Now Is Not The Time to Reduce Investment in Risk Management

As we head into the second half of 2011, the economic recovery here in the US and abroad is taking hold much more slowly than most expected. Given the modest recovery, some executives may be looking to slash expenses to boost profitability and achieve their near-term goals. However, while tempting, cutting staff and investment in the wrong areas may prove to be a company’s undoing. For financial services companies, this is particularly true in the area of risk management because they are still mending their practices in the wake of the recent financial crisis.

According to the Financial Times, US regulators are keenly aware of what may be on the minds of bank executives and are issuing warnings to avoid cutting risk management budgets. According to Michael Alix, a senior vice-president at the Federal Reserve Bank of New York who heads the risk-management function within the regulator’s financial-institutions supervision group, the regulators are paying close attention to any plans to lower investment in risk management programs. “We haven’t seen it yet, but we’re vigilant,” says Alix.

Sacrificing the progress made in strengthening risk management programs at this precarious stage of recovery is certainly short-sighted and could lead to even greater problems for companies looking to weather the next storm.

FDIC Calls for Risk Management Improvements

This week, the Federal Deposit Insurance Corporation (”FDIC”) released a special edition of its Supervisory Insights publication focusing on the recent foreclosure crisis in mortgage banking. In the report, the FDIC provides additional perspective on the deficiencies in internal processes, staffing and control that resulted in a foreclosure moratorium by several of the largest mortgage servicing institutions in late 2010. The FDIC worked with the lead regulatory agencies of the fourteen largest mortgage servicers in the United States to conduct extensive reviews of current foreclosure practices.

The reviews uncovered many common issues among the mortgage servicers. The FDIC noted the following, “concerns included lax foreclosure documentation, ineffective controls over foreclosure procedures, and deficient loss mitigation procedures and controls. Many institutions failed to commit resources sufficient to manage responsibly the rapidly growing volume of mortgage loans in default or at risk of default. Weak governance and controls increased legal, reputational, operational, and financial risks while creating unnecessary confusion for borrowers.”

While the report focuses specifically on the foreclosure shortcomings, it can also serve as a reminder of the value of strong internal controls and risk management practices. As our business processes grow to be more complex and interconnected, the risks inherent in the processes grow exponentially. Unchecked, these risks can quickly propel a business into a full-blown crisis.

U.S. Senate Releases Financial Crisis Report

Yesterday, the United States Senate Subcommittee on Investigations released its report covering the events leading to the financial crisis of 2008. The Subcommittee began its investigation in November 2008 and held several high-profile hearings in April 2010.  The lengthy report includes an analysis into all of the major players involved in the crisis – Mortgage Lenders, Investment Banks, Regulators and Credit Rating Agencies. What is notable about the report is the fact that it received full, bipartisan support unlike the report issued recently by the Financial Crisis Inquiry Commission. In addition, the report is clear and specific in its recommendations.  As noted in the following excerpt, the focus of the report is to prevent a repeat occurrence of a painful shock that could have been averted.

Nearly three years later, the U.S. economy has yet to recover from the damage caused by the 2008 financial crisis.  This Report is intended to help analysts, market participants, policymakers, and the public gain a deeper understanding of the origins of the crisis and take the steps needed to prevent excessive risk taking and conflicts of interest from causing similar damage in the future.

Too Little, Too Late?

At long last, the Financial Crisis Inquiry Commission released its final report today on the causes of the great financial crisis of 2008. Unfortunately, the report probably raises more questions than answers due to the fact that the commission was split on the true cause of the crisis. The Democrat majority provided their view that the crisis was ultimately caused by greedy Wall Street bankers coupled with a lax regulatory system. On the other hand, the Republican minority of three panel members portrayed the following more complicated series of causes in their dissenting view.

  1. Credit bubble. Starting in the late 1990s, China, other large developing countries, and the big oil-producing nations built up large capital surpluses. They loaned these savings to the United States and Europe, causing interest rates to fall. Credit spreads narrowed, meaning that the cost of borrowing to finance risky investments declined. A credit bubble formed in the United States and Europe, the most notable manifestation of which was increased investment in high-risk mortgages. U.S. monetary policy may have contributed to the credit bubble but did not cause it.
  2. Housing bubble. Beginning in the late 1990s and accelerating in the 2000s, there was a large and sustained housing bubble in the United States. The bubble was characterized both by national increases in house prices well above the historical trend and by rapid regional boom-and-bust cycles in California, Nevada, Arizona, and Florida. Many factors contributed to the housing bubble, the bursting of which created enormous losses for homeowners and investors.
  3. Nontraditional mortgages. Tightening credit spreads, overly optimistic assumptions about U.S. housing prices, and flaws in primary and secondary mortgage markets led to poor origination practices and combined to increase the flow of credit to U.S. housing finance. Fueled by cheap credit, firms like Countrywide, Washington Mutual, Ameriquest, and HSBC Finance originated vast numbers of high-risk, nontraditional mortgages that were in some cases deceptive, in many cases confusing, and often beyond borrowers’ ability to repay. At the same time, many homebuyers and homeowners did not live up to their responsibilities to understand the terms of their mortgages and to make prudent financial decisions. These factors further amplified the housing bubble.
  4. Credit ratings and securitization. Failures in credit rating and securitization transformed bad mortgages into toxic financial assets. Securitizers lowered the credit quality of the mortgages they securitized. Credit rating agencies erroneously rated mortgage-backed securities and their derivatives as safe investments. Buyers failed to look behind the credit ratings and do their own due diligence. These factors fueled the creation of more bad mortgages.
  5. Financial institutions concentrated correlated risk. Managers of many large and midsize financial institutions in the United States amassed enormous concentrations of highly correlated housing risk. Some did this knowingly by betting on rising housing  prices, while others paid insufficient attention to the potential risk of carrying large amounts of housing risk on their balance sheets. This enabled large but seemingly manageable mortgage losses to precipitate the collapse of large financial institutions.
  6. Leverage and liquidity risk. Managers of these financial firms amplified this concentrated housing risk by holding too little capital relative to the risks they were carrying on their balance sheets. Many placed their firms on a hair trigger by relying heavily on short-term financing in repo and commercial paper markets for their day-to-day liquidity. They placed solvency bets (sometimes unknowingly) that their housing investments were solid, and liquidity bets that overnight money would always be available. Both turned out to be bad bets. In several cases, failed solvency bets triggered liquidity crises, causing some of the largest financial firms to fail or nearly fail. Firms were insufficiently transparent about their housing risk, creating uncertainty in markets that made it difficult for some to access additional capital and liquidity when needed.
  7. Risk of contagion. The risk of contagion was an essential cause of the crisis. In some cases, the financial system was vulnerable because policymakers were afraid of a large firm’s sudden and disorderly failure triggering balance sheet losses in its counterparties. These institutions were deemed too big and interconnected to other firms through counterparty credit risk for policymakers to be willing to allow them to fail suddenly.
  8. Common shock. In other cases, unrelated financial institutions failed because of a common shock: they made similar failed bets on housing. Unconnected financial firms failed for the same reason and at roughly the same time because they had the same problem: large housing losses. This common shock meant that the problem was broader than a single failed bank–key large financial institutions were undercapitalized because of this common shock.
  9. Financial shock and panic. In quick succession in September 2008, the failures, near-failures, and restructurings of ten firms triggered a global financial panic. Confidence and trust in the financial system began to evaporate as the health of almost every large and midsize financial institution in the United States and Europe was questioned.
  10. Financial crisis causes economic crisis. The financial shock and panic caused a severe contraction in the real economy. The shock and panic ended in early 2009. Harm to the real economy continues through today.

In total, the report and dissenting viewpoints provide a great analysis of the risk event. However, both fail to provide a forward-looking view on how such a crisis can be avoided in the future. In addition, the results of their analysis have emerged months after the U.S. Congress finalized the Dodd-Frank Financial Reform Act of 2010. Unfortunately, this is too often the case when it comes to risk management exercises. Most people will spend an inordinate amount of time debating past events rather than determining strategies to prevent emerging risk events.

Assessing Systemic Risk

New York University’s Stern School of Business hosted a conference yesterday to discuss how systemic risk should be addressed under the Dodd-Frank Act.  One of the presenters at the conference, Stanford Finance Professor Darrell Duffie, proposed a new approach for identifying systemic risk.  Here’s some detail on his proposal as reported by Bloomberg.

The world’s largest banks and investment firms should undergo quarterly stress tests to identify risks that could sink the financial system, according to a proposal by Stanford University finance professor Darrell Duffie. “I’m not talking about the ordinary, matter-of-course, risk management of institutions. We’re looking at what are the sources of risk and how are they flowing through the system. We want to connect the dots.”

Duffie calls his plan “10-by-10-by-10” because it’s based on 10 financial firms undergoing 10 stress tests that expose the banks’ 10 largest trading partners. For example, institutions would be tested on their ability to withstand the default of a single firm that they do business with, an idea replicating the 2008 Lehman bankruptcy.

“The objective is to alert regulators and the public to potential sources of financial instability before they reach dangerous levels,” Duffie wrote in a paper outlining the proposal. The tests, which would be adjusted over time to cover different scenarios, could flush out new systemically important firms as they arise, Duffie said. Central bankers could opt to conduct some of the stress tests using average financial numbers over a given timeframe “to mitigate period-end ‘window dressing,’” Duffie said. Regulators should also audit the way the banks measure the data they present, he said.

More specifics about the Duffie proposal are contained in his working paper, “Systemic Risk Exposures: A 10-by-10-by-10 Approach.” By his own admission, Duffie notes that this proposal merely represents a first step for regulators to begin to analyze systemic risk. There are shortcomings to the proposal such as the current lack of data as well as the potential to exclude other entities that may pose risks to the system. However, the regulators must begin somewhere and this approach is a practical method for assessing systemic risk.

Is This Just the Tip of the Iceberg?

The Congressional Oversight Panel released its November report today and it focused on the continued foreclosure crisis. The panel is calling for additional investigation by regulators and is also requesting that the U.S. Treasury provide additional evidence of their claim that the crisis has been averted.  Below is an excerpt from their report as well as video commentary from the chairman of the panel, Senator Ted Kaufman.

At this point the ultimate implications remain unclear. It is possible, however, that “robo-signing” may have concealed much deeper problems in the mortgage market that could potentially threaten financial stability and undermine the government‟s efforts to mitigate the foreclosure crisis. Although it is not yet possible to determine whether such threats will materialize, the Panel urges Treasury and bank regulators to take immediate steps to understand and prepare for the potential risks.

In the best-case scenario, concerns about mortgage documentation irregularities may prove overblown. In this view, which has been embraced by the financial industry, a handful of employees failed to follow procedures in signing foreclosure-related affidavits, but the facts underlying the affidavits are demonstrably accurate. Foreclosures could proceed as soon as the invalid affidavits are replaced with properly executed paperwork.

The worst-case scenario is considerably grimmer. In this view, which has been articulated by academics and homeowner advocates, the “robo-signing” of affidavits served to cover up the fact that loan servicers cannot demonstrate the facts required to conduct a lawful foreclosure. In essence, banks may be unable to prove that they own the mortgage loans they claim to own.

Only time will tell whether the foreclosure issues are merely the tip of the iceberg.  However, if the issues are real, then the financial institutions and other involved parties will be best served to proactively address the problem now rather than hoping it goes away on its own.

Navigating Risk: From Crisis to Innovation

A big challenge for many companies today emerging from the financial crisis is retaining their ability to innovate new products and services. The typical view is that the larger the company, the harder it is to innovate. Why is that? It seems counterintuitive given the vast resources of larger companies compared to their smaller competitors. This issue was recently highlighted in an article on Here are the views of a few who have examined the issue in greater detail.

Can companies grow and continue to be creative and innovative? Or will smaller operations always have a monopoly in the new-ideas department? “I don’t think there’s any reason why you can’t be as big as Goliath and as nimble as David,” said Jim Andrew, a senior partner at the Boston Consulting Group, which publishes a yearly list of the world’s top innovative companies in conjunction with Bloomberg Businessweek. This year, Apple, Google, Microsoft and IBM led the list. Facebook and Twitter were nowhere to be found.

“Big companies have a tremendous number of advantages that should allow them to actually be, I would argue, more innovative than a given smaller company,” Andrew said.  The tech giants tend to have a wide range of products or services to offer — meaning they can take bets on new ideas without risking their entire business, Andrew said. Start-ups, in contrast, tend to base their future on a single product or concept. They bet big, but most of them “end up dying,” said Karim Lakhani, an assistant professor at Harvard Business School. “They go out there, they try different things and then there’s a large, large failure rate,” he said.

Both Lakhani and Andrew said it’s easy for big companies to get too comfortable and forgo the risks that are necessary for innovation to occur. “As companies get bigger that latitude [for employees to be creative] often unfortunately gets taken over by more rigid management structures and more rigid philosophies,” Lakhani said.

For those interested in exploring this dilemma further, mark your calendars for an upcoming workshop that will help you navigate the risks associated with innovation.  On January 11 & 12, Wheelhouse Advisors will conduct an executive workshop entitled Navigating Risk: From Crisis to Innovation. The workshop will be held at the highly renowned Old Edwards Inn & Spa in beautiful Highlands, NC.  For more information, email or call 404-805-9203.