Showing posts with label CAP Treasury's Capital Assistance Program. Show all posts
Showing posts with label CAP Treasury's Capital Assistance Program. Show all posts

Friday, April 24, 2009

handful of the 19 banks to raise significant amounts of new capital and could lead to greater government ownership stakes in the banks.

TO BE NOTED: From the NY Times:

"
Regulators Disclose Criteria for Bank ‘Stress Tests’

By ERIC DASH

"Federal regulators released the criteria they used to assess the financial health of the nation’s 19 biggest banks on Friday, but provided little new information for investors to distinguish the industry’s weak players from the strong.

In a 21-page report, the Federal Reserve regulators broadly laid out the tools they used to project bank losses if the economy worsens, and officials established an unspecified baseline to measure how much additional capital the banks should add as a buffer against higher losses. But they provided no concrete metrics to assess the depths of the troubles facing the industry or specific banks.

Still, the Federal Reserve report suggested that regulators are focusing on the amount of capital that they want banks to hold in common stock, which makes it easier for them to absorb future losses as the recession wears on. That could force at least a handful of the 19 banks to raise significant amounts of new capital and could lead to greater government ownership stakes in the banks.

“Losses associated with the deepening recession and financial market turmoil have substantially reduced the capital of some banks,” the Federal Reserve report on the stress test said. “Lower overall levels of capital — especially common equity — along with the uncertain economic environment have eroded public confidence in the amount and quality of capital held by some firms, which is impairing the ability of the banking system to perform its critical role of credit intermediation. “

Despite the limited details, Wall Street analysts and traders are already using whatever glimmers of information that have seeped out to conduct their own “stress tests.” Investors are making bets on which bank stocks may rise or fall even before the official exam results are announced. The stress test criteria were released as federal regulators started briefing top executives from the 19 large banks about how their companies fared on the examination. In closed-door meetings at the regional Federal Reserve Bank offices, the regulators plan to review their preliminary findings and inform bankers if they need additional capital. The banks will have until Tuesday to dispute any of the results before they are made public on May 4.

Wall Street has been buzzing about the stress tests since they were announced two months ago as a cornerstone of the Obama Administration’s plans to aid the nation’s ailing banks and overhaul the regulatory system. The program was designed to bolster confidence in the financial system, with regulators certifying which banks were healthy enough to start returning the government bailout money, and which banks needed additional capital.

But it has turned into a minor quagmire, putting regulators in the awkward position of picking winners and losers and setting off internal debates over how much of the confidential test information to disclose. Federal law requires banks to keep exam results under wraps.

Regulators have not yet formally required banks to increase their levels of core capital, or tangible common equity to protect against losses, but the additional capital cushion moves in that direction. Previously, regulators have suggested that banks maintain a tangible common equity ratio of 3 percent, and focused on a broader metrics of financial strength.

Regulators and investors want banks to increase the amount of tangible capital they hold so they can more quickly write down losses that many still expect from real estate, credit cards and other troubled assets.

Investors are paying close attention to the methodology. Even so, the new information is unlikely to provide a full picture of the banks’ financial condition, said John McDonald, a banking analyst at Sanford C. Bernstein.

The data, for example, does not reflect differences in each bank’s lending standards or their ability to generate revenue. Nor does it account for the fact that banks made more loans in areas like California and Florida, where the housing and job markets have been hardest hit.

Investors and the banks have been bracing for the official findings since early March, when the banks sent regulators their own results of a series of computer-run analyses that looked at what might happen if the economy deteriorated. The tests, overseen by the Federal Reserve, involved more than 150 banking regulators and asked the banks to analyze how a variety of hypothetical situations would affect their loss rates. Those include unemployment rising to 10.3 percent by next year, home prices falling an additional 22 percent this year, and the economy contracting by 3.3 percent this year and staying flat in 2010.

As part of the test, the banks analyzed each category of loans they held and compared their results with the ”high” and ”low” range of government loss estimates. If a bank expected fewer losses than the government did, the regulators asked the institution to explain why. The banks were also asked to project their earnings over the next two years to give the regulators a better sense of how much capital they would have to absorb the coming losses.

Over the last few weeks, top federal officials have been combing through the data to get a handle on the depth of the banks’ losses. They also tried to make apples-to-apples comparisons across all 19 banks before determining how much fresh capital each needs.

Banks will be given the chance to raise money from private investors first, but the fragile condition of some lenders and the short timetable before the results are made public makes it increasingly likely that they will return to the government for money.

Administration officials say that the banks may also be able to convert the government’s existing preferred share investments into common shares. That will allow the Treasury Department avoid returning to Congress for additional bailout money but it also could lead to greater government ownership of the banks."

Thursday, April 23, 2009

Whatever you may think of Treasury's approach to the banks, it's hardly "wait and see

From The Economics Of Contempt:

"Since when is Treasury under a "wait and see" policy?

I'll give Simon Johnson one thing: he's great at knocking down straw man arguments.

Today's straw man is Treasury's alleged "wait and see" policy on the banks. Johnson and Peter Boone claim on the NYT's Economix blog that Treasury's plan is to "look the other way on big banks' problems and hope an economic recovery brings them back to sustained profits." They then proceed to show why this "wait and see" policy is a bad idea.

Clever!

Too bad it's just not true. How any semi-informed commentator could describe Treasury's approach as "wait and see" is beyond me. Treasury has adopted a multifaceted approach to the major banks, which includes the Capital Assistance Program (CAP), as well as the Public-Private Investment Program (PPIP), which encompasses the Legacy Securities Program and the Legacy Loans Program.

What do Johnson and Boone propose? Something eerily similar to what Treasury has already proposed:
We know there is a problem in the banks, just not how large it is. So why not do more than is absolutely necessary, in terms of forcing restructuring and recapitalization of the sector (ideally with private money)? Give everyone certainty that the problems are over once and for all.
Gee, that sounds an awful lot like Treasury's Capital Assistance Program, which is designed to determine how large the problem in the major banks is, and then force each bank to recapitalize — "ideally with private money," but if that's not possible, then with government money.

As for forced restructurings, Treasury currently lacks the legal authority to do that, but it has already proposed a new resolution authority for large bank holding companies. (I personally don't think the proposed resolution authority can work, but you can't say that Treasury isn't trying to acquire the legal authority to force restructurings of major bank holding companies.) Oh yeah, and then there's the $1 trillion PPIP, which I hear is kind of a big deal.

Whatever you may think of Treasury's approach to the banks, it's hardly "wait and see."


Me:

Don said...

I think that it really has to do with what we expect at the end of this crisis. Johnson believes that it will be a very similar arrangement to what we had before this crisis. That is, in my opinion, one way to look at things. Geithner seems to be saying that, in fact, when he talks about the role of the private sector, etc.

I am in the odd position of defending Geithner for pragmatic reasons. However, I could be wrong, but I believe that he and Bernanke would be open to large changes in our system. But I'm reading between the lines and reading a lot into their past speeches.

I agree with Johnson's critique. We have had a Welfare State in which some interests, faux free marketers, have been very effective in influencing the government, especially during the Bush years. I call it a Crony Welfare State.

We're still going to have a Welfare State after this, but we can make changes that will better serve our country. I'm for Narrow Banking, an idea put forward by those communists Friedman, Knight, Simons, and Fisher. We should also have a self-insured, supervised,not government guaranteed financial sector.

I'm also a follower of Edmund Burke. I don't believe that Politics and political Theory are the same thing. Politics is the art of the possible. Hence, I can support policies that I do not completely agree with.

In that sense, I would expect Geithner to be saying what he is saying, even if he agreed with me, which I doubt. What I take Johnson to getting at in "Wait & See" is that we're wasting our one chance to change things. I don't agree, but I understand and share his concern.

The changes, so far, have weakened the crony system, but there is a lot of work to be done. I would mention one area of disagreement with Johnson and Kwak: the issue of bondholder's rights isn't the same issue as the power of banks. William Gross is correct to be worried about the consequences of wiping out bondholders. I simply believe that, once taxpayers are involved, they are more important than bondholders. But it is not in our interest to imply or assert that the interests of bondholders, who are often lending money so that our businesses can expand and hire more people, are not essential.

So, I'm suggesting that in Chrysler and PPIP, etc., bondholders should be taken care of unless it really makes the taxpayers situation worse off, given an analysis of the trade-offs.

Don the libertarian Democrat

April 23, 2009 12:29 PM

Saturday, April 18, 2009

That's the noise being made to reassure the great unwashed public. But whether there is any real difference in outcome is unknowable.

From Naked Capitalism:

"Bank Stress Tests Now Officially a Garbage In, Garbage Out Exercise

Listen to this article. Powered by Odiogo.com
We've had plenty of company in voicing doubts about the Treasury's so-called stress tests of the 19 biggest banks. To quickly recap the main issues:
The bank will run the tests themselves, using the same risk models that caused the mess. With only ten examiners on average per bank, and most of the banks having very diverse businesses (mortgages, complex structured credits, credit cards, consumer loans, commercial real estate, large corporate loans, small business lending, foreign operations, credit default swaps, other derivatives exposures, foreign lending and FX exposures), their ability to probe the results, from a skill and manpower basis, is dubious, particularly in the capital markets exposures

For the simpler products, there will be no verification of the loans versus the underlying files.

The so called "adverse" scenario, at the time the tests were announced, was far more optimistic than the typical trajectory of a financial crisis. As the IMF noted in its newly released economic outlook, the current mess is likely to prove worse, due to it being an international, synchronized credit crisis (past outbreaks have been at worst regional).

As the economy has only deteriorated since the tests were announced, even more optimistic mainstream economists are coming to the view that the supposed downside case is likely to approximate the middle of the road case, meaning the "stress" in the tests is insufficient.

The Administration has acknowledged this problem with one of its typically Orwellian responses, by saying it will interpret the results more harshly. But how can anyone do that in a realistic way given the inadequate knowledge of the operations, resulting from sending in only enough examiners to have pleasant conversations over tea about the numbers as they came out? Without digging into operational level data and seeing how it is adjusted to produce bank wide results, any understanding is woefully superficial. Even among the big banks, you can't apply the same sort of adjustment to a largely retail bank like Wells versus a bank with incredible product and geographic diversity like Citi. or ones with very substantial trading operations and complex derivatives exposures (JP Morgan, Goldman, Morgan Stanley, as well as Ciit). Pray tell, how do they decide what adjustment to make to banks with very distinct business profiles? And even for ones with largely similar profiles (Goldman and Morgan Stanley), there are very important differences between.

Answer: they haven't done the spadework to make these subjective adjustments. So the whole exercise, which was dubious from the start, is now patently a PR stunt, with the Treasury also having indicated that it wants to have the exercise be seen as having teeth. That means the Treasury has decided on a forced curve, that on their relative ranking, the somones on the bottom will need to raise more equity (either from the public or failing that, the TARP).

The one thing that may change (we stress may, to paraphrase T.S. Eliot, this Administration cannot take very much reality), is that the line on the relative ranking of who is deemed to need more equity or not may be pushed higher. That's the noise being made to reassure the great unwashed public. But whether there is any real difference in outcome is unknowable. All that is certain is a show will be made as to how the process was toughened up.

A relative ranking is a "price of everything, value of nothing" process, definitive yet singularly unhelpful. An absolute measure, of who needs dough and who doesn't, is vital. In fact, we have said repeatedly that that should have been the Treasury's and SEC's top priority after Bear failed. But the procedures were never in place to do that adequately.

From the Financial Times:
Rising unemployment is prompting US authorities to consider taking a tougher stance in judging the results of bank stress tests...

When the stress tests were revealed two months ago, the authorities defined the adverse scenario as one in which unemployment rose gradually to peak at 10.4 per cent in late 2010.

But, since the announcement was made, unemployment has risen much more quickly than was expected, even under the “adverse scenario”...

The authorities believe it is too late to revisit the assumptions underpinning the stress tests. However, it is not too late for them to decide to interpret the implications for capital more stringently. The Treasury declined to comment.

Making such an adjustment would help arguments against claims by critics such as Nouriel Roubini, chairman of RGE Monitor, who wrote on his blog: “The stress test results are meaningless as actual data are already running worse than the worst case scenario.”

The authorities have not yet made a final decision on changing the way the tests will be interpreted. Even if officials do lean in this direction, it may never be visible because they did not specify in advance any precise formula relating stress test outcomes to required bank capital. Moreover, signs of economic recovery could persuade policymakers to disregard the rapid recent rise in unemployment on the grounds that it might revert to the less alarming trajectory they originally expected.

Policymakers also believe that other assumptions in the test still reflect a worse-than-expected outcome.


Me:

Don said...

“Will applications filed by QFIs or the names of applying QFIs be released publicly?
No. Treasury will not release the names of QFIs who apply for the CAP or those which
are not approved. Treasury will publish electronic reports detailing any completed
transactions, including the name of the QFI and the amount of the investment, as required
by the Emergency Economic Stabilization Act of 2008, within 48 hours of the
investment.”

And:

“What if a QFI needs capital in excess of the investment limit referred to above?
An institution that needs capital in excess of the investment limit referred to above is
deemed as needing “exceptional assistance.” In consultation with the appropriate Federal
banking agency, Treasury will determine whether an institution qualifies for “exceptional
assistance” on a case-by-case basis.
What will be the terms of transactions involving QFIs in need of exceptional
assistance?
QFIs falling under the “exceptional assistance” standard may have bank-specific
negotiated agreements with the Treasury Department.”

That's from CAP. In other words, the whole point was to assure that these banks would be carefully examined for problems, and then made whole or solvent. What we were supposed to hear in public was the amount of assistance, which could vary with the size and particular needs of each bank. The program was meant to instill confidence by assuring the necessary backing for solvency.

Now, just looking at the program as presented, it's asinine to announce who's in what shape. That would negate the point of issuing the blanket guarantee of solvency.

What's happened is that popular perception has latched onto the idea of "stress tests" being a test for who gets seized or something like that. But, think about it: Even if the govt was going to do that, they wouldn't tell us beforehand.

The program was meant to erase a stigma, not produce one. For one thing, we own a lot of Citi, which is trying to sell its assets. It will hardly make selling those assets easier if we announce exactly what they're getting and why.

Now, if you don't want the govt to help these banks, I can understand pissing on this arrangement. But if you do, why would you want to make the banks less able to do business than more?

Finally, unless we seize the banks in an FDIC sort of way, we are going to be left with a hybrid. In other words, if we simply own stock and have someone manage the bank for us until we sell it, that will still be a hybrid plan because the bank will be a private company with certain fiduciary responsibilities to all its shareholders. It's probably a better idea than CAP, but it has lots of risks, such as:
1) It's one thing for a private company to default, another for a govt to default. If we own it, foreign investors and countries expect us to guarantee it. That's why it could lose us a lot of money. We could just screw them, but that will have negative consequences.
2) We will involve ourselves in foreign politics. For example, we needed a retroactive govt law from Mexico to be able to take more than a 10% stake in Citi. That was popular with some people, while not for others. As well, selling Banamex could have currency issues. All of Citi's foreign holdings will involve a similar problem.
3) All other hybrid problems, like conflict of interest, will remain. After all, Geithner is not even from Wall Street, and he's being accused of collusion.

It is true that we can announce every detail of these tests, and that might be what happens. But it could well end up costing us a lot more money if the market and potential investors or buyers hold out for more money. I thought that we were trying to save money.

I'm no fan of this plan, but I'm also not a fan of us shooting ourselves in the foot over and over again. We're in a damnable mess, and there's no clean or easy way out. We've lots of bad choices to choose from. That's it.

Don the libertarian Democrat

April 18, 2009 11:46 AM

Thursday, April 16, 2009

take insolvent banks into receivership and wipe out the stakeholders – senior creditors included. This would be nationalisation by another name

TO BE NOTED: From the FT:

"
Stress tests deepen headache for Obama

By Edward Luce in Washington

Published: April 16 2009 18:17 | Last updated: April 16 2009 18:17

Many US presidents – the past two included – begin their terms vowing to focus on domestic problems, but end up obsessed with foreign policy. For Barack Obama, who on Friday travels to Trinidad for the Summit of the Americas, having stopped off to visit Felipe Calderón, his Mexican counterpart, that switch may come unusually quickly.

Mr Obama is feted abroad, even if he is finding it harder than his predecessors to impose Washington’s agenda on the world. But the realities of dealing with an increasingly multi-polar world pale in comparison to the growing migraine he faces at home.

Within the next two weeks the Obama administration is to release some results of the long-awaited “stress tests” of the nation’s 19 largest banks. If truth be told, these tests could have been finished in an afternoon many weeks ago. But the administration pushed back the day of reckoning to buy some breathing space.

The political climate has since only deteriorated, even if the economy has shown one or two “green shoots” of recovery. Those shoots could easily be killed off by the severe frost of a bank recapitalisation exercise gone wrong. Given the weak hand at Mr Obama’s disposal, nobody should count on a successful roll-out.

With only $32bn (€24bn, £21bn) left of the $700bn in Troubled Asset Relief Pogramme (Tarp) funds – or possibly as much as $135bn depending on how you account for the Treasury’s commitments – Mr Obama will almost certainly lack the cash to recapitalise bank balance sheets. And Congress is in no mood to grant him any more.

There are three possible ways round this.

First, the stress tests could show that the banks will survive any further economic decline over the next few months. For this Panglossian approach to succeed, the administration would have to convince the markets that its tests were sufficiently stressful – a tall order should it produce a straight flush of 19 unlikely solvencies.

Second, the tests could reveal significant capital shortfalls. The Treasury would then give viable banks six months to raise the difference from the private markets. Goldman Sachs, probably the most robust of the group, has expressed confidence that it can do this. But the markets are volatile. To declare a shortfall that the Treasury cannot instantly plug may be to risk another meltdown, triggering a crisis of confidence in Mr Obama’s whole approach to the credit crunch.

Third, Mr Obama could take insolvent banks into receivership and wipe out the stakeholders – senior creditors included. This would be nationalisation by another name. But both Tim Geithner, the Treasury secretary, and the president have all but ruled out a step they consider politically almost as toxic as the assets they wish somebody would buy.

Mr Obama always has the option of saying he has changed his mind. The stress tests revealed a far worse picture than imagined, he might say, leaving a temporary takeover of the leading banks as the only viable option. Or he could spend some of his considerable political capital appealing to Congress to authorise more funds to recapitalise the banks.

Neither option is remotely attractive. But hoping that a rising economy will float the banks clear of the rocks would risk an even worse, and more expensive, shipwreck a few months down the line. It is an unenviable quandary so soon into his term of office.

Meanwhile, the mood music is getting steadily uglier. On Wednesday, fringe Republican groups entertained the country with a collection of “tea parties”, protesting at tax increases. The fact that Mr Obama is cutting taxes for the large majority of Americans, albeit by small amounts, did not damp their sense of outrage.

The fact, also, that this “grassroots” protest was heavily sponsored by Fox News, Rupert Murdoch’s “fair and balanced” channel (meaning that it was, in fact, an “Astroturf” rather than a “grassroots” event) should not remove its underlying message. Most Americans – Democrats included – detest bailing out Wall Street. Whose side is Mr Obama on, they wonder: the banks’ or the public’s?

In a private meeting Mr Obama recently warned senior bankers that he was the only thing standing between them and the “pitchforks”. As time goes on, he may be forced by politics, as much as economics, to conclude that nationalisation is the least of all evils.

But, but... first regulators are going to publish a paper explaining the stress tests on April 24.

TO BE NOTED: From Clusterstock:

"
Let's Just Cancel The Stress Tests

timgeithner-24march09-closeup_tbi.jpgIs there any good reason to follow through with the stress tests and actually release the results?

Word is, the White House plans to announce its finidings on May 4. But, but... first regulators are going to publish a paper explaining the stress tests on April 24. It's the latest evidence that the whole concept is becoming something of a fiasco for the administration, which is now going to great pains to maintain its credibiliy as a serious test for banks, while not spooking investors.

Of course, we've also been told that all 19 banks have passed. But also that some banks would need more shareholder-diluting capital once the results are released.

It doesn't help that all the banks apparently had blowout quarters, which if they're being totally honest should make you wonder why they need any extra capital at all.

At this point, we don't think anyone would begrudge the administration for doing an about face and admitting that they won't do much good. It's ok. People make mistakes.

Besides, the market can do a fine job distinguishing winners and losers on its own. As an alternative, just make all the banks raise, say, 5% of their market cap in the private sector. The ones that can do it are healthy. The ones that can't will get some extra help from TARP and voila. It'd be a lot more honest, and less political."

Amazingly, the biggest banks are defying the federal authorities on this point, insisting on signalling their soundness

TO BE NOTED: From The Baseline Scenario:

"Bring In The Antitrust Division (On Banking)

with 48 comments

In early February I suggested there was a showdown underway between the US Treasury and the country’s largest banks. Treasury (with the Fed and other regulators) is responsible for the safety and soundness of the financial system, the banks are mostly looking out for their own executives, and the tension between these goals is - by now - quite evident.

As we’ve been arguing since the beginning of the year, saving the banking system - at reasonable cost to the taxpayer - implies standing up to the bankers. You can do this in various ways, through recapitalization if you are willing to commit more taxpayer money or pre-packaged bankruptcy if you want to try it with less, but any sensible way forward involves Treasury being tough on the biggest banks.

The Administration seems to prefer ”forbearance”, meaning you just ignore the problem, hope the economy recovers anyway, and wait for time or global economic events to wash away banking insolvency concerns. But this strategy is increasingly being undermined by the banks themselves - their actions threaten financial system stability, will likely force even greater costs on the taxpayer, and demonstrate fundamentally anticompetitive practices that inflict massive financial damage on ordinary citizens.

As the NYT reported yesterday, the Federal Reserve - on behalf of all bank supervisers - recently requested banks in no uncertain terms (1) not to reveal stress test results, (2) not to give other indications of their financial health, and (3) most of all, not to announce capital raising plans immediately. The point, of course, is to manage the flow of information so that plans can be made to help the weaker banks at the same time that the market realizes exactly who needs what kind of help.

Amazingly, the biggest banks are defying the federal authorities on this point, insisting on signalling their soundness and - in the case of Goldman Sachs - rushing to raise capital. In the case of Goldman, the explicit intention is to pay back TARP funds and to escape all government-imposed limitations on compensation. This would obviously be good for Goldman and the people who run it. Anything that strengthens their advantage over competitors and increases market share will presumably raise their profits and compensation, making it easier to attract even more good people. (See my discussion with Terry Gross yesterday for more on these dynamics.)

Such developments would worsen the business prospects of other large banks and potentially threaten their financial situation. The government’s forbearance strategy is fragile unless big banks do as the supervisers tell them. But Goldman and other major players apparently think they have so much political power - and this may be more about connections on Capitol Hill than links with the Administration - that they can ignore the supervisers.

Treasury can try to refuse repayment of TARP funds, but Goldman would hardly have made its move unless repayment (particularly after announcing the intention) is essentially a done deal. Supervisers can send more assertive emails, but these are hardly likely to have any effect. The President himself can call on leading bankers to behave better, but didn’t he just do that (and isn’t that what Valerie Jarrett is working hard on)?

My practical friends in the Administration like to emphasize that “we are where we are” and that we need to understand the limitations of the policy tools in hand and the realities of our political constraints. I completely agree.

The Department of Justice’s Antitrust Division should be called in to investigate the increasing market share of major banks (remember that Bear Stearns and Lehman are gone), the anti-competitive practices of some market leaders (there’s more than one predatory way to force your rivals into bankruptcy and to move closer to monopoly power), and the broader increase in economic and political power of the biggest financial services players over the past 20 years and the last 6 months - this is potentially damaging to all consumers and, obviously, to all taxpayers.

Think of the costs arising from the market power of major banks - and it is financial market power that makes them “too big to fail”; the FDIC has no trouble handling the failure and liquidation of small banks. We started this crisis with privately held government debt at around 40% of GDP. My baseline view is that we will end up closer to 80% of GDP. This means higher taxes for all of us, and this is absolutely not a “left vs. center” or “left vs. right” issue. This is left, right, and center against those parts of the center who insist that we should go back to having the same organizations, essentially unchanged compensation schemes (and all they imply about “Wall Street owns the upside and taxpayers own the downside”), and even more concentrated market power in our financial system.

Probably we need to modernize our thinking about the exact nature of threats arising from financial trusts. Perhaps we need, at some point, new legislation that reflects this thinking. But we can make a great deal of progress, here and right now, with appropriate enforcement of our existing antitrust laws.

The pushback, of course, will be: you can’t do this in the middle of a recession - it will slow the recovery. Honestly, as my colleague Mike Mussa emphasized last week, banking is more likely to follow than lead the recovery; in fact, this is the exact logic that underpins the Administration’s forbearance strategy.

The goal of this antitrust action is to prevent some big banks from further destabilizing the system, hence reducing a serious downside risk. It’s also to limit the taxpayer costs arising from this crisis; for all major bank rescues, the cost is not just the bailout, it’s also the higher fiscal deficit, increased debt, taxes down the road and - given today’s predicament - the very real inflation risks arising from even more monetary expansion. The overarching goal, of course, is to (re)build a more sustainable, sound, and - in all senses - competitive financial system.

By Simon Johnson

Written by Simon Johnson

April 16, 2009 at 6:02 am"

announcement of the stress tests’ existence caused all manner of confusion and second-guessing in the markets, none of which was helpful

From Reuters:

"Stress tests under stress
Posted by: Felix Salmon
Tags: bailouts, regulation

David Wessel has an interesting idea today: while the bank stress tests were a good idea at the time they were announced, in February, a lot has changed since then, and none of it in a good way. Most obviously, the tests’ worst-case scenario is now looking more like a base-case scenario, making the tests less credible. What’s more, the very announcement of the stress tests’ existence caused all manner of confusion and second-guessing in the markets, none of which was helpful. And most profoundly, Congress passed executive-compensation rules which mean that no banks have any interest in accepting government funds should they be found to have insufficient capital.

For me, the fact that all these things managed to happen so quickly after the stress tests were announced is an indication that the stress tests probably weren’t such a good idea in February after all. But never mind that: as Wessel says, “Treasury has to deal with the world as it is, not as it hoped it would be”. And that means being extremely transparent about both the tests themselves and their results.

Near the beginning of the crisis, in the early months of 2008, it was still possible for Treasury to attempt a “trust us, we know what we’re doing” approach to bank regulation. That won’t fly any more. Treasury has to internalize the show-don’t-tell rule which is commonly hammered into journalists. Because no, we don’t trust them to know what they’re doing. Especially when the official org chart still looks like this."

Me:

In the unfolding of this crisis, we’ve reinvented the wheel so many times that we could start a tire store. Everything keeps returning to late September and early October. This change of optics with the “stress test” is a rerun of the change of optics with the “stigma problem”.

The stigma problem was originally solved by a plan to hide, shelter, if you will, the banks needing help from TARP, by forcing healthy banks to participate with the unhealthy banks. A kind of “What’s My Line ( Solvency )? show.

Then, when TARP looked to be a pretty good deal for banks, the stigma became attached to the banks that didn’t join, since, reasonably enough, only banks that couldn’t meet the criteria for joining TARP ( now a badge of honor )would not want some of this government largess.

The stigma problem also came up with the IMF’s CCL program.

In the case of the stigma problem, one could argue that the problem was caused by a change in the plan known as TARP. Maybe changing the name, then, would have been a wise move and averted confusion.

With CAP, the change in optics is even stranger. As I read CAP, the set of CAP participants was supposed to be a kind of badge of honor, since participation was to assure the various bank’s solvency, whatever their initial situation was. Case closed. Solvent banks, guaranteed by the US Government.

In my mind, CAP was very easy to understand. If anything, there was less than met the eye. It was mainly a heuristic document. Pure peshat. Somehow, maybe because of the name “stress test”, people seemed to believe that the insolvent banks were going to be named, and a scarlet “I” added to their name (s). Now, this seems to go against the reasoning of CAP. When this new reading became the main reading, the banks that were solvent started trying to demonstrate that, if there was a problem, it didn’t rest on them. Again, this seems to violate the spirit of CAP.

In this case, there was no change of plan by the government. Instead, their plan was changed by popular perception.

There is one big problem for the taxpayer though, and that is that we are shareholders in some of these banks. If we tell investors that they are hurting, won’t that make it harder for these banks to sell assets, thereby hurting our investment? What exactly are our interests in this matter?

- Posted by Don the libertarian Democrat

Monday, April 13, 2009

Treasury needs to be much clearer than it has been about exactly when and how the results of these stress tests are going to be made public

From Reuters:

"The secret stress tests
Posted by: Felix Salmon
Tags: banking, regulation

If a bank passes a meaningless stress test and nobody hears about it, will the Treasury market rally? Or will there just be lots more volatility in bank share prices?

Answers on the back of a postcard please to T. Geithner, 1500 Pennsylvania Avenue, Washington DC, along with any other unintended consequences of the current making-it-up-as-we-go-along approach to bank regulation.

At the very least, Treasury needs to be much clearer than it has been about exactly when and how the results of these stress tests are going to be made public. And when in doubt, it should release more information more quickly, rather than going the standard Washington route of keeping stuff secret. Because these results are so important, and known to so many people, that they will leak if they’re not released soon."

Me:

I think that people need to start defining their terms. Are the Stress Tests part of CAP? If they are, then:

“Will applications filed by QFIs or the names of applying QFIs be released publicly?
No. Treasury will not release the names of QFIs who apply for the CAP or those which
are not approved. Treasury will publish electronic reports detailing any completed
transactions, including the name of the QFI and the amount of the investment, as required
by the Emergency Economic Stabilization Act of 2008, within 48 hours of the
investment.”

And:

“What if a QFI needs capital in excess of the investment limit referred to above?
An institution that needs capital in excess of the investment limit referred to above is
deemed as needing “exceptional assistance.” In consultation with the appropriate Federal
banking agency, Treasury will determine whether an institution qualifies for “exceptional
assistance” on a case-by-case basis.
What will be the terms of transactions involving QFIs in need of exceptional
assistance?
QFIs falling under the “exceptional assistance” standard may have bank-specific
negotiated agreements with the Treasury Department.”

I’m assuming that the “negotiated agreements” will be a submitted plan by a bank, that the Treasury deems workable and worthy of being funded. For instance, in the case of Citi, it would be a plan detailing which assets it plans to sell, expected prices, a timetable, etc. Since we’re shareholders, we should expect the same thing. If need be, the Treasury can demand changes or terms deemed necessary.

Once again, isn’t it an attempt to prop up the prices of these assets, since the current possible buyers are bidding very low, and are dubious of dealing with Citi? It wouldn’t really help to make the explicit agreement public, assuming that you’re negotiating to sell assets.

Quite frankly, for me, the real question is whether or not Citi has a plausible plan to get itself back on course. If it doesn’t, we need to change management or consider other strategies. If it does, we need to make sure that the taxpayers get a bountiful part of the upside when Citi is back on course. Isn’t that the bottom line question?

- Posted by Don the libertarian Democrat

Thursday, April 9, 2009

So, clearly, the whole point of the CAP is to avoid having any of the 19 largest U.S. financial institutions fail in the near-to-medium term.

TO BE NOTED: From The Economics Of Contempt:

"The Purpose of the CAP

Matt Yglesias badly misunderstands the purpose of the Treasury's Capital Assistance Program (CAP):
I thought the point of the [stress] tests was to open up the possibility that a minority of banks would be shut-down, while the others would be proclaimed healthy (as in actually healthy rather than "healthy given a government guarantee") and we could shift out of the implicit guarantee phase.
You thought wrong. That is not, and has never been, the purpose of the CAP. In fact, that's the exact opposite of the stated purpose of the CAP:
The purpose of the CAP is to restore confidence throughout the financial system that the nation's largest banking institutions have a sufficient capital cushion against larger than expected future losses, should they occur due to a more severe economic environment, and to support lending to creditworthy borrowers.

Under CAP, federal banking supervisors will conduct forward-looking assessments to evaluate the capital needs of the major U.S. banking institutions under a more challenging economic environment. Should that assessment indicate that an additional capital buffer is warranted, banks will have an opportunity to turn first to private sources of capital. In light of the current challenging market environment, the Treasury is making government capital available immediately through the CAP to eligible banking institutions to provide this buffer.
So, clearly, the whole point of the CAP is to avoid having any of the 19 largest U.S. financial institutions fail in the near-to-medium term. How does "avoiding the shut-down of major U.S. banks" become "open[ing] up the possibility that a minority of banks [will] be shut-down"?

Saturday, April 4, 2009

It's almost as if Feldstein hasn't been paying attention. Very odd.

TO BE NOTED: From The Economics Of Contempt:

"Martin Feldstein on the Geithner Plan

Martin Feldstein is generally supportive of the Geithner plan, but he says it needs to be expanded in three ways to ultimately succeed. The odd thing is, the Treasury has already announced two of his three proposed expansions.

Feldstein writes:
First, the Treasury must be prepared to inject capital into the banks that agree to sell mortgages. Without additional capital, the banks may not be willing to sell the mortgages that are causing their lack of confidence.
Umm, providing the banks with additional capital is exactly what the Treasury's Capital Assistance Program (CAP) is for:
Should [the bank stress test] indicate that an additional capital buffer is warranted, banks will have an opportunity to turn first to private sources of capital. In light of the current challenging market environment, the Treasury is making government capital available immediately through the CAP to eligible banking institutions to provide this buffer.
Feldstein continues:
Second, cleansing the banks' balance sheets will also require much more Treasury money for equity investments and loans. The current plan to remove $500 billion of impaired assets will not be enough to cleanse the banks' balance sheets to a point where they can be confident enough about the remaining assets to resume lending.
The Treasury has already stated that the PPIP "will generate $500 billion in purchasing power to buy legacy assets – with the potential to expand to $1 trillion over time."

It's almost as if Feldstein hasn't been paying attention. Very odd."