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The Credit Crisis
    and beyond:
     Lessons from the Financial Crisis
       & Sound Practice Principles

Markus Krebsz
7 March 2013, London
European & International Financial Institutions lecture
1) Lessons from the Financial Crisis

Lesson 1:               Data, Disclosure and Standardization
Lesson 2:               Due diligence
Lesson 3:               Deal motives
Lesson 4:               Arbitrage
Lesson 5:               Rating shopping & Over-reliance on ratings
Lesson 6:               Models, Assumptions & Black boxes
Lesson 7:               Proprietary analysis & Risk management
Lesson 8:               Senior management awareness
Lesson 9:               Lack of drill-down capability
Lesson 10:              Mark-to-market, Mark-to-model & Illiquidity
 ________________________________________________________________________________________________________________________


Source:                 “Securitization & Structured Finance
                        post Credit Crunch” – Part I
                                                                                                                            2
3
Lesson 1:
Data, Disclosure +
Standardization

                     4
Data, Disclosure & Standardization
• Banks’ due diligence vs. outsourced analysis (CRA)
• Historical information  Future performance: NO!!!
• Model = Always model, NOT true reflection of reality
• Paper reports  issues & problems
• Electronic reports  depends on file format really
• Data feeds & APIs
• Definitions  Product taxonomy
• Non-comparability of ratings across CRAs
• Lack of clear reporting or underwriting standards      5
Lesson 2:
Due diligence?


                 6
Due diligence
• Activities investors should undertake prior to
  purchasing new or secondary market bond issuance

• CRAs don’t do “due diligence” but only “servicer
  reviews” – investors don’t always know this

• Thorny issues & digging deeper: not really
• CRAs are always conflicted in their opinion given
  that they are paid by the bond issuer for the rating!

• Issuer pays model (since 1970)

                                                          7
Lesson 3:
Deal motives


               8
Deal motives
• Investors need to ask more questions such as:
      “What is in it for us?” (i.e. the investors)

            AND

      “What is in it for THEM?” (i.e. the issuers)

• Plausible explanation for a particular deal?
• Why has the deal been structured?
• Capital structure of the transaction?


                                                     9
Lesson 4:
Arbitrage


            10
Arbitrage
• Financial motivation, such are arbitrage
• Aim is to leverage an actual or perceived advantage
• Regulatory arbitrage: applying different rules for
  calculating capital charges under BII regime

• Informational arbitrage: different levels of insights
  or information on underlying assets

• Technological arbitrage: more sophisticated
  models with perceived or real analytical edge

• Financial arbitrage: Cash flow advantage, excess
                                                          11
5:
Using
CRAs’
analysis
sensibly
            12
Rating shopping and Over-reliance on Ratings
• Rating by one CRA missing?
   It’s worth digging deeper!

• Reasons: cheaper credit enhancement (C/E)
   Indicating rating shopping!

• Happened often in the run up to the Credit Crisis
• If you are an investor, simply ASK the CRA
• Credit ratings have been key investment criteria
• Outsourcing analysis possible, BUT:
  outsourcing losses is not
                                                      13
Timely rating actions and Deferral

Timeliness of Rating changes Bond maturity profile
 • Process stages to reach                                          • Legal final vs. expected
       rating decisions                                                   maturity
 •     Detection of bond- vs.                                       •     Life-time ratings (40+ years)
       asset class-specific                                         •     Timely payment of interest &
       and/or systemic issues                                             ultimate payment of principal


 31 July 07      20 Aug 07      31 Aug 07       9 Oct 07       16 Oct 07           25 Oct 07
 Cut-off date   CRA analyst   Proposal: RWN    CRA Analyst    Proposal: DG   Indiv. or Asset-class?
                                                                                                       Bulk rating
                                                                                                       actions &
      Report format & frequency, Analyst’s experience, Models, Quorum ...
                                                                                                        Criteria
     15 Aug 07          27 Aug 07        25 Sept 07       12 Oct 07         23 Oct 07     You get
     Distribution
                     st
                    1 Analysis result    st
                                        1 Committee    nd
                                                      2 Analysis result    nd
                                                                          2 Committee    the idea...    Changes


                                                                                                                     14
Constructive Criticism
• Business model: Too slow to react
• Assumptions, methodologies & models
• Conflict of interest (‘issuer-pays’ model)
• Limited capture
• Split ratings
• Notching of competitor’s ratings
• Implied ratings & internal competition
• “Getting it wrong”, “Fat fingers”
• etc.                                         15
Failures of CRAs
   AIG, Bear Stearns, Bradford & Bingley, Enron, Icelandic
   banks, Lehman Bros., Monolines, Northern Rock, Parmalat,
   Sovereigns (Eurozone), Sub-prime bonds etc.

In their own words...
Fitch: “… did not foresee the magnitude of the decline…or
   the dramatic shift in borrower behavior…”
Moody’s: “…We did not . . . anticipate the magnitude and
   speed of the deterioration in mortgage quality or the
   suddenness of the transition to restrictive lending...”
S&P: “…It is now clear that a number of assumptions used
   in preparing ratings on mortgage-backed securities issued
   between 2005 and mid-2007 did not work…”
Source: US Government Oversight and Reform Committee, Oct 2008
                                                                 16
Sensible use of CRAs’ analysis
• Fully understand the instrument you are investing in –
  particularly when using other peoples’ monies

• Understand ratings’ limitations and
  know how to mitigate rating-related risks (previous slide)

• ‘Ignore’ ratings designators (i.e. AAA etc.) and
   focus on CRAs’ analytical narrative instead

• Look out for what is NOT there in the narrative but should
    e.g. Why are obvious issues missing in the analysis?
         Why has this bond not been rated by all three CRAs?

• Apply common sense and trust your gut feeling                17
Lesson 6:
Captured Risks


                 18
Models, Assumptions & Black Boxes
• Extensive use of financial models to do “analysis”
• Fairly simple to highly complex quantitative models
• A “model” is ALWAYS only a “model”!
• Models CANNOT simulate reality!
• Model failures exacerbated by using inadequate
  assumptions, i.e. through the cycle – 10-12 years only

• Historic data points as input into model: limited data?
• Black box: locked-down back-end with no access for
  users, i.e. not easy and often impossible to reconcile
                                                            19
Lesson 7:
Proprietary
analysis

              20
Proprietary analysis & Risk management
• Often overlooked: Good old-fashioned analysis
• Done by dedicated teams of credit analysts
• Analysis, loads of analysis
• Gut feeling & Common sense (which is not so common)
• Lack of qualified risk management practices
• Firm’s strategy  Risk appetite  Risk policy 
  Investment guidelines etc.

• Robust risk management function needs to be
  empowered by the firm to say “NO!” sometimes
                                                    21
Lesson 8:
Senior management

awareness




                    22
Senior management awareness
• Management reporting – or lack of it
• Limited systems capabilities
• Filtering of reports through distribution channels up the
  chain

• Does the information at board level paint a full picture?
• Senior mgmt. ignorance or misinterpretation of data
• Senior mgmt. does not understand


                                                          23
Lesson 9:
Lack of Drill-down +
Group-wide Controls

                       24
Lack of drill-down capability & Group-wide controls
 • US subprime replaced with investments in CDO of ABS
 • Minor issue becomes major disaster
 • “Repackaged” garbage is still garbage!
 • One desk sells and the other buys, largely ignoring firm-
   wide strategy




                                                          25
Lesson 10:
Mark-to-Market,
Market-to-model
+ Illiquidity
                  26
Mark-to-market, Mark-to-model & Illiquidity
“Normal times”: Mark-to-market

• Electronic trading matching bid/offers or
• Collection of broker quotes by phone
“Periods of limited market stress”: Mark-to-model

• If there is no “normal” market  market-to-model
• Based on pricing models which are based on “normal”
  markets

“Periods of prolonged illiquidity”:

• Difficult to price if there is no market at all! Force sale?   27
2) Sound practice principles
DATA
Principle   1:   Access: Open source
Principle   2:   Information asymmetries
Principle   3:   Data formats
Principle   4:   Data delivery
Principle   5:   On deal level
Principle   6:   For the market at large
Principle   7:   Industry data portals

DEFINITIONS
Principle 8: Simplifications
Principle 9: Transparency
Principle 10: Standardisation
                                           28
STANDARDS
 Principle 11:   Underwriting standards
 Principle 12:   Reporting standards
 Principle 13:   Representations & warranties

INVESTOR FOCUSED
Principle 14: Government facilities
Principle 15: Private investors
Principle 16: Incentive alignments

MOTIVATION & DEAL DRIVERS
Principle 17: Arbitrage
Principle 18: Rating shopping
Principle 19: Risk transfer & “Skin in the game”
                                                   29
ANALYSIS
 Principle 20:   Reduced over-reliance on credit ratings
 Principle 21:   Increased proprietary analysis
 Principle 22:   Models, assumptions and common sense
 Principle 23:   Risk management & Risk mitigation

References & Appendix
“Securitization & Structure Finance post Credit Crunch –
 A Best Practice Deal Lifecycle Guide”, M. Krebsz (Wiley 2011)

Please see Part I of the book attached for your kind reference:




                                                                  30

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The Credit Crisis and beyond: Lessons from the Financial Crisis & Sound Practice Principles

  • 1. The Credit Crisis and beyond: Lessons from the Financial Crisis & Sound Practice Principles Markus Krebsz 7 March 2013, London European & International Financial Institutions lecture
  • 2. 1) Lessons from the Financial Crisis Lesson 1: Data, Disclosure and Standardization Lesson 2: Due diligence Lesson 3: Deal motives Lesson 4: Arbitrage Lesson 5: Rating shopping & Over-reliance on ratings Lesson 6: Models, Assumptions & Black boxes Lesson 7: Proprietary analysis & Risk management Lesson 8: Senior management awareness Lesson 9: Lack of drill-down capability Lesson 10: Mark-to-market, Mark-to-model & Illiquidity ________________________________________________________________________________________________________________________ Source: “Securitization & Structured Finance post Credit Crunch” – Part I 2
  • 3. 3
  • 4. Lesson 1: Data, Disclosure + Standardization 4
  • 5. Data, Disclosure & Standardization • Banks’ due diligence vs. outsourced analysis (CRA) • Historical information  Future performance: NO!!! • Model = Always model, NOT true reflection of reality • Paper reports  issues & problems • Electronic reports  depends on file format really • Data feeds & APIs • Definitions  Product taxonomy • Non-comparability of ratings across CRAs • Lack of clear reporting or underwriting standards 5
  • 7. Due diligence • Activities investors should undertake prior to purchasing new or secondary market bond issuance • CRAs don’t do “due diligence” but only “servicer reviews” – investors don’t always know this • Thorny issues & digging deeper: not really • CRAs are always conflicted in their opinion given that they are paid by the bond issuer for the rating! • Issuer pays model (since 1970) 7
  • 9. Deal motives • Investors need to ask more questions such as: “What is in it for us?” (i.e. the investors) AND “What is in it for THEM?” (i.e. the issuers) • Plausible explanation for a particular deal? • Why has the deal been structured? • Capital structure of the transaction? 9
  • 11. Arbitrage • Financial motivation, such are arbitrage • Aim is to leverage an actual or perceived advantage • Regulatory arbitrage: applying different rules for calculating capital charges under BII regime • Informational arbitrage: different levels of insights or information on underlying assets • Technological arbitrage: more sophisticated models with perceived or real analytical edge • Financial arbitrage: Cash flow advantage, excess 11
  • 13. Rating shopping and Over-reliance on Ratings • Rating by one CRA missing?  It’s worth digging deeper! • Reasons: cheaper credit enhancement (C/E)  Indicating rating shopping! • Happened often in the run up to the Credit Crisis • If you are an investor, simply ASK the CRA • Credit ratings have been key investment criteria • Outsourcing analysis possible, BUT: outsourcing losses is not 13
  • 14. Timely rating actions and Deferral Timeliness of Rating changes Bond maturity profile • Process stages to reach • Legal final vs. expected rating decisions maturity • Detection of bond- vs. • Life-time ratings (40+ years) asset class-specific • Timely payment of interest & and/or systemic issues ultimate payment of principal 31 July 07 20 Aug 07 31 Aug 07 9 Oct 07 16 Oct 07 25 Oct 07 Cut-off date CRA analyst Proposal: RWN CRA Analyst Proposal: DG Indiv. or Asset-class? Bulk rating actions & Report format & frequency, Analyst’s experience, Models, Quorum ... Criteria 15 Aug 07 27 Aug 07 25 Sept 07 12 Oct 07 23 Oct 07 You get Distribution st 1 Analysis result st 1 Committee nd 2 Analysis result nd 2 Committee the idea... Changes 14
  • 15. Constructive Criticism • Business model: Too slow to react • Assumptions, methodologies & models • Conflict of interest (‘issuer-pays’ model) • Limited capture • Split ratings • Notching of competitor’s ratings • Implied ratings & internal competition • “Getting it wrong”, “Fat fingers” • etc. 15
  • 16. Failures of CRAs AIG, Bear Stearns, Bradford & Bingley, Enron, Icelandic banks, Lehman Bros., Monolines, Northern Rock, Parmalat, Sovereigns (Eurozone), Sub-prime bonds etc. In their own words... Fitch: “… did not foresee the magnitude of the decline…or the dramatic shift in borrower behavior…” Moody’s: “…We did not . . . anticipate the magnitude and speed of the deterioration in mortgage quality or the suddenness of the transition to restrictive lending...” S&P: “…It is now clear that a number of assumptions used in preparing ratings on mortgage-backed securities issued between 2005 and mid-2007 did not work…” Source: US Government Oversight and Reform Committee, Oct 2008 16
  • 17. Sensible use of CRAs’ analysis • Fully understand the instrument you are investing in – particularly when using other peoples’ monies • Understand ratings’ limitations and know how to mitigate rating-related risks (previous slide) • ‘Ignore’ ratings designators (i.e. AAA etc.) and focus on CRAs’ analytical narrative instead • Look out for what is NOT there in the narrative but should e.g. Why are obvious issues missing in the analysis? Why has this bond not been rated by all three CRAs? • Apply common sense and trust your gut feeling 17
  • 19. Models, Assumptions & Black Boxes • Extensive use of financial models to do “analysis” • Fairly simple to highly complex quantitative models • A “model” is ALWAYS only a “model”! • Models CANNOT simulate reality! • Model failures exacerbated by using inadequate assumptions, i.e. through the cycle – 10-12 years only • Historic data points as input into model: limited data? • Black box: locked-down back-end with no access for users, i.e. not easy and often impossible to reconcile 19
  • 21. Proprietary analysis & Risk management • Often overlooked: Good old-fashioned analysis • Done by dedicated teams of credit analysts • Analysis, loads of analysis • Gut feeling & Common sense (which is not so common) • Lack of qualified risk management practices • Firm’s strategy  Risk appetite  Risk policy  Investment guidelines etc. • Robust risk management function needs to be empowered by the firm to say “NO!” sometimes 21
  • 23. Senior management awareness • Management reporting – or lack of it • Limited systems capabilities • Filtering of reports through distribution channels up the chain • Does the information at board level paint a full picture? • Senior mgmt. ignorance or misinterpretation of data • Senior mgmt. does not understand 23
  • 24. Lesson 9: Lack of Drill-down + Group-wide Controls 24
  • 25. Lack of drill-down capability & Group-wide controls • US subprime replaced with investments in CDO of ABS • Minor issue becomes major disaster • “Repackaged” garbage is still garbage! • One desk sells and the other buys, largely ignoring firm- wide strategy 25
  • 27. Mark-to-market, Mark-to-model & Illiquidity “Normal times”: Mark-to-market • Electronic trading matching bid/offers or • Collection of broker quotes by phone “Periods of limited market stress”: Mark-to-model • If there is no “normal” market  market-to-model • Based on pricing models which are based on “normal” markets “Periods of prolonged illiquidity”: • Difficult to price if there is no market at all! Force sale? 27
  • 28. 2) Sound practice principles DATA Principle 1: Access: Open source Principle 2: Information asymmetries Principle 3: Data formats Principle 4: Data delivery Principle 5: On deal level Principle 6: For the market at large Principle 7: Industry data portals DEFINITIONS Principle 8: Simplifications Principle 9: Transparency Principle 10: Standardisation 28
  • 29. STANDARDS Principle 11: Underwriting standards Principle 12: Reporting standards Principle 13: Representations & warranties INVESTOR FOCUSED Principle 14: Government facilities Principle 15: Private investors Principle 16: Incentive alignments MOTIVATION & DEAL DRIVERS Principle 17: Arbitrage Principle 18: Rating shopping Principle 19: Risk transfer & “Skin in the game” 29
  • 30. ANALYSIS Principle 20: Reduced over-reliance on credit ratings Principle 21: Increased proprietary analysis Principle 22: Models, assumptions and common sense Principle 23: Risk management & Risk mitigation References & Appendix “Securitization & Structure Finance post Credit Crunch – A Best Practice Deal Lifecycle Guide”, M. Krebsz (Wiley 2011) Please see Part I of the book attached for your kind reference: 30