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Nouriel Roubini, global macro Uber-Bear, has posted an interesting commentary
on his blog - "The
delusional complacency that the "worst is behind us" is rapidly melting away...and
the risk of another run against systemically important broker dealers" which
I am excerpting below with my comments in red:
The deleveraging process for the financial system has barely started as most
of the writedowns have been for subprime mortgages; the writedowns and/or provisioning
for the additional losses have barely started. Thus, hundreds of banks in the
U.S. are at risk of collapse. The typical small U.S. Bank (with assets less
of $4 billion has 67% of its assets related to real estate; for large banks
the figure is 48%. Thus, hundreds of small banks will go belly up as the typical
local bank financed the housing, the commercial real estate, the retail boom,
the office building of communities where housing is now going bust. Even large
regional banks massively exposed to real estate in California, Arizona, Nevada,
Florida and other states with a housing boom and now bust will go belly up.
This is true, and the risk is borne not only by the smaller and regional banks,
but the big brokers and the entire US economy as well. This is a snapshot from
the Asset Securitization Crisis Series - A very significant part of our GDP
is now tied up in this mess! In the decade from 1988-1997, residential loans
have expanded at a CAGR of 10.1% as compared to 3.5% for commercial loans.
However, in the following decade i.e. 1998-2007, residential loans grew at
a lower CAGR of 11.2% as compared to 12.4% for commercial loans, mainly because
of small and mid-size banks lent more in commercial real estate during the
period. Although commercial real estate loans were higher paying, they
also bore higher risk in the form of liquidity, valuation, market risk - which
affected the risk profile of these banks that were incapable of bearing such
a level of complexity in risk in the first place.

Source: FDIC
Shift from traditional banking activities
With major opportunities of revenue generation being offered by trading and
other investment activities, as well as the lifting of the Glass-Steagal Act
in the US (which allowed commercial banks and investment banks to compete directely),
banks across the globe shifted from traditional banking activities to other
sources of income, leading to better revenue diversification. The ratio of
non-interest income to a bank's total income has more than doubled from 20%
in 1980 to approximately 44% in 2006.

Source: FDIC
Back to the Roubini Excerpt...
And even large banks and broker dealers are now at risk. After the bailout
of Bear Stearns' creditor and the extension of lender of last resort liquidity
support the tail risk of an immediate financial meltdown was reduced as that
liquidity support stopped the run on the shadow banking system. Indeed in March
we were an epsilon away from such meltdown as - without the Fed actions - you
would have had a run not only on Bear but also on Lehman, JP Morgan, Merrill
and most of the shadow banking system. This system of non-banks looked in most
ways like banks (borrow short/liquid, leverage a lot and lend longer term and
illiquid). So the risk of a bank-like run on non-bank (whose base of uninsured
wholesale short term creditors/lenders is much more fickle and run trigger-happy
- as the Bear episode showed - than the stable base of insured depositors of
banks) became massive. Thus, the Fed made its most radical change of monetary
policy since the Great Depression extending both lender of last resort support
to non-bank systemically important broker dealers (via the PDCF) and becoming
a market maker of last resort to banks and non-banks (via the TAF and the TSLF)
to avoid a full scale sudden run on the shadow banking system and a sure meltdown
of the financial system.
While the tail risk of such a meltdown has now been reduced the view that
systemically important broker dealers - that have now access to the TSLF and
the PDCF - now don't risk a panic-triggered run on their liabilities is false;
several of them can still collapse and not be rescued. The reasons are as follows:
liquidity support by the Fed is warranted for illiquid but solvent institutions
but not for insolvent ones; and the risks that some of the major broker dealers
may face is not just of illiquidity but also insolvency (Lehman had as much
exposure to toxic MBS, CDOs and other risky assets as Bear did). The Fed already
tested the limits of legality (as argued by Volcker) in its bailout of Bear's
creditors.
I have a lot of respect of Professor Roubini's predictive success over the
last few years, but he (like most) appear to have not taken a close look at
these banker's books. Reference my original research on MS form December of
last year. Once it comes to the truly illiquid stuff, Morgan has Bear beat
by about 25% and Lehman beat by a large margin as well. As a matter of fact
the only one's that come close are the media and Street's golden darling boys,
Goldman Sachs. Surprise, Surprise!!! It always pays to go through the numbers.
Is GS reyling on risky prop trading to keep up this pristine facade? Curious
minds want to know.
The riskiest bank on Wall Street - High exposure to Level 3 assets despite
significant write-downs

Unconsolidated VIEs could aggravate woes
VIEs have tormented most Wall Street financial majors -- several of them have
had to consolidate their VIEs to increase liquidity and limit losses. These
innovative, structured entities were introduced to boost earnings without transferring
actual risk into the balance sheets of banks.
Morgan Stanley has significant exposure to VIEs, with the maximum loss ratio
averaging roughly 50% in recent years. The large exposure ($37.7 billion in
4Q 07), high loss ratio and adverse market conditions could force the company
out of business if its maximum loss assumptions become reality. Morgan Stanley's
unconsolidated VIEs comprise the most troublesome asset categories - MBS & ABS
portfolios (worth $6.3 billion), credit & real estate portfolios ($26.6
billion) and some structured finance products ($8.6 billion). Loss exposure
in the credit & real estate portfolio is not expected to be lower than
70% considering the slump in housing demand, falling home prices and rising
foreclosures. The growing housing inventory across the U.S. has also raised
concerns about the disposal of these assets. Home prices across the U.S. declined
7% (on average), while foreclosures increased 20% during the past year alone.
This scenario reflects the bleak prospects of the housing industry and the
securities linked to it.
Unconsolidated VIEs, Exposure to loss (in $ mn) and loss ratio
(in %)

Source: Company data
And back to Roubini...
Suppose that a run - triggered by concerns about illiquidity and solvency
- occurs against a major broker dealer (say Lehman) would the Fed come to the
rescue again? The answer is not sure: such broker dealer has access to the
PDCF but sharply borrowing from this facility would signal that the institution
may be bleeding liquidity and be in trouble; thus large access to the Fed facility
may cause the run on the liabilities of such financial institutions to accelerate
rather than ebb. The reason is as follows: if creditors of the broker dealers
knew with certainty that the Fed liquidity tab is open and unlimited the existence
of the facility would stop the run. But if there is any meaningful probability
that the amount that the Fed would be willing to lend to an institutions using
that facility is not unlimited and is not unconditional then use of the facility
may accelerate the run - as those first in line would have access to the liquidity
provided by the Fed lending to the broker dealer in trouble while those waiting
may be stuck once the lending stops. This is akin to a currency crisis in a
pegged exchange rate regime triggered by a run on the forex reserves of a central
bank. Once the reserves are running down and investors expect that the central
bank will run out of reserves the run accelerated and the collapse of the peg
occurs faster.
I tend not to build too high a concentration in any one position (risk managment
guidelines), but I have been allowing certain broker banks to tilt the scale
a little. I hear whispers of potential runs, and the logic is there as Dr.
Roubini has illustrated and as I have pointed out in earlier posts. This combined
with the fact that a couple of these brokers are quite exposed to risk and
the media/pundits haves not their homework in regards to exactly who is weak
and why portends another Bear Stearns-like catastrophe/profit oppurtunity.
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