Interesting piece in today's Financial Times examining why securitization
did not prevent a banking crisis. The banks make up a large part of the
asset-backed market - either through their trading desks or the off balance
sheet conduits they sponsor - so much of the risk is recirculated among
themselves rather than dispersed more widely. When investors fled mortgage
and other asset-backed securities, the banks could no longer offload their
loans, watched their own ABS portfolios shrink in value, and were forced to
backstop their beleaguered conduits - freezing interbank lending and sending
them scurrying to the central banks to boost reserves the latter had deemed
adequate in the bold new age of credit securitization.

*    *    *

Regulators rethink bank rules
By Gillian Tett
Financial Times
September 19 2007

As Northern Rock has crumbled in recent days, Adam Applegarth, chief
executive of the UK mortgage lender, has made little attempt to conceal his
shock. “Nobody could [fore]see the squeeze on global liquidity ... Watching
liquidity disappear has been astonishing,” he declared last week, adding
that “life changed on August 9” when a sudden money market intervention by
the European Central Bank revealed a broad freeze in the funding system.

Such comments about the unpredictability of events are unlikely to placate
investors in Northern Rock’s shares, let alone the depositors who queued to
get their money out. But Mr Applegarth’s comments highlight a crucial point
about the spreading credit squeeze: behind the scenes many other private
sector bankers, central bankers and regulators are also expressing
astonishment at the turn of events.

Until this summer, most financiers had assumed that it was extremely
unlikely that widespread problems in the money markets – on which financial
institutions depend to fund their day-to-day operations – would occur. Thus,
while financial institutions of almost every hue have been pouring resources
into computer models designed to assess future risks, they had spent
relatively little time analysing the events that have brought Northern Rock
crashing down.

At the Bank of England, for example, officials had this year started warning
about liquidity risks and creating new frameworks for measuring these, ahead
of almost all of the central bank’s counterparts in the western world. But
the Bank had not rushed to finish this framework, since it thought a
systemic funding freeze was unlikely. “Nobody expected a complete money
market freeze of this kind,” confesses one senior continental European
central banker. “Every­one was looking for idiosyncratic financial shocks or
worrying about subprime or credit being mispriced – that was the focus.”

Or as the treasurer of one big investment bank admits: “What we are seeing
now is like a natural disaster – whole parts of the financial system which
we took for granted have stopped working. But that was not something that
people had really prepared for.”

To a certain extent, this lack of preparation reflects the perennial
tendency of experts in risk management to keep fighting the last financial
war – in this case, the implosion of Long Term Capital Management, a US
hedge fund, in 1998. The scenario that banks’ planning meetings have focused
on has been the possibility of another large-scale hedge fund collapse.

In some respects, this LTCM obsession has delivered welcome benefits. This
summer, almost two dozen hedge funds ran into serious problems, including
two linked to Bear Stearns, the Wall Street investment bank. These jolts
have been handled relatively smoothly – in part because banks and regulators
prepared so thoroughly for this scenario. “Hedge funds have not been the
issue this time,” says one senior international regulator, who suggests this
outcome may help to defuse demands from politicians for greater regulation
of hedge funds in the coming months.

But while a focus on LTCM has helped the industry survive some of this
summer’s troubles, it may also have distracted risk managers from
considering other potential shocks. That in turn highlights a bigger
problem: in recent years regulators and investors have tended to play down
the risks attached to banks, because they tended to assume that the biggest
threats to financial stability lay elsewhere, most notably in unregulated
areas such as hedge funds.

The reason for this lopsided view is that a fundamental shift has been under
way in the financial system.

Banks used to be considered the dominant pillars of the financial world,
since they provided credit to companies and individuals and retained the
risk that these loans would turn sour. That meant that if a company
defaulted, banks were left on the hook. As a result of this vulnerability,
regulators required banks to hold large reserves of spare capital and pools
of liquid assets to ensure they could cope with sudden credit shocks.

However, this decade has brought a move to what bankers describe as an
“originate and distribute” model – meaning that although banks still tend to
make (or “originate”) loans, these are increasingly sold (or “distributed”)
to other capital market investors rather than retained on the banks’ books.
Since they have been selling on these loans, regulators have assumed that
the banks would be less vulnerable if loans turned bad. Thus they have been
willing to let the banks hold smaller cushions of capital relative to the
volume of loans they create.

This shift towards an “originate and distribute” system has been good news
for investment bankers, since it has enabled them to increase the volume of
business they can do. One reason why Northern Rock, for example, expanded
its mortgage book so fast this decade is that when the lender started
turning its home loans into securities, regulatory rules permitted it to
lend three times as much per unit of capital.

Until now regulators have generally tolerated – if not actively encouraged –
this “originate and distribute” trend, since there was a widespread belief
that the financial system would be safer if credit risk were spread around.
In particular, policymakers assumed that the fact that banks were selling
risks into the capital markets was making them less vulnerable to any future
financial turmoil. Thus, it was presumed that there was now far less chance
that a crisis would ever erupt in, say, the interbank lending market than
among the hedge funds who were buying the credit risk from banks.

However, this summer’s events have shattered some of these comforting
assumptions. What has become clear in recent weeks is that banks’ offloading
of risks into the capital markets has not eliminated their vulnerability to
a shock; on the contrary, although banks have shoved risk out through the
“front door” (as evidenced in their published accounts), they have been
re-acquiring it in other, indirect – or backdoor – ways.

One issue creating problems is that banks have been acquiring loans from
each other, repackaged as new instruments via the capital markets. Thus as
the value of subprime securities has fallen, for example, it has hurt not
only the hedge funds and other non-bank institutions but the investment
portfolios of banks too.

Another problem is that banks have been selling their credit risk to
investment vehicles or conduits. Until recently, it was widely assumed that
these were separated from the banks, because they raised finance in the
capital markets. But the current crisis has forced banks to prop up these
vehicles, by unexpectedly extending liquidity lines – meaning that risky
assets are in effect moving back on to the banks’ balance sheets again.

Worse still, as the market shock has spread, investors have started to lose
confidence in techniques that have underpinned the “originate and
distribute” model, such as securitisation (or the practice of taking loans
and using these to issue bonds).

That, in turn, has made it impossible for banks to sell assets into the
capital markets – such as loans to risky borrowers. “Markets for a wide
range of securities have de facto disappeared,” says Marco Annunziata, chief
analyst at Unicredit.

The net result of this is that, to cope with an influx of assets, banks are
scrambling to plump up the cash cushions they had let grow thin in recent
years. In place of the “originate and distribute” model, in other words, a
new pattern of “re-intermediation” is emerging, in which banks are again on
the hook for risk. “Re-intermediation by banks is a likely consequence of
the current situation,” note analysts at Dresdner Kleinwort Benson, who warn
that this trend will “stretch capitalisation and reduce returns on assets”
for most banks.

Some think this could herald a sea-change in 21st-century finance that would
see banks returning to a much simpler business model instead of endlessly
slicing and dicing risk. Others insist that the current pattern is simply a
short-term response to a specific financial crisis that will quickly abate.

“For financial innovation, there is no reverse gear,” argues Moody’s, the
credit rating agency (and an institution that has greatly benefited from the
securitisation trend in recent years). “The old days of the bank-based
intermediation system are gone. It is improbable that a dramatic reversal, a
scaling backof securitisation and credit risk transfer will take place.”

But even if this second view is correct and the “originate and distribute”
model is here to stay, the recent shocks are already forcing policymakers to
rethink some of their approaches. This is likely to trigger some specific,
micro-level reforms in the coming months: in the UK, for example,
policymakers are scrambling to improve the system for protecting bank
depositors from financial turmoil. While officials have been aware for
several years that this system contained potential flaws – and had been
mulling changes – efforts to reform it had not had much urgency before,
precisely because a bank run was considered a low-risk event.

The events of recent weeks may also trigger a broader review, well beyond
the UK, of the way regulators treat banks. Central bankers are already
considering taking steps to force banks to prepare more effectively for
liquidity shocks in their trading operations, for example, when a new set of
rules about capital adequacy comes into force next year, known as Basel II.

Some policymakers also think pressure could grow for banks to hold more
capital on their books against loans – even if they have sold on the credit
risk. “One of the things we will have to look at is whether we should
require banks to hold more capital against stuff they have distributed off
their books, but where there is a risk they may need to take this back on to
their books for legal or reputational reasons,” says David Dodge, governor
of the Bank of Canada.

A rethink is also looming about the treatment of off-balance-sheet vehicles.
“This is an area where there will definitely need to be a debate,” admits
one senior European financial official. Meanwhile, policy­makers of almost
every hue are now united in calling for far greater transparency of complex
finance. Or as Moody’s notes: “Looking forward, there will be ... a higher
demand for capital and liquidity buffers throughout the financial system,
which will marginally increase the cost of capital.”

Such measures will be disliked by bankers, who know that a tougher
regulatory regime could make finance far less lucrative. But the longer the
current market turmoil continues, the more the recriminations will grow –
and, with them, the pressures for reform.

One thing is already clear: just as risk managers have spent the last decade
discussing LTCM, the next 10 years will now be shaped by an equally intense
debate about the lessons to be learnt from Northern Rock and the shock being
felt by Mr Applegarth and others.

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