

Alan refered back to an article in Risk magazine in 2006, saying that banks were not experiencing any "exceptions" (breaches of the VaR loss level) at the level that should be expected (2 to 3 per year for 99% VaR). The article suggested that banks were therefore being charged too much regulatory capital and this should be reduced. He said that Citi experienced 20 VaR exceptions in 2007, and expected much more in 2008 and as such VaR is not working well given the current market volatility.

He expects that future risk capital calculations required by the regulators will be based upon VaR combined with subjective, non-probabilistic stress testing (apparently something that Deutsche Bank have been doing internally for years according to a later speaker). He didn't seem to address the issue of how to avoid pricing model risk, but it was a good talk with a lot more openness over Citi's losses and problems than I expected.

Posted by Brian Sentance | 10 December 2008 | 5:29 pm

RiskMinds - Tuesday Panel Debate

Panel debate this morning was interesting, speakers included Riccardo Rebanato of RBS, Bob Scanlon of Standard Chartered, Andreas Gottschling of DB and David Morgan of the UK regulator, the FSA. A few sections from the debate:

Current Crisis - Scanlon said that the current government guarantees offered to the banking industry will realistically have to be in place for 7 to 10 years, not the 3 years that is officially spoken of. He also said that he was concerned that current government intervention will pervert the market, with the transfer of credit risk from corporates to governments. Put a different way Gottschling said that "nationalising crap does not turn it into strawberry cake". Morgan said the FSA is aiming for tighter liquidity and capital standards since the future risk of something similar to the current bail out is unacceptable to the public. Rebanato criticised the FSA for focussing too much on recapitalisation and too little on liquidity provision. Morgan emphasised that the "discount window" funding from the Bank of England was only there for crisis times and not to be used as "lender of first resort". Morgan seemed forceful on this last point but seemed on the back foot relative to the practioners in the panel.
MTM Accounting - all seemed united that mark to market accounting should stay and that we should not effectively "shoot the messenger" i.e. the real source of the crisis lies elsewhere, not in MTM accounting.
Securitisation - Rebanato said that the key to getting securitisation going again was a rethink of how an investor can trust the due diligence done in assessing the risk of a product, in particular a total rethink on the role and practices of the credit ratings agencies. Scanlon added that increased capital requirements combined with no securitisation market would slow economic growth and as such securitisation is a necessary part of the future of the markets and essential for the growth of the global economy.
Liquidity Risk - Rebanato said that ideas such as "liquidity VaR" were invalid given that a liquidity crisis is such a digital event. Gottschling favoured robust scenario analysis but ultimately management skill and judgement is key. Morgan of the FSA criticised the banks for very poor liquidity management in place now regardless of what new regulatory requirements may come. Rebanato made the point that many private companies would (in the absence of regulation) choose not to deflate balance sheets and reduce profitability in order to be better placed to deal with future (but infrequent) liquidity crises. Morgan again came back to the costs to the tax payer of the current crisis and Scanlon threw in that the FSA and other regulators were going to cause the crises of the future...

At that point the debate ran out of time which was a shame since Scanlon was only just getting warmed up on hitting (verbally!) at the regulators...

Posted by Brian Sentance | 10 December 2008 | 4:43 pm

RiskMinds - from Blame to Bubble Indices...

I am attending the RiskMinds Conference in Geneva this week. Given what has happened over the past year, its somewhat intellectual name seems less appropriate than it once did, but I guess not many of us are smelling of roses on that point...

Seems to be very good attendance with the main hall full to overflowing for the first full day of the conference - unsurprisingly I think many people are looking for answers (from "what did I do wrong?" to "who can I blame?"). From a quick survey of the attendees, there seems to be no doubt that regulators and the credit rating agencies seem to be the favoured candidates to blame.

Robert Shiller (author of Irrational Exuberance) gave the openning talk on the current credit crisis and what to do about it. He made the point that behavioural finance (stock market pyschology) is becoming much more integrated with financial markets theory, and put forward the positive point that financial theory needs to be expanded to encompass what we have experienced over the past year, not that all financial theory should be thrown away (a jibe at Taleb on this point?)

Much of Professor Shiller's talk was spent on illustrating various "bubbles" in real asset prices in various markets against long run trends, usually involving a comparison with the data of the Great Depression of the 1930's, and an occaisional mention of his book (I haven't read it (yet) but I would guess it spends a lot of time on bubbles too). He is very keen on the democratisation of finance, more particularly of financial advice (it would seem that the FSA has been listening in the UK, with the recent action against commission-based financial advisors).

He also proposes greater usage of macro economic indices and related derivatives to make risks of house price falls, inflation, economic growth, employment etc more transparent to all and to allow easier hedging of these risks. He raised some eye-brows of many banking staff by proposing mortgages whose payments went down when these factors moved against a house owner (with the originator hedging these risks using futures on the indices he proposes). He was not so clear what should happen when these factors went in favour of the house owner!

One thought struck me though the talk, is that if it is relatively easy to illustrate/calculate these real asset price bubbles illustrated by Professor Shiller, then why not go further than just having indices on direct macro-economic variables and have indices based on these "bubble" calculations? If everyone could see that the "bubble" index for a particular risk factor was high then you could hedge your "irrational exuberance" or at the very least there would be a transparent indicator that a market was moving into dangerous price territory. Stupid idea? Maybe, but if it has legs please remember you heard the nickname"Aero" for the cocoa index here first!...

Posted by Brian Sentance | 9 December 2008 | 10:42 pm

Rules of Principles Based Regulation?

I went along to an event a few weeks ago organised by JWG-IT in which they talked about how they are involving 8 of the top banks (it was 11 but these are the times we live in...) in defining what they term as "Sturdy Breakwaters" to help financial institutions turn regulatory principles into template action plans that would (almost) ensure regulatory compliance.

A "Sturdy Breakwater" is a legally recognised term which in the context of industry guidance by FSA is described as offering effectively what amounts to protection against action by the FSA against an institution following such guidance, but not offering protection from other third parties (other institutions and clients maybe). Such industry guidance would need to be explicitly made public by the regulator but once done so it would be possible for institutions to adopt this approach and benefit from its protection (and prescription). For those of you interested in finding out more please take a look at a background document "FSA confirmation of Industry Guidance"

The debate on the pros and cons of rules-based or principles-based regulation have raged on and on in the industry. Basically most regulators dislike the rules based approach since firstly it promotes a "tick box" approach to achieving regulatory compliance (without necessarily delivering on the underlying problem being regulated) and secondly the bright people at the banks invariably find a way round any given set of fixed rules.

The banks would prefer a rules based approach since it is easier to turn a set of rules into a set of actions, rather than trying to figure out what a broad principle means - anyone fully certain what achieving "best execution" from MiFID entails doing yet for example?

Institutions understandably do not like it when regulators use the best part of a compliance implementation at one organisation to say to another "and why aren't you doing this too?" but sometimes the flip side of this is that the institutions sometimes do nothing for a particular regulation, watch what other organisations do and which organisations are fined and why.

Put another way it seems like the regulators and the institutions are both sometimes guilty of trying to arbitrage each other through a deliberate policy of either saying or doing very little.

This Sturdy Breakwater/Industry Guidance approach seems to be a sensible approach to bridging the gap between principles and rules, I guess the only question is if this is such a good idea then why are there only four pieces of confirmed Industry Guidance in place so far? Any answers appreciated!

Posted by Brian Sentance | 8 December 2008 | 10:34 pm

MiFID Market Data Deterioration

Members of the Investment Management Association (IMA) are not happy about the quality of market data following from the first year of MiFID being with us. According to an article in the FT this morning, a survery of IMA members has voiced concern over the fragmentation of trading venues leading to a deterioration in the quality of market data available.

Most institutions seem positive about the benefits of competition that multiple trading venues such as Chi-X, Turquoise and BATS bring, but IMA members would like to see a centralised venue where prices are consolidated and made available to the market (for free?), similar to the "consolidated tape" available for US markets.

Sounds like the institutional need for centralised data management across different departments and systems is also becoming apparent at a market and exchange level following MiFID. Multiple trading venues and decentralisation is necessary to bring the benefits of competition, but these benefits unsurprisingly do not come without costs or issues (see earlier post).

Posted by Brian Sentance | 25 November 2008 | 11:25 am

Regulators and the law of unintended consequences

Interesting article in the FT fund management supplement on Monday, talking about some research Goldmans have done on the recent performance of US stocks that have a large percentage of their market cap owned by hedge funds.

It seems that hedge fund redemptions and deleveraging is having a strong effect on stock performance. The 50 US stocks most exposed to hedge fund investment have slumped by 19% in September, whilst in contrast the S&P has gone down by 9% and those stocks who little hedge fund investment have only gone down by 2%.

Again an interesting illustration of the systematic risks that are around in the market, ones that once the situation has got bad they only make things worse. The regulators should take a lot of care in identifying and categorising all of these types of systematic effects before they formulate the brave new world of tougher regulation. If they don't, then watch out for the law of unintended consequences, it will always catch you out if it can...

Posted by Brian Sentance | 17 October 2008 | 4:38 pm

Time for System Regulation?

In these difficult times, it's clear there are a lot of questions currently being asked about corporate systems infrastructure and why it has failed to deliver on the needs of the business in times of crisis, just when it was needed most? Despite vast sums of money being poured into those systems, they ultimately failed to do the job that was most needed of them - protecting the business from risk.

However, despite the inevitable finger pointing, it's possible to see how this may have come about. Too many companies have been obsessed with striving for the next best thing to increase short-term returns. System Architects have been tasked with delivering the "Holy Grail of Trading Technology" (that they never reach). This pressure to deliver the ultimate solution has inevitably led to gaps in the existing systems (maybe because they were too technically boring or, more, likely misunderstood?) that have then been exploited and allowed "toxic" risks to pile up.

What the industry is crying out for in this area are standards around risk modelling, performance, quality, accuracy and interoperability. Standards that all external (and internal?) vendors adhere to and can be publicly measured by. Standards that allow the consumer to make choices based on clear, comparable facts that compare like-with-like, as opposed to forcing people to wade through the marketing hype to get to the fundamental issues and detail that matters. Vendors need to come together and cooperate around those standards to deliver solutions that the business community needs, without them having to reinvent the wheel another 20 times over.

STAC (with whom Xenomorph has been working in the area of market data analysis benchmarking) are making clear strides in this direction, as indicated by their latest press release around trading technology.

However, just because STAC have started to define standards doesn't mean that vendors will necessarily join in the party. Just look at Microsoft and the "standard" database benchmarking statistics posted for SQL Server. Microsoft continues to post performance benchmarks, and have been doing so for years, but none of the other database vendors appear to be joining in with them (see SQL Server Magazine article). Why is this? Is it because these benchmarks are deemed meaningless to the consumer or because the other vendors do not want to be seen to perform badly against those benchmarks and hence are avoiding them? My guess is that it is probably some combination of both.

Action is clearly needed.

There are of course already many independent standards initiatives underway within financial services - the market is by no means devoid of them! Most of these have focused on the essential areas of interoperability and messaging (FIX, FpML, MDDL, SWIFT to name but a few). Many of these standards bodies have evolved because the market (as opposed to the regulators) have recognised the need to increase efficiency within the industry as a whole. As a result, they have taken a notoriously long time to evolve as they struggle to sanitise the myriad of exotic financial products that now pervade financial services across countless organisations. For example, just look how long FpML has taken - it started life in 1997 as a research project within JP Morgan and has taken over 10 years to reach its current state. It is still struggling to keep pace with the market. It's a race that it has failed to win in the past but maybe, just maybe, because of recent events and the inevitable caution that will follow around the more exotics products, it will now have a chance of catching up!

Despite the considerable effort these standards bodies have put in we are still, as an industry, at the beginning of that process and dealing with the "wiring" as opposed to the overall system response and measurement that the consumer (and regulator) will now demand to be monitored.

The recent market turmoil is forcing the regulators to start to talk about the need for OTC clearing and better margining so that exposures are crystallised and more transparent to all participants. However, the financial industry and its consumers can ill-afford to wait for standards to evolve slowly and, as the mist begins to clear from the nuclear fallout of recent weeks, the regulators will now be forced (politically) to come down strongly on the industry as a whole and instil a quality of practise that has been sadly missing - a quality of practise that has been present in many other industries (such as manufacturing, pharmaceuticals and the academic sciences) for years.

Despite the complexity of the financial markets, there is no doubt that the vendors and practitioners within them are perfectly capable of moving mountains when they are appropriately incentivised. A quick look at the actions of the Swedish Govt who forced their banks to get their act together and reduce clearing times in 2002 proves this to be the case (see BBC article). In this case, the banks were given an ultimatum and forced to clean up their act quickly or face the music - unsurprisingly, they did.

The same types of ultimatum will now be applied on a global basis. They have to be. Meaningful standards will need to be enforced for financial services systems and practises. Those standards will be forced to ripple down the food chain from the regulator, though the banks and onto the vendor supply chain. These standards will need to be independently defined and verified. With budgets coming under increasing scrutiny, organisations will be forced to look outside their walls and in-doing so the vendors will need to be ready with products and services that meet the needs of the regulators.

I think STAC is heading the right way in starting to set standards that look at overall systems response and beyond.

What's needed now is sufficient pressure by the consumer organisations and regulators to level the playing field, impose standard reference architectures and practises and force vendors to commit to them and be measured by them...

Posted by Chris Budgen | 8 October 2008 | 3:10 pm

Repeat after me...

Nice line from Martin Crook on the need for regulation at the FT:

"Repeat after me: you encourage recklessness if you protect people from its consequences."

Good discussion on moral hazard of intervention towards the end of the article once you get past the bit on Obama/Clinton/McCain - interesting point is that the small risk of huge losses accepted by some banks/hedge funds (whilst in the meantime getting superior returns, see earlier post http://xenomorph.typepad.com/xenomorph/2008/03/hedge-funds-and.html) immediately becomes society's problem if and when these losses occur - so difficult to isolate society from the risk appetite of private investors:

http://www.ft.com/cms/s/0/cd997118-feb9-11dc-9e04-000077b07658.html

Posted by Brian Sentance | 31 March 2008 | 8:45 pm

Regulation is not the answer

Good article on regulation from John Kay in this mornings FT, arguing for an approach where banks are not subject to invasive regulation/investigation of their business strategy but are rather made to face the full risks of their own decisions - whilst at the same time ensuring that depositors and the payments are protected by the government. Could not agree more in my view, shareholders are there to face both upside and downside risk and retail investors should be protected from that which they are ignorant of:

http://www.ft.com/cms/s/0/f03d6aa8-fad6-11dc-aa46-000077b07658.html

Posted by Brian Sentance | 26 March 2008 | 12:10 pm

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