The Senior Supervisors Group recent document, Observations on Risk Management Practices during the Recent Market Turbulence is a more interesting read than the Financial Stability Forum interim report not least because it compares leading firms who have come through recent events relatively unscathed with those that suffered some of the largest impacts.
Some of the highlight follow, with my emphasis. First the SSG identifies four firm-wide risk management practices that differentiated performance:
Through robust dialogue among members of the senior management team (including the chief executive officer, the chief risk officer, and others at that level), business line risk owners, and control functions, firms that performed well through year-end 2007 generally shared quantitative and qualitative [risk] information more effectively across the organization.
This is pure risk culture. Firms which keep risk data to the high priesthood of risk management and a few senior business leaders are not using as much of the brainpower of their organisation as they could. Further, this kind of culture tends to go with authoritarian, vertical management styles which makes it much harder to discuss issues openly and honestly.
At firms that performed better in late 2007, management had established, before the turmoil began, rigorous internal processes requiring critical judgment and discipline in the valuation of holdings of complex or potentially illiquid securities. These firms were skeptical of rating agencies’ assessments of complex structured credit securities and consequently had developed in-house expertise to conduct independent assessments of the credit quality of assets underlying the complex securities to help value their exposures appropriately. Finally, when they reached decisions on values, they sought to use those values consistently across the firm, including for their own and their counterparties’ positions. Subsequent to the onset of the turmoil, these firms were also more likely to test their valuation estimates by selling a small percentage of relevant assets to observe a price or by looking for other clues, such as disputes over the value of collateral, to assess the accuracy of their valuations of the same or similar assets.
Clearly anyone trading complex securities should have independent expertise to value them. Equally clearly once they have been valued, that value should be used consistenly throughout the firm. What’s shocking here is that some leading firms – this survey comprises eleven of the largest banks – did not have these basic control processes in place.
Those firms that avoided more significant problems through our year-end review period aligned treasury functions more closely with risk management processes, incorporating information from all businesses in global liquidity planning, including actual and contingent liquidity risk. These firms had created internal pricing mechanisms that provided incentives for individual business lines to control activities that might otherwise lead to significant balance sheet growth or unexpected reductions in capital. In particular, these firms had charged business lines appropriately for building contingent liquidity exposures to reflect the cost of obtaining liquidity in a more difficult market environment.
It so often comes down to incentive structures doesn’t it? If you charge businesses for actual and contingent liquidity, including writing liquidity lines to conduits, then they will make sure the firm is paid enough for these structures. If you don’t, they will be pretty much given away.
Firms that tended to avoid significant challenges through year-end 2007 typically had management information systems that assess risk positions using a number of tools that draw on differing underlying assumptions. Generally, management at the better performing firms had more adaptive (rather than static) risk measurement processes and systems that could rapidly alter underlying assumptions in risk measures to reflect current circumstances. They could quickly vary assumptions regarding characteristics such as asset correlations in risk measures and could customize forward-looking scenario analyses to incorporate management’s best sense of changing market conditions. Most importantly, managers at better performing firms relied on a wide range of measures of risk, sometimes including notional amounts of gross and net positions as well as profit and loss reporting, to gather more information and different perspectives on the same exposures. Moreover, they effectively balanced the use of quantitative rigor with qualitative assessments.
This is very interesting. If you have different tools with different assumptions, you have a reasonable handle on model risk. If you have one system, or multiple systems which all use the same assumptions, then you don’t. Flexible systems are clearly important, but perhaps even more significant is the mindset of looking at risk in different ways, and being sceptical about the results of any one analysis.
The report then goes on to look at three business lines where varying practices produced different outcomes. The first, unsurprisingly, is CDO structuring, warehousing, and trading businesses. Here the key issue was whether
Internal incentives were missing or inadequately calibrated to the true risk of the exposures to the super-senior tranches of CDOs.
To be fair, I doubt anyone really got this right. What may have happened, though, is that positions that were originally acquired with the intention of selling them on became prop positions when they couldn’t be sold at the mark rather than being written down until they did sell.
Next, syndication of leveraged financing loans:
Some firms worked aggressively to defend or expand market share in the syndication of leveraged financing loans, and many of those that later faced challenges in this business did not properly account for the price risk inherent in the syndicated leveraged lending pipelines.
Buying business is fine. But if you are going to pay for league table position, then at least know how much you paid for it.
Finally in conduit and SIV business we find:
Several firms did not properly recognize or control for the contingent liquidity risk in their conduit businesses or recognize the reputational risks associated with the SIV business.
For me the interesting part here is the reputational incentive. All the accounting and regulatory arguments that got these assets off balance sheet depending on the risk really passing to SIV and conduit investors. Firms that recognised that their reputational risk tolerance meant that this risk really had not been transferred clearly did better than those that pretended that the accounting and regulation followed the reality.