
In this article…
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Phasellus at nisl nunc. Sed et nunc a erat vestibulum faucibus. Sed fermentum placerat mi aliquet vulputate. In hac habitasse platea dictumst. Maecenas ante dolor, venenatis vitae neque pulvinar, gravida gravida quam. Phasellus tempor rhoncus ante, ac viverra justo scelerisque at. Sed sollicitudin elit vitae est lobortis luctus. Mauris vel ex at metus cursus vestibulum lobortis cursus quam. Donec egestas cursus ex quis molestie. Mauris vel porttitor sapien. Curabitur tempor velit nulla, in tempor enim lacinia vitae. Sed cursus nunc nec auctor aliquam. Morbi fermentum, nisl nec pulvinar dapibus, lectus justo commodo lectus, eu interdum dolor metus et risus. Vivamus bibendum dolor tellus, ut efficitur nibh porttitor nec.
Pellentesque habitant morbi tristique senectus et netus et malesuada fames ac turpis egestas. Maecenas facilisis pellentesque urna, et porta risus ornare id. Morbi augue sem, finibus quis turpis vitae, lobortis malesuada erat. Nullam vehicula rutrum urna et rutrum. Mauris convallis ac quam eget ornare. Nunc pellentesque risus dapibus nibh auctor tempor. Nulla neque tortor, feugiat in aliquet eget, tempus eget justo. Praesent vehicula aliquet tellus, ac bibendum tortor ullamcorper sit amet. Pellentesque tempus lacus eget aliquet euismod. Nam quis sapien metus. Nam eu interdum orci. Sed consequat, lectus quis interdum placerat, purus leo venenatis mi, ut ullamcorper dui lorem sit amet nunc. Donec semper suscipit quam eu blandit. Sed quis maximus metus. Nullam efficitur efficitur viverra. Curabitur egestas eu arcu in cursus.
H1
H2
H3
H4
Lorem ipsum dolor sit amet, consectetur adipiscing elit. Vestibulum dapibus ullamcorper ex, sed congue massa. Duis at fringilla nisi. Aenean eu nibh vitae quam auctor ultrices. Donec consequat mattis viverra. Morbi sed egestas ante. Vivamus ornare nulla sapien. Integer mollis semper egestas. Cras vehicula erat eu ligula commodo vestibulum. Fusce at pulvinar urna, ut iaculis eros. Pellentesque volutpat leo non dui aliquet, sagittis auctor tellus accumsan. Curabitur nibh mauris, placerat sed pulvinar in, ullamcorper non nunc. Praesent id imperdiet lorem.
H5
Curabitur id purus est. Fusce porttitor tortor ut ante volutpat egestas. Quisque imperdiet lobortis justo, ac vulputate eros imperdiet ut. Phasellus erat urna, pulvinar id turpis sit amet, aliquet dictum metus. Fusce et dapibus ipsum, at lacinia purus. Vestibulum euismod lectus quis ex porta, eget elementum elit fermentum. Sed semper convallis urna, at ultrices nibh euismod eu. Cras ultrices sem quis arcu fermentum viverra. Nullam hendrerit venenatis orci, id dictum leo elementum et. Sed mattis facilisis lectus ac laoreet. Nam a turpis mattis, egestas augue eu, faucibus ex. Integer pulvinar ut risus id auctor. Sed in mauris convallis, interdum mi non, sodales lorem. Praesent dignissim libero ligula, eu mattis nibh convallis a. Nunc pulvinar venenatis leo, ac rhoncus eros euismod sed. Quisque vulputate faucibus elit, vitae varius arcu congue et.
Ut convallis cursus dictum. In hac habitasse platea dictumst. Ut eleifend eget erat vitae tempor. Nam tempus pulvinar dui, ac auctor augue pharetra nec. Sed magna augue, interdum a gravida ac, lacinia quis erat. Pellentesque fermentum in enim at tempor. Proin suscipit, odio ut lobortis semper, est dolor maximus elit, ac fringilla lorem ex eu mauris.
- Phasellus vitae elit et dui fermentum ornare. Vestibulum non odio nec nulla accumsan feugiat nec eu nibh. Cras tincidunt sem sed lacinia mollis. Vivamus augue justo, placerat vel euismod vitae, feugiat at sapien. Maecenas sed blandit dolor. Maecenas vel mauris arcu. Morbi id ligula congue, feugiat nisl nec, vulputate purus. Nunc nec aliquet tortor. Maecenas interdum lectus a hendrerit tristique. Ut sit amet feugiat velit.
- Test
- Yes

By: Tom Hannagan In previous posts, we’ve dealt with the role of risk-based capital, measuring performance based on risk characteristics and the need for risk-based loan pricing. What about risk mitigation? Some of the greatest sins of the financial industry in the current malaise have been the lack of transparency, use of complex transactions to transfer risk and the creation of off-balance-sheet entities to house dodgy investments. Much has been made of the role of Credit Default Swaps (CDSS) as one of the unregulated markets (and therefore guilty parts) of the current credit meltdown. The regulatory agencies and the media are aghast at the volume (peak of some $62 trillion in notional value) of CDSS that have resulted from a totally private market. The likes of Lehman Brothers, Bear Sterns and AIG were all big issuers of CDSS. And the trillions of notional value of open CDSS is as much as 100 times the underlying value of the actual debt being insured. There are problems here, but it may be worth clarifying the useful risk management activities from the potentially abusive excesses involving such instruments. CDSS are derivative contracts whereby one party buys credit protection from a counterparty. The buyer pays a premium to the seller either in a lump sum or periodically over the life of the contract. If a credit event such as a default on a loan or a bond occurs, the seller of the CDSS pays the holder for the loss or purchases the initial debt, the reference obligation, at a pre-set price. So, a CDSS is in effect a put option that is deep-out-of-the-money. They expire upon termination and most are never exercised. They are subject to fair-value accounting and can change in value from month to month as the credit markets premiums for similar cover moves up or down. Banks and others can use CDSS to, in effect, adjust the nature of credit risk in their portfolios by both buying and selling such contracts. Asset securitizations, whether mortgage-backed securities or other formulations, are in fact broken-down and re-packaged forms of assets that can be sold — transferring certain rights, values and risk to another party for payment received. They are complex and therefore mostly opaque to the general public and even many practitioners. They often involve the use of special purpose entities or trusts that can further confuse investors. These tactics have added to the difficulty of the credit crisis and the collapse of capital markets. But, CDSS are contingent in nature and act more like fire insurance or a back-up data center. Such operational expenses are intended to control risks. The accounting treatment is complex and, to an extent (especially as regards the tax treatment), still not well defined by accounting authorities. For most banks, and most CDSS contract, the premium is amortized over the life of the contract. The premium expense entry in their general ledgers is an expense of doing business that is intended to alleviate some credit risk. We are now talking about a covered CDSS, where the bank has extended credit or invested in a debt instrument. Those who purchased uncovered CDSS are gambling on a default occurrence and used CDSS as a more cost-effective (and secretive) alternative to shorting securities. It is somewhat like a naked short. So, a covered CDSS is ultimately an expense associated with protecting the net asset value of a credit transaction. Importantly, this expense should be included in any performance analysis or pricing of the risk-adjusted profitability of the credit obligation and/or client relationship involved. This risk mitigation exercise may be in lieu of a higher required rate or fee on an otherwise uncovered/unmitigated credit transaction, or being satisfied with a lower risk-adjusted return where the bank assumes (self-insures) all of the credit risk. CDSS quotes/costs, similar to rate spreads on corporate bonds, are the open market’s current feeling regarding an entity’s credit quality or relative probability of default. There are some 400 or so participants in the CDSS market, including writers and dealers. Market data is published for many obligations. Even the previously risk-free Treasury securities now have CDSS quotes – and they have gone up considerably in recent months. It is always the buyers’ responsibility to decide if the quoted prices make sense or not and how such quotes should be used in evaluating credit and negotiating lending opportunities in addition to whether or not to purchase this insurance. Finally, the quality of the seller is a consideration. There is no good reason to buy fire insurance from someone that might not be able to pay for your building if it burns down. CDSS have been private party transactions and, as stated earlier, there have been solvency problems with some of the sellers of such instruments. There is now a move under way to create a central exchange for such transactions with both regulations governing the sellers, more standardized contracts and financial backing of the instruments from the exchange. Such an exchange will address both the transparency of the process and the efficiency of market prices. Risk mitigation strategies (risk-based pricing, portfolio risk management, credit risk modeling, etc.) need to be carried out thoughtfully. If something sounds too good to be true, it deserves a deeper look. Your bank’s credit regimen may well be better at evaluating default probability than a marketplace that is prone to feed on its own fears. But, CDSS “insurance” quotes are an outside point of reference and an option to mitigate some credit risk…no pun intended. Here are two interesting sources of information: * BNET Business Network * Georgetown University — Law Center

Just as with diet recommendations, moderation needs to be the new motto for credit risk management. Diets provide for the occasional bag of chips or dessert after dinner, but these same food items become problems if the small quantity or occasional indulgence suddenly becomes the norm. Similarly, we, in our risk management efforts, put forth guidelines that establish limitations on certain loan types or categories that have been deemed risky should the numbers or quantity become too large a part of the overall portfolio. Unfortunately, we have a tendency to allow earnings or portfolio growth to cloud our judgment and take an attitude of “just one more.” In the past several years, we have experienced excesses in commercial real estate, residential development and subprime mortgages. It is now these excesses that are creating the problems that we are dealing with today. Bringing back these limitations – in other words, reestablishing the discipline in our portfolio risk management – will go a long way in avoiding these same problems in the future. As I learned early in my banking career: “…soundness, profitability and growth…in that order.”

By: Tom Hannagan The problem in the 2005 to 2007 home lending frenzy was not just granting credit to anyone who applied. It was giving loans to everyone at essentially the same price range regardless of normal credit risk scrutiny. While “selling” financial services may be largely an art form, appropriate risk-based pricing is more of a science. Although the financial press seemed to have discovered sub-prime lending in the last year or so, such high-risk lending isn’t new at all. It has been (and is still being) done since finance and money were invented. And, importantly, sub-prime lending has been done profitably by many lenders all along. The secret to their success, not surprisingly, has always been risk-based pricing — even if they didn’t call it that until recent times. Sub-prime funding has been available in many forms and from many sources. Providers range from venture capitalists to pawn shops. It includes pay-day lenders, micro loans, tax refund loans, consumer finance companies, and even dates to Shakespeare’s merchant of Venice. We often hear complaints that the effective rates (prices) on loans from such sources are unfairly high and predatory. The cost of that credit is high, but so is the risk of that credit. Without these kinds of sources, and their high rates, there would not be any credit granted from for-profit sources to high-risk borrowers. Listed firms that regularly provide pay-day loans or cash advances to sub-prime borrowers have very high gross margins and very high credit charge-offs, compared to banks. They also have much higher risk-based capital (or equity) positions that range from 40 percent to 60 percent of their average assets. This risk-based capital burden is much higher than the 8 to 10 percent found at commercial banks. So the sub-prime lenders have a significantly larger capital cushion than banks. Most of these financial results and ratios are examples of successful risk management where the credit risks are identified, managed, priced and backed by sufficient capital. Then…along came the rose-colored greed of the housing bubble that resulted in aggressive building and selling of homes, loan originations to all (no-down, no-income, no-assets, no-problem mortgages), securities packaging and attractive ratings, and global leveraged investing — all by prime-oriented entities and all at prime-oriented prices. Well, obviously, it didn’t work. Risk-based pricing of mortgages would have dissuaded many home buyers to begin with… but what would we have done with all of those shiny new homes? Realistic credit models (that took into account a full credit cycle and a huge proportion of sub-prime credits) would not have rated mortgage-backed securities as AAA. Regulators that were still focused on earnings correctness (the last major snafu) should have been looking into realistic net asset values. And highly compensated investment bankers, with 30-to-1 leverage ratios, would not have gone overboard with intuitively dodgy investments. Few of these players took risk management seriously. The new danger is that banks are doing the whole thing in reverse. They are tightening lending standards — which is, of course, a euphemism for shutting off credit. The danger has nothing to do with so-called credit standards. It’s the general over-reaction of shutting off credit to all borrowers, again, without regard to relative risk. The latest Federal Reserve Board survey of senior loan officers paints a picture of rapid tightening to record levels. We feel that credit standards should always improve AND that loan pricing should always proportionately reflect risk-adjusted rates and terms. Opening the flood gates and then slamming them shut is a very pro-cyclical behavior pattern on the part of bankers that doesn’t reflect a measured approach, borrower-by-borrower, using reasonable risk management at the client relationship level.


