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	<title>Comments on: Not all that sophisticated</title>
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	<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/</link>
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	<pubDate>Fri, 21 Nov 2008 11:57:08 +0000</pubDate>
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		<title>By: JB</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107087</link>
		<dc:creator>JB</dc:creator>
		<pubDate>Tue, 29 Apr 2008 00:57:21 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107087</guid>
		<description>I've got some issues with this commentary.  Triple A rated tranches in CDO's are not as risky an investment as the lower tranches.  While I will agree that the risk element was seriously underestimated by the rating agencies.  I'm not going to join the banter that Wall Street has zero brains and anyone could have seen this crisis coming.  If all of you fellas had seen it, why are you chatting away on an economics discussion forum rather than enjoying your new yacht on the islands.  Some elements, were visible, and should have been anticipated by the banks.  But, not all of it was visible.  The speed and transition of the pension fund investor out of Asset Backed Securities was really quite impressive.  Similarly, I think some of the sharpest risk experts will tell you that the triple AAA rated tranches are undervalued.  After Wall Street got their liquidity back this tranche has started to rally on some of the recent rolls.  &lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;In regard to whether or not the rating agencies played a conspiratorial role?  Ofcourse they did, at the request of Spitzer and the Federal Reserve.  They were holding their downgrades on the big banks and monolines until the last minute.  How would you like to be the head of a quasi-public agencies that threaded the needle for massive economic recession?</description>
		<content:encoded><![CDATA[<p>I&#8217;ve got some issues with this commentary.  Triple A rated tranches in CDO&#8217;s are not as risky an investment as the lower tranches.  While I will agree that the risk element was seriously underestimated by the rating agencies.  I&#8217;m not going to join the banter that Wall Street has zero brains and anyone could have seen this crisis coming.  If all of you fellas had seen it, why are you chatting away on an economics discussion forum rather than enjoying your new yacht on the islands.  Some elements, were visible, and should have been anticipated by the banks.  But, not all of it was visible.  The speed and transition of the pension fund investor out of Asset Backed Securities was really quite impressive.  Similarly, I think some of the sharpest risk experts will tell you that the triple AAA rated tranches are undervalued.  After Wall Street got their liquidity back this tranche has started to rally on some of the recent rolls.  </p>
<p>In regard to whether or not the rating agencies played a conspiratorial role?  Ofcourse they did, at the request of Spitzer and the Federal Reserve.  They were holding their downgrades on the big banks and monolines until the last minute.  How would you like to be the head of a quasi-public agencies that threaded the needle for massive economic recession?</p>
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		<title>By: bsetser</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107086</link>
		<dc:creator>bsetser</dc:creator>
		<pubDate>Wed, 23 Apr 2008 13:02:21 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107086</guid>
		<description>I appreciated the quality of this discussion, and the various links that were posted.  I will archive many of them in the references section of the post over the weekend. Many thanks.</description>
		<content:encoded><![CDATA[<p>I appreciated the quality of this discussion, and the various links that were posted.  I will archive many of them in the references section of the post over the weekend. Many thanks.</p>
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		<title>By: SGC</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107085</link>
		<dc:creator>SGC</dc:creator>
		<pubDate>Tue, 22 Apr 2008 23:29:32 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107085</guid>
		<description>Twofish 15:56:02:  Most of the CDOs backing Citi's asset backed commercial paper conduits were ABS CDOs (i.e. securitizations of securitizations, see  http://www.citigroup.com/citigroup/fin/data/qer081.pdf, page 11).  Since it is usually the lower quality ABS that is put into CDOs, it's hard to believe that the drop in value was due only to illiquidity and not credit risk.  Citi took a 17% writedown on these at the end of December (and the write-downs continue).  &lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;In fact I ran into this http://www.soa.org/files/pdf/2008-ny-kalotay-r2.pdf by a Citi analyst. See page 3 for an estimate of 75% losses for ABS CDOs.  If the super senior tranche is 70% of the CDO, this implies over 60% losses on the super senior tranche.&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;That there was significant credit risk for securitizations of securitizations must have been obvious in the fall to the credit rating agencies -- which afterall understood the structure of these creatures.&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;Twofish 16:00:27:  Touché.</description>
		<content:encoded><![CDATA[<p>Twofish 15:56:02:  Most of the CDOs backing Citi&#8217;s asset backed commercial paper conduits were ABS CDOs (i.e. securitizations of securitizations, see  <a href="http://www.citigroup.com/citigroup/fin/data/qer081.pdf" rel="nofollow">http://www.citigroup.com/citigroup/fin/data/qer081.pdf</a>, page 11).  Since it is usually the lower quality ABS that is put into CDOs, it&#8217;s hard to believe that the drop in value was due only to illiquidity and not credit risk.  Citi took a 17% writedown on these at the end of December (and the write-downs continue).  </p>
<p>In fact I ran into this <a href="http://www.soa.org/files/pdf/2008-ny-kalotay-r2.pdf" rel="nofollow">http://www.soa.org/files/pdf/2008-ny-kalotay-r2.pdf</a> by a Citi analyst. See page 3 for an estimate of 75% losses for ABS CDOs.  If the super senior tranche is 70% of the CDO, this implies over 60% losses on the super senior tranche.</p>
<p>That there was significant credit risk for securitizations of securitizations must have been obvious in the fall to the credit rating agencies &#8212; which afterall understood the structure of these creatures.</p>
<p>Twofish 16:00:27:  Touché.</p>
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		<title>By: Twofish</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107084</link>
		<dc:creator>Twofish</dc:creator>
		<pubDate>Tue, 22 Apr 2008 21:00:27 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107084</guid>
		<description>SGC: You can't have investors believing that money market accounts will never break the buck while also requiring them to sign on to the fact that they could lose money. The product is nonsensical on its face.&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;No more nonsensical then having people base their investment decisions on credit ratings given by an agencies that explicitly tell people not to use rely on those ratings to make investment decisions.......&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;</description>
		<content:encoded><![CDATA[<p>SGC: You can&#8217;t have investors believing that money market accounts will never break the buck while also requiring them to sign on to the fact that they could lose money. The product is nonsensical on its face.</p>
<p>No more nonsensical then having people base their investment decisions on credit ratings given by an agencies that explicitly tell people not to use rely on those ratings to make investment decisions&#8230;&#8230;.</p>
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		<title>By: Twofish</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107083</link>
		<dc:creator>Twofish</dc:creator>
		<pubDate>Tue, 22 Apr 2008 20:56:02 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107083</guid>
		<description>SGC: Contractually the loss should have been taken by the commercial paper holders, since liquidity backstops exclude any assets that are impaired -- and by the time that Citi, for example, took the assets on it was clear that they were already impaired, whether or not they had a AAA rating.&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;The trouble was that the AAA rating referred to credit risk not liquidity risk, and even though the values of the securities dropped because they became illiquid the default risk of those assets didn't markedly increase, thereby giving the credit rating agencies little reason to reevaluate the rating of the security.&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;I think the basic problem is that a AAA rating didn't mean what a lot of people thought it meant.  (And to be far, there were some huge financial incentives not to think too hard about this.)&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;</description>
		<content:encoded><![CDATA[<p>SGC: Contractually the loss should have been taken by the commercial paper holders, since liquidity backstops exclude any assets that are impaired &#8212; and by the time that Citi, for example, took the assets on it was clear that they were already impaired, whether or not they had a AAA rating.</p>
<p>The trouble was that the AAA rating referred to credit risk not liquidity risk, and even though the values of the securities dropped because they became illiquid the default risk of those assets didn&#8217;t markedly increase, thereby giving the credit rating agencies little reason to reevaluate the rating of the security.</p>
<p>I think the basic problem is that a AAA rating didn&#8217;t mean what a lot of people thought it meant.  (And to be far, there were some huge financial incentives not to think too hard about this.)</p>
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		<title>By: anonGuest</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107082</link>
		<dc:creator>anonGuest</dc:creator>
		<pubDate>Tue, 22 Apr 2008 20:06:58 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107082</guid>
		<description>SGC - interesting point on rating agency strategy. I have no view on it except that it was an incredibly stupid product in terms of the risk gymnastics required for some paltry yield pick up. Probably a lot of brokers at fault for pushing it like some boiler room stock scam.&lt;br&gt;&lt;br&gt;</description>
		<content:encoded><![CDATA[<p>SGC - interesting point on rating agency strategy. I have no view on it except that it was an incredibly stupid product in terms of the risk gymnastics required for some paltry yield pick up. Probably a lot of brokers at fault for pushing it like some boiler room stock scam.</p>
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		<title>By: SGC</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107081</link>
		<dc:creator>SGC</dc:creator>
		<pubDate>Tue, 22 Apr 2008 18:54:31 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107081</guid>
		<description>&#34;force the banks to treat the liquidity backstops ...&#34;  maybe that should be &#34;enable the banks to treat the liquidity backstops ...&#34;</description>
		<content:encoded><![CDATA[<p>&quot;force the banks to treat the liquidity backstops &#8230;&quot;  maybe that should be &quot;enable the banks to treat the liquidity backstops &#8230;&quot;</p>
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		<title>By: SGC</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107080</link>
		<dc:creator>SGC</dc:creator>
		<pubDate>Tue, 22 Apr 2008 18:41:56 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107080</guid>
		<description>I think the question is whether the rating agencies deliberately held off on downgrading the super senior CDOs in order to protect the money markets and force the banks to treat the liquidity backstops as credit enhancement.  Contractually the loss should have been taken by the commercial paper holders, since liquidity backstops exclude any assets that are impaired -- and by the time that Citi, for example, took the assets on it was clear that they were already impaired, whether or not they had a AAA rating.&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;While some very short-sighted people might see this protection of the money markets as a good thing because the public would have been frightened, it seems to me that it just allows a fundamentally unstable and contradictory market to continue to operate.  (You can't have investors believing that money market accounts will never break the buck while also requiring them to sign on to the fact that they could lose money.  The product is nonsensical on its face.)  In short, it seems that the money markets have been protected at the expense of the banking system, when the reverse would have put us on the road to a more stable and sensible investment environment.</description>
		<content:encoded><![CDATA[<p>I think the question is whether the rating agencies deliberately held off on downgrading the super senior CDOs in order to protect the money markets and force the banks to treat the liquidity backstops as credit enhancement.  Contractually the loss should have been taken by the commercial paper holders, since liquidity backstops exclude any assets that are impaired &#8212; and by the time that Citi, for example, took the assets on it was clear that they were already impaired, whether or not they had a AAA rating.</p>
<p>While some very short-sighted people might see this protection of the money markets as a good thing because the public would have been frightened, it seems to me that it just allows a fundamentally unstable and contradictory market to continue to operate.  (You can&#8217;t have investors believing that money market accounts will never break the buck while also requiring them to sign on to the fact that they could lose money.  The product is nonsensical on its face.)  In short, it seems that the money markets have been protected at the expense of the banking system, when the reverse would have put us on the road to a more stable and sensible investment environment.</p>
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		<title>By: anonGuest</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107079</link>
		<dc:creator>anonGuest</dc:creator>
		<pubDate>Tue, 22 Apr 2008 18:17:43 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107079</guid>
		<description>Perhaps there's a loose analogy between the morphing of these liquidity backstop lines into full credit exposure, and the Fed's decision to move beyond its normal liquidity provision role by assuming longer term credit risk (particularly with the Bear Stearns loan).&lt;br&gt;&lt;br&gt;</description>
		<content:encoded><![CDATA[<p>Perhaps there&#8217;s a loose analogy between the morphing of these liquidity backstop lines into full credit exposure, and the Fed&#8217;s decision to move beyond its normal liquidity provision role by assuming longer term credit risk (particularly with the Bear Stearns loan).</p>
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		<title>By: anonGuest</title>
		<link>http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107078</link>
		<dc:creator>anonGuest</dc:creator>
		<pubDate>Tue, 22 Apr 2008 18:04:08 +0000</pubDate>
		<guid isPermaLink="false">http://blogs.cfr.org/setser/2008/04/21/not-all-that-sophisticated/#comment-107078</guid>
		<description>SGC:&lt;br&gt;&lt;br&gt;&lt;br&gt;&lt;br&gt;I see your point in part, but the fundamental issue has always been the answer to the question, “Has the credit risk effectively been transferred from the bank to the vehicle?” If the answer is yes, the bank frees up its capital while collecting a fee. Credit enhancement is separate and is charged capital. The liquidity backstop lines were structured in such a way as to create the impression that credit risk had been transferred. The problem is that the liquidity scenario had never been thought through to the point of the total breakdown of the securitization system itself, and the collapse of normal funding availability. When funding reverts to the bank permanently, it effectively assumes the credit risk permanently. This is yet another permutation of the classic bank run. These were ‘normal’ liquidity backstops. This did not require circumvention of rules. It was just a rule that didn’t contemplate the worst case. This points to another very fundamental problem with Basle and risk management in general. In general, there is no capital charge for liquidity risk. The macro categories for capital charges are credit risk, market risk, and operational risk. Liquidity risk is managed under separate guidelines, which are somewhat fluffy in substance. These events hopefully will cause Basle to rethink the approach to liquidity risk.&lt;br&gt;&lt;br&gt;</description>
		<content:encoded><![CDATA[<p>SGC:</p>
<p>I see your point in part, but the fundamental issue has always been the answer to the question, “Has the credit risk effectively been transferred from the bank to the vehicle?” If the answer is yes, the bank frees up its capital while collecting a fee. Credit enhancement is separate and is charged capital. The liquidity backstop lines were structured in such a way as to create the impression that credit risk had been transferred. The problem is that the liquidity scenario had never been thought through to the point of the total breakdown of the securitization system itself, and the collapse of normal funding availability. When funding reverts to the bank permanently, it effectively assumes the credit risk permanently. This is yet another permutation of the classic bank run. These were ‘normal’ liquidity backstops. This did not require circumvention of rules. It was just a rule that didn’t contemplate the worst case. This points to another very fundamental problem with Basle and risk management in general. In general, there is no capital charge for liquidity risk. The macro categories for capital charges are credit risk, market risk, and operational risk. Liquidity risk is managed under separate guidelines, which are somewhat fluffy in substance. These events hopefully will cause Basle to rethink the approach to liquidity risk.</p>
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