Don’t Destroy the Essential Catalyst of Risk
Since the spring, and most acutely this autumn, a global contagion (传染)of fear and panic has choked off the arteries of finance, compounding a broader deterioration in the global economy.
Financial institutions have an obligation to the broader financial system. We depend on a healthy, well-functioning system but we failed to raise enough questions about whether some of the trends and practices that had become commonplace really served the public’s long-term interests.
Seven important lessons
As policymakers and regulators begin to consider the regulatory actions to be taken to address the fallings, I believe it is useful to reflect on some of the lessons from tiffs cr.
The first is that risk management should not be entirely predicated on historical data. In the past several months, we have heard the phrase" multiple standard deviation s" more than a few times. If s that were calculated to occur once in 20 years in fact occurred much more regularly, it does not take a mathematician to figure out that risk management assumptions did not reflect the distribution of the actual outcomes. Our industry must do more to enhance and improve scenario ysis and stress testing.
Second, too many financial institutions and investors simply outsourced their risk management. Rather than undertake their own ysis, they relied on the rating agencies to do the essential work of risk ysis for them. This was true at the inception(初期)and over the period of the investment, during which time they did not consider other indicators of financial deterioration.
This over-dependence on credit ratings coincided with the dilution of the desired triple A-rating. In January 2008, there were 12 triple A-rated companies in the world. At the same time, there were , 000 structured finance instruments, such as collateralized debt obligations, rated triple A. It is easy and appropriate to blame the rating agencies for lapses in their credit judgments. But the blame for the result is not theirs ’alone. Every financial institution that participated in the process has to accept its share of the responsibility.
Third, size matters. For example, whether you owned $5 billion or $50 billion of (supposedly) low-risk super senior debt in a CDO, the likelihood of losses was, proportionally, the same. But the consequences of a miscalculation were obviously much bigger if you had a $50 billion exposure.
Fourth, many risk models incorrectly assumed that positions could be fully hedged. After the collapse of Long-Term Capital Management mid the cr in emerging markets in 1998, new products such as various basket indices and credit default swaps were created to help offset a number of risks. However, we did not, as an industry, consider carefully enough the possibility that liquidity would dry up, it difficult to apply effective hedges.
Fifth, risk models failed to capture the risk inherent in off-balance sheet activities, such as structured investment vehicles. It seems clear now that managers of companies with large off-balance sheet exposure did not appreciate the full magnitude of the economic risks they were exposed to; equally worrying, their counterparties were unaware of the full extent of these vehicles and, therefore, could not accurately assess the risk of doing business.
Sixth, complexity got the better of us. The industry let the growth in new instruments outstrip(超过)the operational capacity to manage them. As a result, operational risk increased dramatically and tiffs had a direct effect on the overall stability of the financial system.
Last, and perhaps most important, financial institutions did not account for asset values accurately enough. I have heard some argue that fair value accounting -- which assigns current values to financial assets and liabilities -- is one of the main factors exacerbating(使恶化) the credit cr. I see it differently. If more institutions had properly valued their positions and commitments at the outset, they would have been in a much better position to reduce their exposures.
Fair value: a discipline for financial institutions
The daily marking of positions to current market prices was a key contributor to our decision to reduce risk relatively early in markets and in instruments that were deteriorating. This process can be difficult, and sometimes painful, but I believe it is a discipline that should define financial institutions.
As a result of these lessons and others that will emerge from this financial cr, we should consider important principles for our industry, for policymakers and for regulators. For the industry, we cannot let our ability to innovate exceed our capacity to manage. Given the size and interconnected nature of markets, the growth in volumes, the global nature of trades and their cross-asset characteristics, managing operational risk will only become more important.
Risk and control functions need to be completely independent from the business units. And clarity as to whom risk and control managers report to is crucial to maintaining that independence. Equally important, risk managers need to have at least equal stature with their counterparts on the trading desks: if there is a question about the value of a position or a disagreement about a risk limit, the risk manager’s view should always prevail.
Understandably, compensation continues to generate a lot of anger and controversy. We recognize that having troubled asset relief programme money creates an important context for compensation. That is why, in part, our executive management team elected not to receive a bonus in 2008, even though the firm produced a profit.
More generally, we should apply basic standards to how we compensate people in our industry. The percentage of the discretionary (任意的)bonus awarded in equity should increase significantly as an employee’s total compensation increases. An individual’s performance should be evaluated over time so as to avoid excessive risk-taking. To ensure this, all equity awards need to be subject to future delivery and/or deferred exercise. Senior executive officers should be required to retain most of the equity they receive at least until they retire, while equity delivery schedules should continue to apply after the individual has left the firm.
Limitations of self regulation
For policymakers and regulators, it should be clear that self-regulation has its limits. We rationalized and justified the downward pricing of risk on the grounds that it was different. We did so because our self-interest in preserving and expanding our market share, as competitors, sometimes blinds us -- especially when exuberance is at its peak. At the very least, fixing a system-wide problem, elevating standards or driving the industry to a collective response requires effective central regulation and the convening power of regulators.
Capital, credit and underwriting standards should be subject to more" dynamic regulation". Regulators should consider the regulatory inputs and outputs needed to ensure a regime that is nimble and strong enough to identify and appropriately constrain market excesses, particularly in a sustained period of economic growth. Just as the Federal Reserve adjusts interest rates up to curb economic frenzy, various benchmarks and ratios could be appropriately calibrated. To increase overall transparency and help ensure that book value really means book value, regulators should require that, all assets across financial institutions be similarly valued. Fair value accounting gives investors more clarity with respect to balance sheet risk.
The level of global supervisory co-ordination and communication should reflect the global interconnectedness of markets. Regulators should implement more robust information sharing and harmonized disclosure, coupled with a more systemic, effective reporting regime for institutions and main market participants. Without this, regulators will lack essential tools to help them understand levels of systemic vulnerability in the banking sector and in financial markets more broadly.
In this vein, all pools of capital that depend on the smooth functioning of the financial system and are large enough to be a burden on it in a cr should be subject to some degree of regulation. When the Long-Term Capital Management was disintegrated, the products initiated to counterweigh risks were ______.