Deus Ex Macchiato

One of the key messages of this blog in its early years was ‘actuaries have escaped a big dollop of blame for our financial mess that is rightfully theirs’, the argument being in very short form that without their utterly unjustified assumptions about investment growth and life expectancy we would not have nearly as big a pensions crisis as we do.

I’m currently watching the last episode of Utopia. (Spoilers.) One of the things that this series posits is a cabal trying to return Earth to a much smaller population. Apart from making me cheer for the baddies (I’m a child of the Limits to Growth generation), it also made me wonder what the consequences of another bad actuarial design decision – current pensions funded by increasing numbers of workers – will be. We have already seen the beginning of this crisis in muniland, and it is going to get rather worse. The baddies in Utopia are meeting increasingly ugly ends: while I wouldn’t wish any of them on the average actuary, I do rather think that some measure of accountability for their past deeds would not be entirely unwarranted. That’s just Utopian, right?

Posted in: Insurance and Actuarial Practice, Pensions by David /
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I’m a little busy trying to finish something, so here are three terse items from my ‘read, and want to blog about’ list for the week so far:

• A truly shocking article on The Big Picture about the effective tax rates of the most profitable US companies. I really don’t think this state of affairs can continue: people will not tolerate it.
• An insightful letter by John Hutton in the FT about the EU proposal to extend Solvency II type regulation to pensions schemes. The key point:
  

  The immediate impact … would be a significant but arbitrary increase in pension scheme liabilities. If these proposals go ahead, funded pension schemes will undoubtedly have to adopt higher funding levels and shorter periods over which they have to make up any deficits… If schemes are forced to adopt ultra-cautious funding models, they will need to disinvest from equities, which would be highly damaging for European financial markets… None of this will offer meaningful protection to fund members – on the contrary, it will undermine the very existence of the remaining defined benefit schemes.

• A typically over-stated Felix Salmon column that nevertheless makes one good point. He discusses the rise of collateralized funding arrangements such as repo and the decline of the interbank market. This is a bad thing:
  

  If we’re talking about the banking system, here, we’re talking about a world in which banks simply cease to trust each other at all, and the answer to all interbank credit [extension] questions is “no”. The only way for banks to lend to each other is to either go through some central counterparty, hub-and-spoke style, or else to retreat to the world of repo, where banking prowess counts for nothing and all that matters is collateral quality.

  Clearly a fundamental job of banks is to lend, including to each other: to make credit judgements and to put money on the line based on those. We need to find a way to restore bank confidence in each other (not least because smaller amounts of unsecured debt in a bank’s capital structure gives less of a cushion protecting depositors in resolution).

Posted in: Credit, Insurance and Actuarial Practice, Pensions, Taxation by David /
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(Crossposted from FT Alphaville.)

“The question is,” said Alice, “whether you can make words mean so many different things.”

In a recent Alphaville post, I made the claim that if the monolines had been required to mark the credit risk that they had taken to market, they would not have played such a prominent role in the financial crisis. Here I want to provide some support for that claim.

There will be several threads to this narrative. We begin with credit spreads.

What’s in a credit spread?

A credit spread is the compensation the taker of credit risk receives for risk. It is well-known that this includes more than just compensation for default risk. Citi research, for instance, produced this illustration recently, showing the default and non-default components of generic BBB credit spreads over time:

They use the term ‘risk premium’ for the non-default component: in reality this component is a mix of compensation for liquidity risk, funding risk, and other factors.

Notice how this non-default component varies over time. What this means is that a holder of credit risk who is marking to market suffers some P&L volatility that is unrelated to default risk (as well as some that is).

The consequences of marking credit to market

If you have to mark a credit risk position to market, then:

• You have to fund losses caused by credit spread volatility;
• You have to support the risk of credit spread volatility with some equity; and
• The risk of the position includes the risk of movements in the non-default component in the credit spread.

A non-mark-to-market holder of the same risk does not have these issues. Depending on their precise accounting standard they may have earnings volatility resulting from changes in perceptions of default, but they won’t have volatility resulting from non-default factors, and thus they don’t need as much equity to support the same position. The need for less equity means that a non-MTM credit risk taker will require a lower return than one who has to mark-to-market.

The history of historic cost

Long ago, the existence of multiple ways of accounting for financial instruments made sense. There were liquid (or at least semi-liquid) securities, and these were marked; there were totally illiquid loans, and these were accounted for based on historic cost (with a reserve being taken if the loan was judged to be impaired). Banks had a buy-and-hold strategy in the loan book, so recognising P&L on an historic cost basis made sense, while marking to market was natural for the flow-based trading book. Insurance companies had approaches* that were similar to historic cost: essentially they recognised premiums as they were paid, and reserved for claims that had been incurred but not yet presented.

Over the 1990s, these boundaries became blurred. Credit default swaps and securitisation liquidified banking book credit risk, and some institutions adopted originate-to-distribute strategies, while others were able to take credit risk in unfunded form by writing credit protection.

This meant that an arbitrage became available whereby the same risk could be taken by both mark-to-market players (by buying a trading book security) and non-MTM players (by writing credit protection which did not have to be marked or making a loan).

So how exactly did you take unfunded credit risk without having to mark it?

Several methods were developed to allow insurance companies to take unfunded credit risk without having to mark it to market.

• In the transformer approach, the insurance company would write a contract of insurance to a SPV which then wrote a CDS. Provided that neither the insurer nor the CDS buyer consolidated the SPV, this provided a compound contract that at one end looked like and was accounted for as insurance, and at the other end looked like and was accounted for as a credit default swap.
• In the wrap approach, the insurance company provided a financial guarantee contract on a bond. If the guarantor was AAA-rated (which the large monolines were pre-crisis), this essentially split the bond into a funding component provided by the buyer of the wrapped bond and a risk component, provided by the insurer.

Insurance companies took credit risk in other ways, too, of course, including some mark-to-market ones; we will come back to this shortly.

Why was taking credit risk in unfunded non-MTM form attractive to some insurers?

The insurance business model is, roughly: take risk by writing insurance, receive premiums, invest the premiums, and pay claims when presented. It works well when the value of invested premiums is larger than that of the presented claims. Given this model, some insurers found credit risk attractive: due to the non-default components of the credit spread, it seemed as if they could get paid more to take credit risk than defaults would cost them, and the structuring technology described above allowed them to do this without having to worry about intermediate earnings volatility caused by having to mark to market. The only question in this business model was ‘do you expect ultimate default losses to bigger or smaller than the value of invested premiums?’

Insurance risk models vary significantly from firm to firm, but what they share is a desire to estimate the capital required to support the risk of unexpectedly large claims. In other words, they assumed that the key risk was the risk of bigger-than-expected claims; something that is perfectly reasonable given the insurance accounting model.

Credit risk taking, then, was potentially attractive to insurers for three reasons:

• It could be made to look like a business model they were familiar with (take premiums, invest them, pay claims);
• It could be accounted for as insurance; and
• The capital required to support some forms of credit risk taking, such as writing protection on asset backed securities, was rather small according to their models.

Was insurance accounting a gateway drug?

It is certainly not that case that most credit risk taken by insurers pre-crisis was non-MTM. AIG, for instance, used fair value accounting on most of the contracts it wrote. However I believe that the availability of the non-MTM model in the early 2000s acted as a kind of ‘gateway drug’, getting some insurers into credit risk taking. Without it, the capital required to support credit risk taking would have been higher, and thus the business would have seemed less attractive. Moreover, the earnings volatility potentially created by having to mark to market** would have at least have given pause for thought at a much earlier stage.

To be fair to insurance accounting standards setters, it is hard to see what they could have done differently. Financial guarantee accounting makes some kind of sense where the guarantor is writing a wrap on an entire municipal bond, and there are no reasonable proxies available. The transformer structure, where a transaction is accounted for as insurance at one end and marked to market as CDS at the other, is less defensible. Arguably, though, the transformer SPV is a major part of the issue, and the rules governing when such things are consolidated have been tightened up (as have the details of financial guarantee accounting). One does wonder, though, what the relevant supervisors had in mind given their evident comfort with the types of practice described here.

Conservation of P&L volatility

Many laws in physics say that in any interaction, some property such as momentum or charge is conserved: the total amount of it in the system remains the same. In a certain sense, moving credit risk from an MTM to a non-MTM player violates conservation of risk. A non-MTM party sees less risk in the deal than an MTM party as the volatility of the non-default-related component of the spread has disappeared. Early 2000s structures such as the one we have described facilitated this, and thus allowed the non-default component of the spread to be monetized.

The introduction of CVA made this situation somewhat better. Non-MTM parties do not get the full benefit of their accounting if they have to post collateral based on the mark of the position – at very least they have to fund the collateral, and that is a drain on their liquidity. So many of monoline trades were done without collateral agreements. This in turn meant that once CVA charges were imposed, some of the volatility of the non-default component of the credit spread reappeared as CVA volatility. This risk hadn’t disappeared after all. Perhaps that is the real lesson: if your trade seems to make risk disappear, there’s something wrong with it.

*Obviously a one sentence account glosses over many complexities and jurisdictional differences.

**Of course, being able to use a model to mark means that much of this volatility can be avoided, at least while the asset credit protection has been written on is not obviously impaired.

Posted in: Accounting, Credit, Insurance and Actuarial Practice by David /
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I didn’t catch this, but Jonathan Hopkin did. Julie Finch has the original suggestion in the Observer. Hopkin comments on her article

high earners in Britain receive enormous tax relief on their private pensions, estimated by Richard Murphy to be worth £38 billion per year, about a quarter of the deficit. [Julie] suggests that ‘we should maintain the subsidy, but only if the recipients divert at least a proportion of their funds into infrastructure investments and local authority bonds’.

Sounds good to me. In fact, why stop at that? The subsidy could be tied to the purchase of Treasury bonds at rates close to the rate of inflation. After all, the deficit is at least in part the consequence of saving the value of private investments through state intervention. Financing government borrowing at a reasonable rate seems a fair contribution from those who have benefited so much. This would remove fears of a spike in bond prices, allowing us to plan for an orderly reduction of the deficit over a longer period of time.

Absolutely. This would also have the side effect of reducing asset price bubbles and the inevitable clamour when pensioners lose money on (highly risky) equity investments. How about a requirement to invest a minimum of half of your pension in long-dated linkers?

Posted in: Inflation, Insurance and Actuarial Practice, Pensions, Politics by David /
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A recent paper by Cecchetti et al. The Future of Public Debt has been widely noticed: see for instance here for Ritholtz or here for the Econgrapher. The paper is certainly thought provoking. In particular, it points out that the time bomb of ageing populations is not confined to Japan:

The current expansionary fiscal policy has coincided with rising, and largely unfunded, age-related spending. Driven by the countries’ demographic profiles, the ratio of old-age population to working-age population is projected to rise sharply. Interestingly, this rise is concentrated in countries such as Japan, Spain, Italy and Greece, which are already laden with relatively high debts. Added to population ageing is the problem posed by rising health care costs.

An ageing population who have been promised a lot combined with slower growth and hence less tax income gives a problem. A big problem in some countries, as these promises are simply unaffordable:

What can we conclude? The authors are clear:

fiscal problems facing industrial economies are bigger than suggested by official debt figures that show the implications of the financial crisis on fiscal balances. As frightening as it is to consider public debt increasing to more than 100% of GDP, an even greater danger arises from a rapidly ageing population

Clearly first world governments are not going to let interest service payments get to 10% of GDP without a struggle. That means some of (perhaps all of) reduced pensions and health care, lower public spending, and increased taxation. Reducing the real value of liabilities makes sense too, so expect somewhat higher inflation eventually – but not for a while. Intergenerational wealth transfer is going to become a key political issue in the developed economies, too. There are interesting times ahead…

Posted in: Credit, Economic Theory, Insurance and Actuarial Practice by David /
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The standard argument that credit derivatives are not insurance runs in brief:

• They require no insurable interest;

• They require no proof of loss; and in particular
• The payout is independent of the counterparty

All of this is standard, and goes back to an opinion of Robin Potts. Now, with ill-advised US action to regulate some credit derivatives activity as if it were insurance deferred, there is a new and more comprehensive account of the issues from M. Todd Henderson.

Henderson does a reasonable job, although the case seems a little over-argued to me. In particular, credit derivatives product companies (CDPCs) are much like insurers in financial substance – as was the Financial Products Group of AIG. So arguing from the perspective of the need to regulate insurers not applying to companies engaging in CDS may involve ground that is not firm. Where Henderson is good, though, is pointing out where risk shifting and pooling contracts in other spheres do not constitute insurance. For instance, if I set up a company to sell naked puts to commodities producers, and invest the premium, then I am acting as a pooling and risk shifting enterprise, but not an insurance company. The paper is worth a read if you have an interest in these matters even if it does seem to me a little propagandist.

Update. It is worth pointing out that the ‘insurance’ vs. ‘not insurance’ question is about more than regulation. It also affects accounting – insurers have their own accounting framework which is rather like accrual – and taxation. Given that much of the need to regulate CDS relates to counterparty credit risk, it seems that a much more cost effective fix to the vulnerabilities revealed by AIG is simply to do what we are doing anyway – set up a central clearing and market data reporting entity. Add in a reclassification of financial insurance as a derivative, enforce fair value requirements, and prudent capital requirements, and you would have a reasonably robust regulatory framework without the need to get insurance regulators involved.

Posted in: Credit, Insurance and Actuarial Practice, Legal Risk and Trade Documentation, Regulation by David /
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Felix Salmon discusses some recent JPM research on MBIA:

in a note issued this morning they said that MBIA’s tangible book value is actually negative, to the tune of about -$40 per share.

OK, the full article has some caveats. But the mere fact that a reputable investment bank (if that is not an oxymoron) can suggest that MBIA is insolvent should raise some warning signs about the extended historical fiction that is insurance accounting.

Posted in: Accounting, Insurance and Actuarial Practice, Monoline by David /
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(The fate of the monolines was sealed by the risk they wrote in 2005-2007, so day 1000 is if anything conservative – it takes insurers a long time to die thanks to their accounting and the pay as you go nature of the claims against them.)

In a move so predictable it hardly raises a yawn, Bank of America, Citigroup, JPMorgan and 15 other large financial institutions filed suit on Wednesday against MBIA, claiming the bond insurer reduced its ability to pay policyholders by splitting its business in two.

It is difficult to think of how a monoline could split without generating lawsuits. If x of capital and y of investments support z of risk, and you split z into to pieces, how do you divide x and y? There is not widely agreed answer, so someone is going to think that the credit quality of the piece they end up with a claim against is lower that it should be – and they will sue. Moreover since there are clearly diversification benefits between risks, even if the split is entirely fair, the capital needed for the two pieces is larger than that for the original whole.

The lesson? Agree collateral upfront, based on your marks.

Posted in: Capital and Contingent Instruments, Insurance and Actuarial Practice, Monoline by David /
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Thanks to AIG, the weird and wonderful world of finite reinsurance has come under broader scrutiny recently. (You may recall that a finite reinsurance policy between AIG and Gen Re was the method used to inflate AIG’s earnings in the case that came to the courts in 2008.)

Now, thanks to the Big Picture, further amusing documents have achieved more general publication. I don’t agree with much of the thrust of the post – which frankly contains altogether too much credit derivatives related hysteria. But the extra light on finite reinsurance is welcome.

When is finite reinsurance a valid business tool, and when does it verge on fraud? This is difficult to answer because finite reinsurance is a very sophisticated tool that can be used in myriad ways. But let me illustrate a good and a bad situation.

Good finite reinsurance. Suppose a company has a liability with a known size but uncertain timing. Asbestos-related claims are a commonly cited example: the firms knows it will have to pay workers for past exposure to asbestos, and it can estimate the size of those claims reasonably well, but it does not know when the claims will be presented as the sickness has a long and uncertain gestation period. The uncertainy thus created weighs on the share price, even though the company has every intention of paying and the resources to do so. Therefore it purchases a finite reinsurance policy whereby it pays a premium equal to (roughly) the present value of the expected claims to a large, well capitalised reinsurer. The reinsurer takes two risks: one small (that the claims will be larger than expected: this is unlikely as typically the risks insured under finite schemes have rather little uncertainty in claims); and one larger (that the claims will be presented earlier than expected, and hence the invested premium will not have grown sufficiently for them to make a profit). From this we see that finite schemes are often about transferring timing or investment risk rather than the risk of uncertainty in claims.

Bad finite reinsurance. Consider the effect of the scheme above though. Before the reinsurance, the firm had a known hit to earnings in the future but with uncertain timing. Afterwards, it has a stream of expenses – the premium payment or payments on the policy – but no uncertainty. Earnings have been smoothed. Clearly we can extend that effect more broadly via policies which pay out money in the future for an appearance of risk reduction today (buying surplus for an insurer, i.e. flattering their capital position) but where all of the risk comes back in later years, or via policies which move current profits into later years, smoothing earnings. Accounting rules do not permit you to arbitrarily reserve whatever amount of current earnings you like against some future risk, especially a very unlikely and hard to quantify one, but finite reinsurance policies achieve the same effect.

Finite reinsurance can therefore be used, quasi-legally, to manipulate earnings for many companies. It can also be used to manipulate insurance companies’ capital position. If ever there was an area of finance crying out for better regulation, I’d say it was insurance.

Posted in: Accounting, Insurance and Actuarial Practice by David /
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(HT The Big Picture.)

What is interesting about this is the GIAs. I _think_ that these are GICs, i.e. guarantees of minimum investment returns, sometimes on variable balances. Obviously as rates have fallen, GICs have become more valuable to the holder and riskier to the writer. Insurers have conspicuously underpriced the implied puts in GICs for years, and now it seems that for AIG these have come home to roost.

Posted in: Accounting, Insurance and Actuarial Practice by David /
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I think that someone tried to scam me yesterday. I had gone out for a pint of milk, around 8 in the evening, when a man came up to me. At first glance he seemed well dressed – although the suit wasn’t hand-made and the tie wasn’t silk – and he had a sob story. His wallet had been stolen. He had no money. Could I lend him a tenner to get the train home? Sadly he rather ruined the spiel by clutching a mobile phone, with which he could have presumably have called a friend or work-mate. And the script was rather similar to one I have heard several times before. But what completely ruined it for me was that he claimed to be an actuary. He even showed me his business card, presumably in an attempt to establish his credentials as a trustworthy person. Now, dear reader, if you know what I think of actuaries, you will know that this back-fired.

What happened next? Well, I didn’t steal his mobile. Although I was tempted. But he didn’t get the cash. So the lesson, scam artists of E1, is when you are trying a con, pick a profession that your interlocutor doesn’t think is fundamentally mis-guided.

Posted in: Insurance and Actuarial Practice by David /
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MTM means for course `mark to me’. It appears that AIG has determined the most reliable source of fair values for some transactions is — itself. Think of a number. Wow, the number I just thought of was … the number I was thinking of. I must be right.

I exaggerate of course. Let Bloomberg take up the story:

AIG swaps not covered by the government program include guarantees on $249.9 billion of corporate loans and residential mortgages, most of them made by banks in Europe…
[These swaps] are different because they didn’t insure against losses… they were bought to take advantage of European accounting rules that allow the banks to use the swaps to reduce the capital they’re required to set aside as loss reserves.

The swaps are kept in place only until new accounting rules, known as Basel II, are phased in. Those rules eliminate the ability of financial institutions to reduce the capital they need to set aside by buying swaps.

[AIG has] unwound $95 billion of these regulatory-capital swaps without any losses as of the end of the third quarter. And Gerry Pasciucco, hired from Morgan Stanley on Nov. 12 as interim chief operating officer of AIG’s financial-products subsidiary, said the company continues to “experience early terminations according to our schedule at par.”

As a result, Lewis [AIG risk officer] said, even if the assets underlying the remaining swaps fall in value, AIG isn’t required to mark them to lower market levels.

That’s because, as the insurer said in its third-quarter filing, it “estimates the fair value of these derivatives by considering observable market transactions.” And the only relevant transactions are the swaps AIG has successfully unwound with the European banks, according to the filing.

There is more to trouble an AIG investor, European bank regulators, the SEC, the FED, and AIG’s auditors in this, if it’s true, than you can shake a stick. Here are a few of the issues.

Firstly you would have thought that the Gen Re case had taught AIG that doing transaction purely for regulatory manipulation without risk transfer is a bad idea.

Secondly, what do European bank regulators think of this? (I’ll leave Basel 2 being described as an accounting standard as a signal that this new item may not be entirely reliable. And while we are asking questions, where exactly in Europe hasn’t Basel 2 been implemented yet? And what is a default swap that does not transfer losses, and how exactly does it qualify for capital relief?)

Thirdly, if both the transaction and AIG’s accounting for it are correctly described, why on earth do their auditors, PWC I think, let them get away with this? Hasn’t AIG had enough auditing issues at AIG FP already?

Fourthly does the FED really want an almost 80% state owned company doing this kind of transaction? And accounting for it this way?

Posted in: Accounting, Insurance and Actuarial Practice, Regulation by David /
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Bloomberg has a nice article on one of my favourite pieces of actuarial insanity, guaranteed annuity contracts. The basic story is that life insurance companies wrote long-dated equity index and basket puts in size and didn’t price them properly, because their actuaries didn’t understand derivatives. With the recent market falls, they are beginning to see just quite how stupid an idea this was.

It’s ending in tears. In September, the insurance raters A.M. Best and Fitch moved the life-insurance industry into its negative-outlook column. In October, Moody’s, and Standard & Poor’s did the same. A.M. Best has downgraded 30 life and annuity companies so far this year.

Of course, because all of this is in an insurance wrapper, there is no requirement to mark to market, so investors cannot see the size of the problem.

In the meantime, the industry is proposing to handle its problems the good, old-fashioned, American way: by putting lipstick on its books.

As the value of GMWB [guaranteed minimum withdrawal benefit] annuities tumbles, the carriers are required to raise the reserves they hold against these products, as a way of assuring that consumers will be paid. Raising reserves, however, could starve their working capital at a time when they’re also writing down toxic mortgage assets. The companies say they’re already holding plenty of reserves, so they’re asking the states, which regulate the industry, to loosen the rules.

Astonishingly, some of the state regulators seem sympathetic:

The National Association of Insurance Commissioners will discuss the proposed changes this month. Iowa insurance Commissioner Susan Voss calls some of the reserves “redundant” and suggests that NAIC will go along.

Short now, short in size. It is a very cheap way to get protection on an extended period of low equity markets.

Posted in: Accounting, Insurance and Actuarial Practice by David /
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How should we view Warren Buffett’s short put position? The FT has some comment which clarifies both Buffett’s thinking and the conflict between insurance and capital markets views of risk. It is useful background to my earlier post about this position.

First the facts. Berkshire has sold long dated out of the money (forward) puts on major indices and received premium upfront. These puts are getting closer to the money as the indices concerned fall, giving rise to mark to market losses.

John Gapper’s FT article points out that Buffett is usually thought of as a great investor – and he really is one – but what is less commonly discussed is where the money came from for that investment. The answer is that it is often from writing insurance. That is, Berkshire is a classic insurance company: it writes insurance, receives premiums, and invests them in the attempt to produce a bigger pot of money than is needed to meet claims. It has been highly successful at this.

The two different communities, insurers and derivatives folk, look at risk in entirely different ways. An actuary would ask how like a risk is to be manifest and what it will cost the insurer if it is based on history. A derivatives trader would ask what the market price of the risk is. Thus insurers and investment banks made great trading partners as the insurer will often take risk for far less than the bank thinks it is worth. This is one of the reasons AIG wrote so many default swaps: they thought that they were being well paid for them.

Another point is that for classical insurance risks like catastrophe, auto or terrorism, the accounting for the risk is on the basis of received claims. You don’t take a mark to market hit on the hurricane book if the weather gets worse in the North Atlantic: you only have to provision for the loss when claims are both likely and can be estimated. This is very close to accrual accounting in banks loan books.

Derivatives, though, are different. Here Warren has to mark to market, so Berkshire suffers earnings volatility regardless of whether the puts really will pay out or not, a fact that anyway won’t be known for many years. Why are investors spooked by a mark to market write-down on a derivative with eleven years left to run when they are perfectly unphased by the warming Atlantic, something that could – if it generates more hurricanes like Katrina – devastate Berkshire’s cat book? Investors seem overwhelmed by the risk that they are being forced to look at, yet indifferent to the ones the accounting glosses over. Interesting, isn’t it?

Posted in: Accounting, Insurance and Actuarial Practice by David /
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Felix Salmon has a nice piece on AIG FP’s strategy and why it went so badly wrong.

When AIG wrote protection on CDOs and the like, it got insurance premiums in return, and considered those premiums to essentially be free money, since (according to AIG’s own models, and those of the ratings agencies) the chances of those CDOs defaulting were essentially zero.

…AIG’s biggest mistake was in failing to realize that this business couldn’t scale in the way that most insurance does scale. Most insurance does scale: if you insure a house against fire, for instance, it’s easy to lose much more money than was paid in insurance premiums. But if you insure houses across the country against fire, you’d need a nationwide conflagration in order to lose lots of money.

… The reason AIG’s models said the CDOs couldn’t suffer any losses was that house prices don’t fall in all areas of the country simultaneously. Since AIG was only insuring the last-loss CDO tranches, investors with lower-rated tranches took the risk that prices in Florida, or Arizona, or California might fall. AIG would only lose money if prices fell in all those states at once — which is, of course, exactly what happened.

In other words, AIG’s models assumed default correlation would be low, and that there was a good measure of diversification benefit between the different CDOs it had written protection on. In reality once house prices turned down there was very little diversification, default correlations leaped up, and the mark to market on many of AIG’s contracts turned against them, necessitating the collateral postings that brought the insurer into the welcoming arms of the FED.

Posted in: CDS and Negative Basis, Insurance and Actuarial Practice, Model risk by David /
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The Aleph Blog has a remarkably wrong-headed piece on insurance regulation here, suggesting that federal insurance regulation is a bad thing and that the FED should have let the AIG parent fail.

Some comments. First, the US is the only major economy that does not have a national regulatory framework for insurance. Instead it is regulated at the state level. Some of the states do it well, some less well. Many of them are different. How can it possibly make sense to have over 30 regulatory frameworks for the same product in one country?

Secondly US insurance regulation is a long way behind the curve even in the best states. While the EU is on solvency two, with fairly sophisticated capital modelling, the US framework does not require enough capital for credit risk, which is why the monolines and AIG got into so much trouble in the first place. Their leverage was not effectively constrained by their capital requirements (and in some cases their accounting framework encouraged them to take risks more cheaply than banks would). The U.S. needs to address the arbitrage whereby it is significantly cheaper for some insurance companies to take credit risk than for banks.

Thirdly, letting AIG fail was not a realistic option however much moral hazard its bailout presented. I continue to dislike the bailout. However depriving the banks of hundreds of billions of dollars of protection is simply not sensible at the moment: you would only have to spend the money recapitalising them.

Posted in: Insurance and Actuarial Practice, Regulation by David /
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It has written an awful lot of CDS protection. If it goes down, the contracts accelerate and the banks who bought protection get recovery on the current MTM. Recovery is unlikely to be more than 50 cents on the dollar, and so the protection buyers would suffer large losses. At least a hundred billion, I would estimate, probably more. So you have the choice between letting AIG fail and putting 100B or more into the protection buyers, or giving it another 50B and trying to keep it afloat. That’s a no brainer.

Posted in: Capital and Contingent Instruments, Insurance and Actuarial Practice, Mother of all Bailouts by David /
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Confirming the insurance industry habit of substituting claims adjustment for underwriting diligence, MBIA is suing Countrywide according to Housing Wire:

The breach-of-contract lawsuit, filed in New York State’s Supreme Court, suggested that Countrywide developed a “systematic pattern and practice of abandoning its own guidelines for loan origination,” in effort to inflate its market share during the mortgage-lending boom. MBIA accused Countrywide of knowingly negotiating riskier loans “no matter the cost to borrowers, investors or guarantors like MBIA.”…

Overall, the case involves 10 residential mortgage-backed securitizations of more than $14B in mortgage loans.

This is going to be interesting. On the one hand, it seems obvious that mortgage quality did decline in the last years of the Greenspan boom. But can MBIA really prove that Countrywide abandoned its own loan underwriting standards – rather than simply changing them to adjust to `market conditions’ – and that that was a breach of contract of the financial guarantees? If it can, we are going to see a lot more wriggling from the wrappers, and the lesson from Hollywood Funding – that insurers can’t always be trusted to pay when you think they have written protection – will be driven home to a lot more people.

Posted in: Insurance and Actuarial Practice, Legal Risk and Trade Documentation, Monoline by David /
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According to Bloomberg:

New York State will begin to regulate part of the $62 trillion market for credit-default swaps, Governor David Paterson said.

The state will treat contracts in which the buyer also owns the underlying security as insurance, Paterson said today in a news release.

That’s it then. London always was ahead of New York in structured credit: now, provided we do not do something similarly stupid, we can own this market.

It is worth pointing out, en passant, how successful treating credit derivatives as just another insurance contract has been so far. The largest two firms to adopt that paradigm were MBIA and Ambac. Unless you count AIG of course. Still, New York will still have better looking trucks.

That’s something. But it doesn’t produce jobs for the geeks.

Update. The Economist has a nice article, Guilt by suspicion, about the benefits of derivatives and the mud slung at them. I do think it is worth remembering that the cause of all of this mess was not derivatives, it was mortgages.

Posted in: CDS and Negative Basis, Credit, Insurance and Actuarial Practice by David /
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In what is either a strong buy signal for the market or a strong sell signal on the stock, MBIA has announcing that it was not changing its projection of losses on its mortgage-related exposures. The FT story is here. Yes, they had some bizarre FAS 159 gains (CNN is here and my take on the rules is here): yes, they resumed a share buy-back programme. But ignoring all that, if their actuarial loss estimates for RMBS have not changed, either that is a very useful datapoint on where realised default losses actually will be, or their actuaries are fools and it is time to short the stock again. It will be interesting to see which.

Update. John Dizard has pointed out the possible value in the monolines as a vulture play on the eventual losses on RMBS. I can see the idea, but I’d like to know more about the implied residual value of the monolines given the current equity price. Are they really cheap yet?

Posted in: Fair Value, Insurance and Actuarial Practice, Monoline, Mortgages by David /
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CFO.com has an excellent post on Fair Value accounting. One quote in particular amused me:

James Tisch, who was effectively the sole voice of dissent on the first panel, complained bitterly that fair value accounting required reams of nearly incomprehensible disclosure information and often forced his company to make poor economic choices.

Tisch … said that if insurance companies had to run mark-to-market accounting through their income statements, “[they] would essentially be out of business”

And that, as we have seen with the financial guarantee insurers, is clearly right. But perhaps if the insurers were forced to use fair value, they might deploy less leverage and pay a little more attention to what the market is telling them.

Posted in: Accounting, Fair Value, Insurance and Actuarial Practice by David /
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Yet another story about the travails of the monolines – this time on guaranteed investment contracts – made me think about who is really to blame for the mess these companies are in. It’s the people who made their underwriting decisions: their actuaries. They decided that there was little risk in guaranteeing investment returns for extended periods. They decided writing hundreds of billions of dollars of financial guarantees on ABS was a good risk return tradeoff. For that matter their colleagues in the life companies decided that variable annuity life policies were a good idea. (These policies, like a GIC, guarantee a return on a risky investments so they act a lot like long dated written puts: needless to say, the actuaries did not price them that way. Now that the equity markets are tumbling you can expect to see some life companies getting into distress…)

So perhaps one lesson that shines out of this mess is do not let an actuary price or risk manage a financial contract without help from a professional. They are not certain to screw it up. But the evidence of the last few years suggests that there is a real risk that they might get it very wrong indeed.

Posted in: Insurance and Actuarial Practice, Monoline by David /
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S&P lowered Ambac and MBIA to AA today. They are under review from Moody’s. Fitch, only six months late rather than the year or so of the other two agencies, downgraded them in January. Bill Ackman made another big pot of money. And there’s a nice opportunity opening in zombie monoline runoff…

Posted in: Insurance and Actuarial Practice, Monoline, Ratings by David /
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This is a valid question as we go into any restructuring of the bond insurers, and the answer is more complicated than it appears at first sight. Here are some of the issues.

Many corporate bonds pay interest and final principal – you get coupons for some period, then a return of principal.

A standard CDS on a corporate bond uses a notion of credit event which typically includes default, failure to pay and bankruptcy. If the bond displays a credit event, then the CDS protection buyer stops paying the premium on the CDS and has the right to receive recompense in a short period, perhaps 3 or 5 days. This recompense is either through the right to deliver a bond and receive par (physical settlement) or through the right to receive an estimate of par minus recovery as a cash payment (cash settlement). Some key features include rapid payment, the ability to go short – by purchasing cash settled CDS without owning the bond – and the derivatives (i.e. mark to market) nature of the instrument. Note too that the premium is risky in a standard CDS: if default happens, you stop paying it.

There are insurance policies which behave much like CDS. These are part of a wider class of insurance known as financial guarantee policies. The difference here is that they are legally insurance (and hence have a different legal, accounting, regulatory and tax framework). In particular this is not a mark to market instrument, and in most jurisdictions you have to be an insurance company to write insurance. Note also that insurance typically requires an insurable interest – I cannot profit from buying fire insurance on your house even if it burns down – so if you purchase a financial guarantee policy directly it might not allow you to go short.

The fact that there are two instruments, CDS and financial guarantee policies, which can act much the same way yet have very different accounting should be a matter of shame to the FASB and the IASC.

Another possibility for obtaining protection is a bond wrap. Bond wraps are part of a wider class of insurance policies known as financial guarantee policies. In a bond wrap the policy runs to maturity of the bond, you have to keep paying premium until that date (so the premium is not risky), and the policy writer agrees to make good the scheduled cashflows of the bond should the original bond issuer suffer a credit event. Thus here you get paid on the original schedule, and if there is a credit event you substitute the risk of the issuer for that of the policy writer. Most of the muni policies the monolines have written are in this form. The advantage from their perspective are not only insurance accounting, but also lack of cashflow stress: unlike a CDS you typically have plenty of time to find the cash to make the principal repayment.

With amortising securities the issues become more complex since there is the possibility of a principal and interest payment at each coupon date. You can write standard CDS on amortising securities, but it is also possible to write a pay as you go CDS. This imports bond wrap technology into derivatives, and gives the protection holder the right to demand payments on the original schedule from the CDS writer.

For corporate bonds, amortising or not, matters are fairly straightforward since the failure to receive any cashflow (or at least a material one) is an event of default. For ABS you might not want that feature though: in a typical credit card deal, for instance, there will be a certain level of delinquencies which all parties expect, and if you have a credit event which triggers cash settlement based on default, then many junior ABS would suffer that event in the first month. Moreover in many ABS the collateral prepays, so you do not know when you will get your principal back. This means that to define a CDS or financial guarantee you need to tease out the cashflows each security should get in a given month given the level of prepayments, see what cashflow it actually gets, and define protection based on the difference.

Matters get even more difficult when you have amortising collateral in a CDO but some of the tranches have bullet maturities. Remember too that in some cases the CDO issuance SPV can be technically unable to pay without the CDO collateral having lost value: this can happen in particular due to liquidity risk. Figuring out exactly who pays whom what when something bad happens in a CDO of ABS is sufficiently complex that standard documentation has not been available until recently. Most transactions historically used bespoke documentation, and figuring out exactly which risks were transferred was not a trivial business.

Finally, note that the legal final maturity of ABS is often well beyond the last cashflow date. For a mortgage deal, for instance, it might be 35 years. So a contract which only gives you the right to claim ultimate principal at legal final maturity is like buying protection on a long dated zero coupon bond.

My guess is that most but not all of the monoline’s structured finance business involved taking middle or upper tranche ABS and writing pay as you go style protection on it in the form of a financial guarantee. This has considerable accounting advantages over writing standard bullet CDS, as well as the advantages the monolines enjoy as a result of insurance rather than banking capital. Finally it means that the monolines have relatively little immediate cashflow stress even though their structured finance portfolio would be, on a mark to market basis, highly underwater. None of that means that there is no problem with their business — just that if this is going to be a train wreck, it will be a slow motion one.

In any event we do need to know the answer to this question as it determines the capital needs. If they have written CDS with collateral agreements then the monolines need enough capital to support the mark to market volatility of the trades. If they have just written insurance then they only need enough to support the ultimate realised losses on the portfolio. Those numbers are very different (and it impacts how right Bill Ackman is).

Some people have suggested that one of the villains of the current crisis is mark to market. I don’t agree: mark to market gives one view of the value of a portfolio; insurance accounting another. But certainly having a portfolio of similar risks subject to wildly differing accounting principles in the same legal entity is unhelpful.

Posted in: Accounting, CDS and Negative Basis, Insurance and Actuarial Practice, Monoline by David /
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Bloomberg reports that MBIA is falling again:

MBIA Inc., the giant bond insurer hobbled by the collapse of the subprime market, will cut its dividend 62 percent and raise $1 billion in a sale of notes to boost capital and preserve its AAA credit rating.

The Armonk, New York-based company has declined 81 percent on the New York Stock Exchange in the past 12 months and fell 4.2 percent today after it reported fourth-quarter writedowns and expenses of about $4 billion related to mortgage securities.

Bizarrely Buffett may be willing to help, despite his interest in setting up a competitor:

“We’re looking at multiple ways to participate in the industry,” Ajit Jain, head of Berkshire’s new bond insurer, said today in an interview. Berkshire, based in Omaha, Nebraska, is “looking at ways to support the existing insurers in terms of reinsurance and capital,” he said.

Part of the reason the monolines are in focus is, as Naked Capitalism reports, that Countrywide is rumoured to be close to bankruptcy. If it were to go down, it would trigger a wave of claims on the wraps the monolines have written that they likely could not pay. In this context, why doesn’t Buffett just let his competitors go down? Or has it been gently suggested to him that it would be in the U.S. national interest if he used that spare cash to support the industry? Certainly the NYT’s account of the support Buffett got for setting up his new monoline is bizarre. To pick some of the juicier bits:

Shortly before Thanksgiving, Eric R. Dinallo, the insurance regulator for New York State, did something unusual. He called Warren E. Buffett’s right-hand man on insurance, Ajit Jain, and suggested that he start a new company to insure municipal bonds in New York….

To be a New York company, Berkshire, with its main insurance offices in Stamford, Conn., would technically need to run its new business from offices in New York. But Mr. Dinallo agreed that Berkshire could set up a token office in New York and do most of its work in Connecticut…

For its part, Berkshire agreed to put up $105 million in capital to start, $30 million more than the minimum required by New York. But “to minimize the amount of capital trapped in the entity,” Mr. Jain said, Mr. Dinallo worked out a way for Berkshire to increase its leverage by permitting it to exceed the usual limits on reinsurance, or insurance on the risk the new company acquired.

Posted in: ABS, Insurance and Actuarial Practice, Monoline, Mortgages by David /
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Further to the discussion on Saturday, here are some more thoughts on risks in pensions and who should bear them.

Pensions are complicated things. Consider a typical defined benefit scheme. Here the pensioner has a right to a certain level of pension – often index linked – and the employer has an obligation to provide it. The pension is simply collateral against that obligation.

The first risk, then, is that the employer cannot meet that obligation, typically because they have defaulted, and the pension fund is not adequate. It is this risk that pensions protection legislation is meant to address.

The second risk is that the fund is not judged be adequate to meet the employer’s liability, causing the need to ‘top up’ the fund. I say ‘is not judged to be’ rather than ‘is not’ because the law requires an assessment of the future likelihood of adequacy to be made rather than a spot assessment. Ignoring for a moment the veracity of the assessment – which is questionable – let’s look at how a fund might fail to be sufficient to meet an employer’s liabilities.

There are two moving parts here: the fund assets, and the fund liabilities. Funds are typically invested in some or all of corporate bonds, equities, and inflation linked bonds, plus perhaps other asset classes. Therefore they are typically:

• Short credit spreads (if credit spreads increase, the fund loses money on a MTM basis);
• Short nominal rates (because if rates increase, fixed rate bonds are worth less);
• Long equities; and
• Long CPI inflation (to the extent that they hold inflation-linked assets).

On the liability side the fund is:

• Short longevity (if people live longer it has to pay a pension for longer and hence loses money);
• Short wage inflation (if final salaries increase, so do pensions);
• Short CPI inflation (if inflation increases, so do index-linked pensions);
• Long nominal rates (because future liabilities are discounted back to today along some interest rate curve).

The risk is then that the spread assets – liabilities goes negative. In a DB scheme then the employer has to top up a fund if this spread falls beneath some threshold value, and hence they are short an option on the spread. In a defined contribution (‘DC’) scheme the pensioner bears all the risk and hence they are short this complicated spread cap: if their funds don’t meet their pension expectations, then they have to find the cash for their retirement from somewhere else.

The details of the cap in any particular situation of course depend on how funds are invested, but typically it will have some elements of equity risk, interest rate risk, corporate credit spread risk, and both wage and CPI inflation risk, together with the risk of the comovement of these factors (which you can simplistically think of as correlation risk). Given it is a very long dated instrument – perhaps as much as ninety years for someone entering the workforce now – and very complicated, it is hardly a surprise that it is difficult to know what it is worth.

Note in particular that because we have a long-dated problem, the details of the dynamics of each component of the spread are crucial. It might be reasonable to assume that some of them, such as corporate credit spreads, are mean reverting. This makes the problem easier. For others, notably inflation and equity returns, there seems no reason at all to assume long term mean reversion. This means there is an awful lot of model risk in pensions analysis.

Some dimensions of pensions risk can be minimised: for instance if the scheme holds inflation linked gilts then it can hedged inflation risk and bears no equity risk. However it still have longevity risk, and (absent a liquid longevity swap market anyway) contingent inflation risk (since if longevity increases the fund is mismatched on the duration of its assets vs. its liabilities and hence has inflation term structure risk). Moreover, of course, a low risk pension fund has to be much more comprehensively funded than one that is taking market risk in multiple dimensions (equities, corporate credit, property, alternative investments, …) Finally note that longevity risk is remarked considerably less often than other risk components so it is less visible – but that does not mean that it is not there.

The key policy question, then, in pension is who should bear the risk of underfunding, i.e. who should write the spread cap. Recently, there has been a suggestion that rather than one party bearing all of the risk as in current DB and DC schemes, perhaps it should be shared between employers, employees, perhaps with a far out of the money state backstop*. (See here for a further discussion.)

This is certainly a policy option that could be considered. Pensions policy is bedeviled by a failure to address risk issues openly, not least because most pensioners do not want to face the harsh reality that either a pension has significant risk or it is extremely costly to fund. Education is needed to address this point. Once we are ready for the debate, though, I would suggest there is room for a creative sharing of risk. There are no easy options here, not least because of the considerable uncertainty in estimating the size of the risk. But the problem is hard enough without artificially restricting the domain of possible solutions.

*One issue not addressed here is the use of DC schemes to reduce employer contributions. DC does not imply lesser employer contributions and legislation could (and probably should) stop employers using DC as a way of reducing their funding obligations.

Posted in: Inflation, Insurance and Actuarial Practice, Pensions by David /
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Here’s what an actuary used to do.

Unsurprisingly that strategy didn’t work that well which is why we have a pensions crisis (as I discussed earlier: see here or here). The latest in this slow motion train wreck is that UK life insurers have finally woken up to the continuing improvements in longevity and are now shoring up their reserves, again, to account for this.

Over the past hundred years, life expectancy in the UK has increased by four months every 10 years. Now all we need is for insurers to start to appreciate that they are not just short longevity but they are also short longevity vol…

Posted in: Insurance and Actuarial Practice, Pensions by David /
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There is a very nice article on Accrued Interest summarising the muni market. It helpfully discusses who the muni issuers are, the difference between general obligations and revenue bonds, muni default rates, and the role of the monolines in wrapping muni bonds. What we need next would be a summary of the tax games in muni land…

Posted in: Insurance and Actuarial Practice, Monoline by David /
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Goldie has announced that it will publish a mortality index, presumably to stimulate growth in the mortality swap business. Insurance-linked capital markets products have been around the market for a while without really catching on – I remember being told that mortality swaps were the new credit derivatives – but this might stimulate the market a little. All the same, I’d want to be sure I wasn’t one of the 46,000 odd individuals in the index just in case. Getting between Goldie and an index fixing might just be bad for your health…

Posted in: Insurance and Actuarial Practice by David /
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One of the murkier parts of the reinsurance world is finite reinsurance. Even finding a good definition is difficult. But here, rather than surveying the whole topic, I want to discuss one particular application, namely hedging timing risk.

The typical situation this arises is where there either may or will certainly be claims on an insurance policy over an extended period, but their timing is uncertain and their maximum size is bounded. Suppose for instance we know that over the next ten years we will very likely have to pay out claims of £10M, but we do not know when these claims will be presented. This risk can cause significant earnings volatility: in years with no claims, our earnings look great, but if £8M or £9M of the £10M arrive all in one year, things will look less good for that year.

This earnings volatility can be hedged (for a price). Typically we transfer some assets, say £8M worth, to a reinsurer: these assets are invested. Simultaneously they write us a reinsurance policy capped at £10M on the risk, and receive a small premium to be thought of as an asset management fee. If claims arrive very early in the policy the reinsurer can lose money as the £8M will probably not have grown to £10M in the first couple of years. If the claims happen late, they make money as the assets will have grown to be worth more than £10M over eight or nine years if prudently managed. The reinsurer therefore takes some timing risk and some investment performance risk, but not much. It is a very large very well capitalised entity so it can handle the earning volatility much better than the ceding insurer.

There is even the possibility of passing some upside of good investment management and/or good claims management back to the ceding insurer via an experience account: for instance if the £8M has grown to £12M before claims of £9M leaving £3M at the end of ten years, then this could be split 50/50 between the reinsurer and the ceding insurer. With careful structuring this can mean that it is possible to transfer very little risk with a finite reinsurance policy yet achieve the desired aim of smoothing earnings, i.e. an accounting arbitrage.

This kind of technology emphasises that insurance can act as a form of capital. Without the policy, the ceding insurer would have to support the earnings volatility with equity. With it in place, capital requirements are reduced. The reinsurer is better placed to take the timing risk than the primary insurer and hence a deal is possible which makes sense for both parties.

Posted in: Insurance and Actuarial Practice by David /
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