Monday, February 23, 2009

It scored 15 out of 100 on reading ease; apparently you need a grade level of 16 to understand it.

From Felix Salmon:

"Parsing Treasury

I just ran this morning's joint statement from Treasury, the Fed, and just about every other regulatory institution in the US through a readability calculator. It scored 15 out of 100 on reading ease; apparently you need a grade level of 16 to understand it.

So you might be forgiven for missing the message here:

Any government capital will be in the form of mandatory convertible preferred shares, which would be converted into common equity shares only as needed over time to keep banks in a well-capitalized position and can be retired under improved financial conditions before the conversion becomes mandatory. Previous capital injections under the Troubled Asset Relief Program will also be eligible to be exchanged for the mandatory convertible preferred shares. The conversion feature will enable institutions to maintain or enhance the quality of their capital.

I'm not sure I understand this myself, but the government here seems to be coming up with ever-more-obscure forms of capital which it can inject into the banks. We're relatively familiar with preferred shares, common equity, and warrants to buy common equity; now we must add to that list this new animal: mandatory convertible preferred shares, which had a brief moment in the sun back when banks were raising private capital rather than having to go to the government for bailouts.

These shares seem to work in a most peculiar way. For one thing, they convert "only as needed over time", which implies that there isn't some set conversion date, despite the fact that conversion is mandatory. What's more, the swap from normal preferred shares into common equity looks like it's being envisioned as a two-step process, with the preferred shares first being swapped into the new mandatory convertible preferreds, and then, if necessary, ultimately becoming common stock.

What's weird is that the government starts off talking about capital being "in the form of mandatory convertible preferred shares", which implies that those shares are capital, before then going on to say they will "be converted into common equity shares only as needed over time to keep banks in a well-capitalized position" -- which implies that they're not really capital unless and until they convert.

The key here is the concept of tangible common equity: before they convert, these instruments are capital, but not TCE. After they convert, they're both capital and TCE. But how such nice distinctions are meant to guarantee the medium-term health of the US financial system while avoiding the taint of nationalization is less obvious."

Me:

Is there any truth to the rumor that Treasury is about to announce that they've managed to hire Ben Stein of the NY Times as a senior economic adviser? Apparently they're quite excited, and believe that the country will be as well.

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