Control Leverage

Key question is whether 'adding more control' will stabilize financial institutions like banks, insurance companies or pension funds.....

With all the - apparently failing - new legislation of the last decade already in place and new control measures like Solvency II and the strengthening of the Basel II Framework ahead, one might - at least - question whether we're on the right track with this intensified 'control approach'.

Will adding more control
empower or paralyze financial institutions?

In other words: Is the Control Leverage Effect positive or negative?

Insurance
In an FT-Adviser article called 'Solvency II costs are unsustainable', Joy Dunbar reports that the ABI (Association of British Insurers) has warned that the costs of implementing Solvency II regulations could destabilize the industry across Europe.

To gain more control (financial stability), European Insurers are obliged to implement Solvency II measures by the end of 2012, starting already in 2010.

Impact Solvency II
The increasing control costs and capital demands of Solvency II will have an enormous impact om the insurance market:

• Recapitalization: Insurers need to acquire fresh equity capital (billions of Euros) in the market
  
• Over-Capitalization: More 'dead' capital is created in financial institutions, resulting in declining investment returns in insurance.
• Market shake out: Companies will exit the market
• Pricing effects: prices (premiums) will rise, cover will be reduced

Banks
Whereas the European Insurers are on a more or less 'blind track' with regard to the implementation of Solvency II, the banks - according to chairman of the Basel Committee Mr Wellink - stressed that "decisions on the final proposals and their calibration will be made only after a thorough analysis of the impact assessment and the comments received on the consultative documents. The Committee will ensure that implementation of the new standards is consistent with financial market stability and sustainable economic growth".

The real problem
One doesn't have to be an actuary or financial expert to conclude that we're at the end of the road where adding more of the same type of control measures will substantially stabilize our system.

Without diving deep into real life quantitative analyses, let's get a helicopter-view and take a look at an average 'Control-Return Matrix' to do some 'rule of thumb' exercises...

Rule of thumb Control-Return analyses

Phase I
A few decades ago, starting in the good old sixties of the twentieth century, there where only limited control measures in place (control=0). The average Return on Equity (ROE) of a company was (e.g.) 6% and although Value at Risk (VaR) didn't yet exist as such, the 6% ROE could easily swap between (e.g.) +15% and -50%.

Financial markets where not that developed as today (no derivatives, , CDS, etc). Systemic risk was almost non-existent and accounting principles where based on the simple and relatively stable method of 'historical cost'.

The need for 'more control' was clear to everybody. More control implied lower costs, 'more opportunity insight' and 'more risk control'.
More control turned out to be a good investment and would lead to realizing a better return (ROE) in combination with a lower risk (Var) and a higher 'upward potential'. Every stakeholder was happy.

Phase II
Getting into the eighties and nineties of the twentieth century, 'control' had done its major job and still did, as it was able to manage the few relatively small recessions in those years.

With the help of the oncoming heavy computers, the first baby steps regarding new risk management techniques and ALM (Asset Liability management) were taken.

This way major risks (VaR) could further reduced, sometimes at the cost (expense) of a small reduction of the ROE. But this small effect was largely compensated by the 'fallacy high returns' in the high trust market.

Phase III
At the beginning of the Twenty First Century a new recession made clear the financial environment had substantially changed:

• New techniques, models and the use of modern computer software led to new markets and new products like derivatives
• Markets became global, (on face) transparent, in open competition
• A lack of insight with regard to systemic risks
  
• Differences in local supervision, legislation, administration and accounting rules, led to a complex, non-transparent global market.
• In order to be able to compare companies, they had to be valued at 'market value', implicating the birth of more volatile (stock) markets....
• Step by step, the public and media became more conscious. Investors and consumers understood that even if a 0.5% VaR level would be further reduced, it wouldn't make any sense because it would be always overshadowed by the non-trackable, nor manageable, risk of let's say 1 à 2%. And moreover, who would trust his money to a bank that would go bankrupt once every 50 or 100 years....
  
  

Investors, Boards, Managers, everyone lost their handrail....

In the recent decade (2000-2010) things got worse :

• Existing control and accounting systems would locally differ and failed to meet the complex demands of the new markets
  
• Supervisors en regulators, normally ahead of the market, were suddenly one step behind and unable to catch up given the actual system of supervision
  
• It had become clear that new financial products ( e.g. CDOs, CDSs, subprime mortgages, swaps, swaptions) had been introduced without a good understanding of their financial construction or risk
• Turbulence in the markets. Relatively stable stocks of big international firms, suddenly appeared remarkably unstable, due to new volatile markets/products and 'fair value accounting'.
• The once so well controlled VaR risk exploded, due to these new types of risk in the market, the fair value accounting principles and the spooky systemic risk.

Way out
Like everyone else - totally flabbergasted - supervisors and regulators immediately grabbed the traditional emergency brake of 'more control'.

Unfortunately, more 'traditional' control in phase III will not have the same effect as in phase I or II. The effects of more traditional control in phase III will be:

• Substantial but unsure decrease of ROE and 'upward potential'.
  The effects are not known upfront and can't be estimated well.
  Sure is that the costs of extra control and 'dead money' will have a negative impact on the ROE.
  
  
• Unknown and questionable reduction of VaR risks, as one thing is sure: the new type(s) of (VaR) risks can not be estimated by our retrospective based models. Probably, all efforts in vain, the remaining actu(ari)al risk level will not be substantially reduced.
  
  
• Trying to 'catch' more 'safe' risk levels (lower α , VaR) will lead to over-capitalization and 'dead' money in the balance sheet and an unbalanced growth of derivatives.
  
  

• The market of derivatives continuous to grow.
  
  The notional value of derivatives held by U.S. commercial banks increased $804 billion in the third quarter to $204.3 trillion.
  
  This, despite the statements of Fed Chairman Bernanke who says he wants to avoid the possible risk of a future speculative bubble.
  
  And despite of Treasury Secretary Geithner who says he wants to reform financial regulation to avoid a future debt disaster.
  
  
• Because the real issues of the financial crisis where not solved, but only covered up with government help (money), new uncontrollable 'bubbles' will keep showing up.
  

Solutions
probably the best solution is not 'more control', but

Other Control

Examples of 'other control' are:

• Obligatory report and central registration of all derivatives under one worldwide supervisory. This way systemic risk analyses won't be 'guess statistics' anymore and can be managed. System risk is one of the weirdest risks to tackle, as is illustrated by the next article:
  
  Why Your Friends Have More Friends Than You Do
  
  Although the Exchange Commission has taken some serious steps in 2009 to regulate and strengthen the over-the-counter ("OTC") derivatives, this process will probably not be rigorous and fast enough to prevent a possible new bubble or collapse.
  All OTC market products should be asap standardized on a centrally administered basis.
  
  
• Limit and control the derivatives market. Maximize the derivative market in respect to the 'normal' market. Limit each companies derivatives in line with his equity. New regulation should also be developed with regard to participating in non defensive (strange) derivatives (e.g. define max. exposure multipliers).
  If not the next bubble is a fact!
  
  
• New derivatives should be subject to approval ('no objection') by the regulator before market launch.
  
  

So it all comes down to the 'right control' leverage.
It's either positive leverage with 'new other control' or negative leverage with 'more of the same traditional control' and waiting for the next bubble. What do you prefer as an actuary?

Sources:
- Contagion in Financial Networks
- Testimony Concerning OTCs (Over-the-Counter Derivatives )
- OCC’s Q3 2009 Report on Bank Trading and Derivatives Activities
- The bigger and riskier monster....
- Tarp facts: The Troubled Asset Relief Program
- The Investment Fallacy

Wir haben es nicht gewusst

Let's be humble and take a look at home. The home of actuaries, accountants and last but not least 'quants'.

Gewußt oder nicht gewußt?
Actuaries and accountants have failed in foreseeing the credit crisis. Together, we have greatly underestimated the developments and put our head in the sand. We've also failed to bring the emerging crisis to a possible end through enhanced cooperation with each other or by sending out common strong signals. In short: "Wir haben es nicht gewußt!"

Without an adequate technical substantiation, we have trusted business plans promising ROEs of 15% and more. This, while we all know that the average risk-free rate is still about 10% below this level and that such high returns can certainly not be made without taking additional risk.

VaR Model
As an article in The Actuary shows, we got intimidated and overruled by the quants with their Value at Risk (VaR) models. The consequences of the advices of these magic mathematicians and their VaR models are well explained in an excellent article called 'Risk Mismanagement' in the New York Times.

In another article, Global Association of Risk Professionals Review, David Einhorn explains:

VaR ignores what happens in the tails.

It specifically cuts them off.
A 99% VaR calculation does not evaluate what happens in the last 1%.

This makes VaR relatively useless as a riskmanagement tool and potentially catastrophic when its use creates a false sense of security among senior managers and watchdogs. " Quote:

VaR is like an airbag that works all the time,
except when you have a car accident

Also, according to Bloomberg, the risk-taking VaR model is broken and everyone is coming to the realization that no formula or rating system can substitute for old-fashioned 'due diligence'.

Quantum mechanics
Because of the complexity of these new VaR-like models, experienced actuaries, accountants, managers and supervisors were all afraid to ask deeper questions or to admit that they didn't totally understood these complex models that were presented as 'simple manageable board instruments' with 'simple steering parameters'. Just like nobody is eager to admit that 'quantum mechanics' is hard to understand and therefor every amateur quantum guru can say what he wants, because nobody checks it.

Consequences
This way, indirect and by our advice and our models, CEOs and CFOs of large companies and pension funds got the (wrong) impression that 'complex financial markets' were based on 'a sound statistical model', where (annual) deficit risks of 2.5%, 0.5% or 0.1% are exactly calculable and moreover also acceptable.

Whatever, lessons learned, new opportunities for actuaries to set a new benchmark for '21 century riskmanagement'.

However..., stay careful, to catch a tiger by the tail is risky!