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Slides24 PDF
Slides24 PDF
Lecture 24
Tri Vi Dang
Columbia University
Spring 2022
I.3. New Forms of Money and II.3. Market Making and Risk
Banking Management of Banks
G. Case: Risk Retention Rule and the Rise of MOA and CMOA
This section provides another example that shows how regulation leads to new
innovations and new investment opportunities.
Amended from section 15G of the Securities Exchange Act of 1934 and
required under section 941 of the Dodd-Frank Wall Street Reform and
Consumer Protection Act
Effective December 24, 2015 for ABS backed by residential mortgage loans
and December 24, 2016, for all other securitizations
Six Agencies: OCC, Federal Reserve Board, SEC, FDIC, FHFA, and HUD
Vertical Interest: retaining at least 5% of the face value of each tranche and
represents an interest in the entire structure of the securitization transaction
Horizontal Interest: retaining at least 5% of the face value of the entire issue,
typically in the most subordinate tranche, and represents a “first-loss position”
on the entire asset pool
Securitizer/Sponsor:
Majority-Owned Affiliate:
“an entity (other than the issuing entity) that, directly or indirectly, majority
controls, is majority controlled by or is under common majority control with,
such person” and where majority control means “ownership of more than 50
percent of the equity of an entity or ownership of any other controlling
financial interest in the entity, as determined under GAAP”
The Loan Syndication and Trading Association (LSTA) filed a lawsuit against
the SEC and Federal Reserve shortly after the final rules were passed. The
industry and LSTA cite the following in support of repeal or moderation of
rules for CLOs:
CLO managers earn a performance fee. Thus, their incentives are already
aligned with investors.
CLOs are not the “originate-to-distribute” model risk retention aims to correct.
i) asset quality, ii) portfolio diversification, iii) capital structure, iv) alignment
of interests of the manager and investor, v) regulation of the manager, and vi)
transparency and disclosure”
CLO 1.0
Originally issued in the 1990s, the first vintage of CLOs invested in leveraged
loans, high yield bonds, and other structured products (e.g. CDS). They were
invented to facilitate increased lending and focused on generating income.
CLO 2.0
Following the financial crisis in 2008, CLOs featured stronger credit support
(greater subordination, less leverage, tighter collateral tests, etc.) and a shorter
reinvestment period.
CLO 3.0
In response to the Volker Rule and a new regulatory environment, CLOs since
2014 have been “Volkerized” to remove all non-loan assets from collateral
pools.
Three standard risk retention vehicles have emerged: the MOA, CMOA, and
CMV.
According to Moody’s, only 59 out of 6606 CLO tranches they rated since
1993 have suffered principal impairment (none of CLO 2.0).
Section I.3.O shows that there are no adverse selections and Wildcat CLOs.
This section uses JP Morgan (JPM) to illustrate the main principals of bank
risk management.
With $2.266 trillion in total assets at December 31, 2011, but only $184 billion
of total stockholders’ equity, JPM needed to accurately measure and closely
monitor the risks that it took.
In December 2014, JPM had 2.571 trillion total assets and $232 billion book
equity.
The Risk Policy Committee “provides oversight of the CEO’s and senior
management’s responsibilities to assess and manage the Firm’s credit risk,
market risk, interest rate risk, investment risk, liquidity risk, and reputational
risk, and is also responsible for review of the Firm’s fiduciary and asset
management activities”.
JPM used a formal framework to link the firm’s appetite for risk with its return
targets, capital management, and other controls.
The Risk Policy Committee approved the risk appetite policy on behalf of the
Board.
Chief Executive Officer Jamie Dimon established JPM’s overall risk appetite
and also approved the risk appetite that the head of each of the bank’s lines of
business had set for their unit.
Country
Private Equity
Operational
Reputation
Money and Banking, Tri Vi Dang, Columbia University, Spring 2022 36
The following four corporate functions provided oversight.
Risk Management
coordinates and communicates with each line of business through the line of
business risk committees and chief risk officers to manage risk
Corporate Treasury
same responsibilities as the CIO
Money and Banking, Tri Vi Dang, Columbia University, Spring 2022 37
Money and Banking, Tri Vi Dang, Columbia University, Spring 2022 38
Remark
JPM separated its Chief Investment Office (CIO) from its Treasury unit in
2005, with CIO becoming a separate unit within the bank.
By year-end 2011, CIO had 428 employees based in New York and London,
consisting of 140 front office traders and 288 middle and back office staff.
The next sections discuss the CIO unit and the $6 billion loss incurred by its
$350 billion synthetic credit portfolio.
In April 2011, the Board of Governors of the Federal Reserve System and the
OCC issued joint “Supervisory Guidance on Model Risk Management” for the
banks under their supervision.
Value at Risk (VaR) was developed by JPM in the early 1990s and has since
become one of the most common methods employed by financial institutions
to measure and monitor market risk by using data about the volatilities of and
correlations among financial securities to measure potential loss.
JPM defines “market risk” as the “exposure to an adverse change in the market
value of portfolios and financial instruments caused by a change in market
prices or rates”.
VaR is an estimate of the most that one or more financial instruments could
lose in value over a fixed time period (e.g., one day) with a given level of
confidence (e.g., 95%).
“Value-at-Risk (VaR) means the estimate of the maximum amount that the
value of one or more positions could decline due to market price or rate
movements during a fixed holding period within a stated confidence interval.”
“VaR is calculated using a one day time horizon and an expected tail-loss
methodology, and approximates a 95% confidence level.
This means that, assuming current changes in market values are consistent
with the historical changes used in the simulation, the Firm would expect to
incur losses greater than that predicted by VaR estimates five times in every
100 trading days, or about 12 to 13 times a year.
Financial institutions use VaR models to calculate regulatory capital and for
internal risk management.
Though the OCC allows banks under its supervision to develop their own VaR
models used for regulatory purposes, it provides detailed guidance on how
these VaR models should function.
Furthermore, the OCC must approve the regulatory VaR models that the banks
create.
However, the OCC does not review or approve VaR models used by banks for
internal risk management.
JPM uses numerous VaR models to calculate the market risk of individual
positions, products, and trading desks, with different models typically used to
calculate regulatory capital and for internal risk management.
JPM’s most important VaR calculation for internal risk management is the one
used in quarterly 10-Q and annual 10-K filings.
This so-called “10-Q VaR” is based on a one-day holding period and a 95%
confidence level and is a Level 1 risk limit.
Since JPM calculated 10-Q VaR using a 95% confidence level, it expected
losses greater than those predicted by the model 5 times in every 100 trading
days, or about 13 times per year.
There is a 5% that the loss exceeds $76 million at one trading day.
Or only 5 times in 100 trading days, would the loss exceed $76 million.
JPM risk management staff would compare actual VaR usage to the maximum
VaR limit set by senior management.
At January 1, 2012, JPM’s firm-wide 10-Q VaR limit was $125 million, and
CIO’s equivalent limit was $95 million, reflecting that much of JPM’s market
risk came from the CIO.
JPM provides a wide variety of financial services, yet its commercial bank
subsidiaries continue to engage in the basic banking functions of taking
deposits and making loans.
JPM had not loaned out excess deposits, so the bank needed a way to
profitably yet safely invest these excess deposits.
This task was assigned to the CIO unit, and it was the unit’s primary
responsibility.
CIO invested the bank’s excess deposits in Treasury bonds and other
investment grade (i.e., high quality) fixed income securities, including
corporate, municipal, and asset-backed bonds.
This conservative investment approach was consistent with how other banks
managed excess deposits, and the average credit rating for CIO’s investments
was AA+.
One of CIO’s other objectives was to partially hedge JPM’s credit risk.
Like other lenders, JPM is exposed to credit risk (also known as default risk),
which is the risk that someone who has borrowed money from the bank is
unwilling and/or unable to repay the money when due.
JPM separated its Chief Investment Office (CIO) from its Treasury unit in
2005, with CIO becoming a separate unit within the bank.
By year-end 2011, CIO had 428 employees based in New York and London,
consisting of 140 front office traders and 288 middle and back office staff.
Ina Drew, who was JPM’s Chief Investment Officer, was also head of CIO
from its start as a separate unit in 2005 until her retirement in May 2012 one
month after the CIO trading losses had become public.
Her subordinate Achilles Macris ran the CIO London office in his capacity as
International Chief Investment Officer. Javier Martin-Artajo directly oversaw
the SCP as Head of Europe and Credit & Equity, and reported to Macris.
Bruno Iksil, the “London Whale”, was the senior trader of the SCP and
reported to Martin-Artajo.
JPM fired Macris, Martin-Artajo, and Iksil in July 2012, while suspending
Grout (who then subsequently resigned).
In an internal memo dated March 31, 2014, JPM said that it would recombine
the CIO and Treasury units, which is how asset-liability management function
is traditionally structured at most banks.
The main products traded by Iksil were based on the CDX.NA.HY and
CDX.NA.IG indices administered by the Markit Group Limited (Markit).
In December 2011, Dimon and Braunstein instructed CIO to reduce the size of
the SCP during 2012, so that JPM could reduce its Risk-Weighted Assets
(RWA) as the bank prepared to adopt the impending Basel III bank capital
regulations.
However, Martin-Artajo, Iksil, and Grout were also expected to minimize the
trading costs of decreasing RWA, while still maintaining the chance to profit
from unexpected corporate bankruptcies.
The trading strategy was not successful, as changes in credit spreads caused
the value of protection owned by SCP to decrease more rapidly than did the
value of protection that the traders had sold.
Although Drew ordered the SCP traders to halt this strategy on March 23,
losses continued to mount as the credit derivative positions were unwound,
ultimately reaching $6.2 billion by December 2012.
This case highlights that senior risk managers might have not intervened
properly when traders exceeded their risk limits.
Large part of the firm-wide risks came from the synthetic credit portfolio
(SCP).
When risk limits were exceeded, senior managers increased risk limits.
Remark
All major financial institutions use various risk limits and metrics, often based
on mathematical models, to measure and monitor the risk of their lending and
investing activities.
The amount of risk taken is measured on a daily or weekly basis using various
risk metrics, and these amounts are compared with the relevant limits.
If a risk limit is exceeded, JPM policy requires that such breaches be reported
to senior management in a timely fashion, and that the affected line of business
reduce the size of its trading positions or consult with senior management on
the appropriate action.
In practice, these risk limits and the accompanying metrics and models
provided little or no restraint on the risk that was taken by CIO.
JPM risk management staff would compare actual VaR usage to the maximum
VaR limit set by senior management.
At January 1, 2012, JPM’s firm-wide 10-Q VaR limit was $125 million, and
CIO’s equivalent limit was $95 million, reflecting that much of JPM’s market
risk came from the CIO.
On January 9, JPM VaR was $123 million and CIO VaR was $88 million,
already rapidly approaching their respective limits.
On January 16, caused CIO exceeded its own $95 million VaR limit and was
the main contributor to the breach of the $125 million firm-wide VaR limit.
However, Drew did not order the CIO traders to reduce the size of the risky
positions within the SCP book in response to the limit breaches.
Irvin Goldman, the recently appointed CIO Chief Risk Officer, e-mailed his
superior Hogan that the most important solution to stop the breaches was the
new VaR model that CIO planned to implement by the end of January.
On January 23, Dimon and Hogan approved a temporary increase in the firm-
wide VaR limit from $125 million to $140 million until January 31.
Ms. Drew likewise temporarily raised the CIO VaR limit from $95 million to
$105 million.
On January 30, JPM’s Model Review Group (part of the risk management
function) approved CIO’s new VaR model.
With the new model reducing CIO VaR by half from the initially reported
$132 million to only $66 million.
When Peter Weiland, CIO head of market risk, learned of the $6.3 billion
CRM figure in early March, he dismissed it as “garbage”.
For example, how much would JPM profit from the change in fair value of
protection that it had purchased on a high yield CDS whose spread widened
from 500 to 501 basis points, or how much would JPM lose from the change in
fair value of protection that it had sold on an investment grade CDS whose
spread widened from 200 to 201 basis points?
CS01 was also referred to as Credit Spread Basis Point Value (CSBPV).
Though these proposed limit increases were not granted, Drew also did not
require traders to reduce risk.
Weiland also faulted CSBPV, just as he criticized the results of the CRM
metric.
The Credit Spread Widening 10% (CSW10%) metric measures the expected
profit or loss to a portfolio if the spread on each credit position simultaneously
widened by 10% of its current amount.
For example, how much would JPM profit from the change in fair value of
protection that it had purchased on a high yield CDS whose spread widened
from 500 to 550 basis points, or how much would JPM lose from the change in
fair value of protection that it had sold on an investment grade CDS whose
spread widened from 200 to 220 basis points?
In contrast with their general disregard for CRM and CSBPV, both Drew and
Weiland felt that CSW10% was useful in measuring and monitoring risk.
However, the various long and short derivative positions in the SCP book still
existed, and losses escalated and risk limits continued to be exceeded as a
result, even as the trading book was being dismantled.
After its review, most SCP credit derivatives were transferred during the
second quarter to the Investment Bank, which closed out these positions
throughout the remainder of the year.
JPM reviewed and revised market risk limits across all lines of business,
adding more granular limits.
For example, CIO had 260 risk limits by January 2013, including
concentration limits and portfolio-specific limits for the first time.
JPM CIO unit was responsible for investing excess deposits in low-risk high-
quality bond holdings,
While the CIO was in charge of a number of different portfolios, one important
issue surrounding the SCP (synthetic credit portfolio) specifically was whether
the portfolio evolved over time from a purely hedging function to also
incorporate proprietary trading.
JPM completed the initial internal audit review of what it termed “CIO Global
Credit Trading” in November 2007.
In the final audit report, the business overview began by noting that CIO
“credit trading activities commenced in 2006 and are proprietary position
strategies executed on credit and asset back indices.”
A report issued January 2013 by the internal JPMorgan Chase Management Task
Force (JPM Task Force) stated “The Synthetic Credit Portfolio managed by CIO was
intended generally to offset some of the credit risk that JPMorgan faces, including in
its CIO investment portfolio and in its capacity as a lender.” (JPM Task Force 2013, 2)
However, the SCP traders could produce no documentation of what these credit risks
were, what hedges would be used, or how to test hedge effectiveness. (US Senate
Report, 4)
In other US Senate testimony, JPM officials acknowledged that the CIO never
documented SCP’s purpose or intended manner of working, nor did the CIO ever issue
a policy delineating SCP hedging parameters or strategies.
Senior JPM executives have stated that the SCP would not have required such
procedures and documents, since it was not intended as a dedicated hedge, but rather
as a macro hedge to protect the bank as a whole against credit risk during another
financial crisis or other stress event.
Money and Banking, Tri Vi Dang, Columbia University, Spring 2022 86
Credit Suisse Gave Archegos Big Leverage for Collateral
Bloomberg, 05/03/2021
Credit Suisse lent the family office of Bill Hwang funds allowing bets with leverage of
up to ten times, and only asked for collateral worth 10% of the sums borrowed,
according to a person familiar with the business.
The leverage offered by the Swiss bank was in some cases double what other brokers
gave Hwang, helping to push the loss to some $5.5 billion after the fund imploded in
March. That compares with a $2.9 billion hit to Nomura Holdings Inc and lesser sums
or no loss at all for lenders including Deutsche Bank AG that offered Hwang prime
brokerage services.
https://www.bloomberg.com/news/articles/2021-05-03/credit-suisse-gave-archegos-big-leverage-for-little-collateral
The impact stems from Archegos’s failure to meet a margin call in March. The
resulting fire sale of assets, which initially included high-profile US media stocks,
flooded the market and resulted in lower returns for investment banks that were trying
to unwind the hedge fund’s position and recoup their losses.
The margin call, which is usually triggered when the total value of assets held in a
firm’s prime brokerage account falls below an acceptable level, required Archegos to
top up its account with extra cash or collateral.
When it failed to meet that demand, the investment banks tried to minimise potential
exposure to losses by selling shares and other assets from the Archegos’ accounts.
But lenders like Credit Suisse have taken a hit after failing to recoup losses through
the sell-off.
https://www.theguardian.com/business/2021/apr/27/nomura-and-ubs-latest-banks-to-reveal-impact-of-archegos-collapse
Banks Are Making It Harder for Hedge Funds to Leverage Their Bets After
Archegos
Bloomberg, 05/06/2021
https://www.bloomberg.com/news/articles/2021-05-06/archegos-fallout-crimps-hedge-fund-leverage-as-banks-curb-risks
Zeissler, Bennett, and Metrick (2014): JPMorgan Chase London Whale Z: Background
& Overview Yale Program on Financial Stability Case Study 2014-2Z-V1.
http://som.yale.edu/sites/default/files/files/001-2014-2Z-V1-REVA.pdf
Zeissler, Bennett, and Metrick (2014): JPMorgan Chase London Whale D: Risk
Management Practices, Yale Program on Financial Stability Case Study 2014-2D-V1.
http://som.yale.edu/sites/default/files/files/001-2014-2D-V1-JPMorgan-D-REVA.pdf
Zeissler, Arwin and Metrick (2014): JP Morgan Chase London Whale C: Risk Limits,
Metrics, and Models, Yale Program on Financial Stability Case Study 2014-2C-V1.
http://som.yale.edu/sites/default/files/files/001-2014-2C-V1-JPMorgan-C-REVA.pdf
Zeissler, Arwin and Metrick (2014): JPMorgan Chase London Whale G: Hedging
versus Proprietary Trading, Yale Program on Financial Stability Case Study 2014-2G-
V1.
http://som.yale.edu/sites/default/files/files/001-2014-2G-V1-JPMorgan-G-REVA.pdf