Monday, July 8, 2019

And Now Comes Libra

No surprise? Facebook leads the charge to establish a new cryptocurrency
In June, Facebook took yet another step to show its digital dominance, while presuming it has sufficiently managed a batch of issues it has encountered in recent years (issues like privacy, data accumulation, data exploitation, and the call from politicians and editorial writers that it should be broken up). 

Facebook, after leaks to the public, announced the creation of a new digital coin, Libra. Instead of observing from the sidelines the fuss and fury of Bitcoin, Ether, Blockchains, and the ferocious volatility in cryptocurrencies, it decided to join the circus by helping to create its own. 

Right away, to attract attention and offer comfort to Facebook followers who might buy (or invest in) the coin, it presented a different approach. 

The Libra coin, unlike other cryptocurrencies, will have value tied to a basket of bank deposits and government securities in different currencies. Hence, unlike Bitcoin, the underlying market value of Libra will be tied less to emotional and sometimes irrational supply-demand dynamics for the cryptocurrency and more tied to the value of the basket.

But before we understand the potential value and usefulness of the coin, why is Facebook doing this in the first place? Or why is Facebook leading the charge?

In almost none of the announcements has Facebook explained a profit motive, an opportunity to increase long-term revenues and expand into businesses beyond social networking--a strategy that might appeal to long-term shareholders.

But it's not an unusual ploy for large technology companies. They can't stand still; they must do research and invest in the next generation of products/services, because old products die, fade out or must evolve. Facebook the social network may one day reach a top limit in how many billions of accounts it has in place. Hence, the company, in amoeba-like fashion, ventures in many directions. A popular ploy, until now, has been to acquire smaller competing or complementary ventures and experiment with them until they contribute to growth (or they don't) (e.g., Instagram, WhatsApp, etc.). 

Another popular big-tech strategy is to step beyond comfortable grounds and do something radically different and take advantage of being big:  Amazon acquires Whole Foods and experiments with drones. Google introduces a smart phone and contemplates driver-less cars.   

Indeed Facebook, not even two decades old, is big today. It generated over $55 billion in revenues in 2018, resulting in $22 billion in net income. Operating costs are well-managed, sufficient enough for it to spend over $10 billion in research and develop last year (a few dollars of which likely resulted in the Libra venture). 

At this point, despite public-reputation woes and everybody's concerns about Facebook being too all-knowing and too powerful, the company by 2019 is generating about $7-9 billion a quarter in new operating cash flow. That helps explain why over $40 billion of cash and cash-equivalents sit on the balance sheet--cash it could give back to shareholders or cash it will likely use to fund new ventures or non-social-network growth. It's cash, too, it has to shoulder it from possible privacy-related settlements and lawsuits or to fund the promised investments in systems to ensure it has the privacy issue under control.

And now comes Libra. 

In the aftermath of the announcement, critics have shared their views. (Nobel laureate and Columbia economics professor Joseph Stiglitz in late June wrote an essay lampooning it. New York Times op-ed writers have weighed in quickly.) Tech-industry watchers and market analysts have scrutinized it. 

As the coin is unveiled and the system is implemented, there are questions that require answers and issues that must be addressed:

1. What will be Facebook's stated objective to account users, expected users of the digital coin, shareholders and government regulators vs. any underlying, unspoken goals (e.g., increase in account users, increase in site clicks and volume, diversify revenue sources, expand into new markets and regions, etc.)?

Will it aggressively seek to make money from this activity or present itself as a "utility"? Shareholders will question the company's willingness to step into a non-profit, utility role unless there are other expansive, important social benefits.

Initially Facebook has announced the Libra initiative will be managed through its Calibra subsidiary and Libra business operations will be separate from all other activities. The same subsidiary will be a member of the "Libra Association," which will oversee coin operations and the Blockchain. 

2. Will it be able to extract and exploit data (metrics, trends, numbers, account activity, etc.) from this line of business for purpose in the core business (increase account activity and account users to attract more numbers and more effective digital advertising)?

For now, Facebook contends data culled and aggregated from Libra will be segregated and not used by the social-network, digital-advertising business model.  But Facebook management will certainly need to show and prove how the separation will be enforced. 

3. Will it be able to explain honestly and openly the advantages of its currency vs. other cryptocurrencies vs. government-supervised country currencies? What are such advantages?

Will there be vivid, significant advantages in its payment system vs. what exists around the world today? The company and some observers say participants around the world will welcome a system of global payments (among individuals, companies, and institutions) that is cheaper and quicker, embraces technology fully in various ways (mobile payments, etc.), and not vulnerable to cyberthreats or information leakage. 

Facebook also contends the system will permit populations not able to have bank accounts to establish accounts and move money in ways they can't do so today. 

4. How will regulators intervene? 

When the new idea of "ICOs" (initial public offerings of new companies by issuing digital coins instead of stock and, therefore, bypassing regulators and investment bank underwriters in the process) sprouted, government regulators (the SEC in the U.S. notably) opined and offered public statements soon afterward. They explained situations ICO activity would be stepping out of beyond into realms of illegality and rationalized how the SEC must be involved. 

In Libra's case, regulators will step up to review, examine and opine--especially if there is any indication that users (including individuals) would be deceived, exploited or disadvantaged in hurtful ways. As a vast payments system, it will justify intervention because of potential impact on financial markets and the global financial system.

For now, Facebook states the organization structure will be under the umbrella of a Libra Association (including other known companies like Mastercard, Uber, eBay, PayPal and Visa). Hence, it won't act alone to determine the rules and requirements of the system. The early members of the association will make cash investments to cover initial operating costs to get the system started (technology, administration, and legal expenses, e.g.). Governance will include other corporate parties, none of which are (to date) sovereign government entities (central banks, government agencies, etc.).

Just like familiar cryptocurrencies, BlockChain transactions (or Digital Ledger Technology) will be under surveillance and confirmation by designated "miners" (participants who confirm transactions on behalf of all other participants and who earn a new coin (or commission or fee) for serving in the role). The Libra Association will define how miners will be compensated. 

5. Will the currency be subject to vast swings in value, unexpected and intolerable volatility? 

Perhaps not, if it is possible that owners of Libra will 

(a) know the value will be tied to a basket of well-known, government-sanctioned global securities in several currencies and 

(b) know any holder of the currency can cash out within a reasonable time (a few days?) from the sale of low-risk sovereign securities. 

In some ways, the set-up of Libra can be viewed like an open-ended mutual fund (or an "Exchange-Traded Fund" (ETF)). Libra coin holders can use Libra units for payments with other users and can choose to cash out into dollars or other currencies within a short time period. 

Like an ETF, Libra coin holders can acquire and deliver among themselves. Like a mutual fund, Libra coin holders can require the Association to cash out securities to redeem units in cash. 

Libra owners will have claim on a large pool of deposits and sovereign securities (including U.S. Treasury securities), but not as a source for an investment return. Interest income from the Treasury pool (after other operating costs) will accrue (at least for now) to "miners" and to members of the association. (In a traditional mutual fund, the interest income, of course, accrues to investors who own fund units.) 

Libra "value" will be a function of the value of the securities basket, which in theory should not fluctuate significantly. (Within the basket, if the dollar depreciates, then the Euro or the Yen might appreciate.) The intrinsic value of the basket could be updated daily. 

Because the system appears to look somewhat like a mutual fund with large numbers of purchasers of "units," U.S. regulator might have a convenient path to show the coin must be regulated. If we don the regulatory cap, we might deduce what regulators will expect to see. They could argue: 

(a) "Investors" or users of the coin will require various forms of investor protection. 

(b) Investor-users must be informed at all times of the value of the underlying securities that back the coin and that value should include a margin or cushion above the value of the coin outstanding. 

(c) Regulators should, therefore, be permitted to review the Digital Ledger and exclude undesirable participants and approve who will act in the role of "miners." 

(d) Regulators may require the "association" establish a reserve to ensure that losses from investments in Treasuries (from interest-rate swings) will not result in losses in value of Libra. 

(e) Regulators may require the “association” to increase its commitment to purchase a minimum amount of the coin (“skin in the game” notion). And they may stipulate that if the organizers and administrators of the system do not perform duties, income or compensation should accrue to coin holders. 

(f) Regulators, of course, will also probe for concerns about money-laundering and suspicious activity and will find a way to force Libra organizers to comply with bank-secrecy rules financial institutions must comply with today. 

(g) Regulators, central bankers and politicians will argue that if the system proves to have exceptional influence on global payments and the financial system, there will be systemic risk, which must be supervised. (Could Facebook and the association one day find itself designated a "Significantly Important Financial Institution"--especially if total coin value exceeds, say, $500 billion?)

Because the “association” will be entitled to interest income from the Treasury pool, there is money to be made. That will be tied to volume. Therefore, Facebook and its association cohorts will likely seek to promote the advantages of usage of the coin. In this case, it’s not about the number of account users, but also about the magnitude of coin each user is willing to buy.

Facebook promises Libra and the social network will operate separately. No doubt, however, the social-network users will be subject to advertising from and tie-ins to Libra. 

Facebook announced the project before it was ready, because of reported leaks. The implementation is still a year or two away. What wasn’t leaked (at least not yet) was projections of long-term earnings and value that could accrue to the company as a result of this expansion into a new venture. Few will believe this is primarily a venture in social justice and empowerment for the populations that don't have access to the banking system. 

Tracy Williams 

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Wednesday, May 1, 2019

Jamie Gets the Last Word for 2018

When Jamie Dimon pens his annual letter to shareholders, the market listens, reads and interprets what's on his mind 
Warren Buffet's annual letter to shareholders is legendary in financial circles.  The messages in the letters extend beyond a review of Bershire Hathaway performance. Over time they became annual seminars in investment analysis.  Reading batches of his letters from over the past two decades could comprise a business school course in evaluating investment performance--not to mention an occasional insightful analysis of accounting rules and financial derivatives.

Over the past 10 years in banking, the annual letter scripted by JPMorgan Chase CEO Jamie Dimon has become the awaited annual address to the financial industry. In years past with customary candor, Dimon has explained the benefits and drawbacks of bank regulation, painstakingly rationalized the bank's dividend-payout and stock-buyback programs, and has dissected the U.S. economy's prospects.

Dimon's 2019 letter was released in April. As he has done in previous years, he took the opportunity to analyze important issues in the financial services industry after he had a chance to applaud JPMorgan Chase's solid results in 2018 across the board.

What's on his mind in 2019? What's the last word for closing out 2018?

Dimon used sidebars to make remarks about inactions and ineffectiveness of government--including excess regulation in financial services, daunting health care costs, and deplorable U.S. public infrastructure (bridges, roads and tunnels that, he says, have become a national embarrassment).

But because he runs a bank, he won't hesitate to evaluate the global financial system, what banks do well, what they need to do going forward, and how regulation too often gets in the way. Much of his 2018 oratory on the banking system is an update on previous years' remarks; he's just now armed with more data to back him, better analysis of costs and benefits, and more heft from running an even larger, better capitalized financial institution. 

Like investment-guru Buffet, Dimon assesses performance (of the bank as a whole and of business units) based on returns on book equity, or return on capital deployed. More specifically, the bank focuses on return on tangible equity (after subtracting out goodwill and intangible assets).  Business units have capital allocated to them from upstair, and senior manager assesses how effectively they use the capital. Otherwise, the bank may choose to redeploy that capital into other businesses or decide whether to "give" that capital back to shareholders, who might invest it better elsewhere. 

Bank management assigns capital to business units based on operating needs, but also based on assessments of worst-case risks. Because shareholders have expectations for returns and performance, bank management holds each business line to similar expectations for returns on this risk-based capial--while managing the same risks banks take on to conduct these banking activities.

Year after year, in his letters to shareholders, Dimon explains and reviews returns on capital and rationalizes when the bank is better off permitting shareholders to get back their capital and do their own thing with it. This year he got to boast the bank's 2018 return on tangible capital leaped to 17% last year.

When it's time to drift into the gory details of accounting guidelines and requirements, Dimon doesn't mind. He embraces the challenge to explain arcane rules to the general public. This year he scolded the profession in inconsistencies of balance-sheet reporting. These are technical nuances that sometimes fascinate (or bewilder) Dimon, but significant enough to gain his attention because the impact in reporting may be, for JPMorgan Chase, in the billions, not in the thousands. 

Why are all the costs (today, tomorrow and long term) shown upfront in some products (like credit cards) but not in others? Why are all the revenues (today and in the futures) shown upfront in some activities (like mortgage servicing) but not in others (like other cash management services)? "Accounting can easily make people do silly things," he wrote, while warning financial analysts to be careful when reviewing bank business activities and product and service costs.

When it's time to assess bank regulation, Dimon explains where it works and describes where it's absurd. And he doesn't buffer his views with diplomatic language. For the past several years, he seems to speak for other bank leaders who (a) might not want to offend Washington bank supervisors or (b) who may not be as intimately familiar with Dodd-Frank rules as he is.

The Federal Reserve annual stress test and regulators designating JPMorgan as a bank "too big to fail" (or a globally significantly important bank) particularly irk him. There is too much "arbitrariness" in the test, he says.  The extra capital requirements that come with being "too big" are based on Federal Reserve Bank criteria and should be "risk-adjusted," he explains, based on factors that contribute to the bank being too big and based on how a bank prudently manages such big risks. 

As he has done in previous years, he questions why banks must maintain capital for operational risks, when those risks are already addressed addressed when a bank quantifies credit and market risks.  JPMorgan has about $40 billion in operational-risk capital requirements, much of which is tied to inherited risks from its acquisitions of Washington Mutual and Bear Stearns and risks that have, in  practice, disappeared as the bank vastly restructured those units. 

Volumes of books and analyses have been written on the financial crisis and the demise of Lehman and Bear Stearns: What caused it? What triggered it? How could it have been averted? The 10-year anniversary of the Lehman and Bear Stearns failures prompted Dimon to review that period in the context of today's bank regulation. 

Dimon explains how Lehman, Bear Stearns and AIG Financial Products might have survived under current Basel III and Dodd-Frank Rules.  (Lehman and Bear Stearns, if they had survived would likely have been consolidated banking organizations, subject to the rules enforced by the Federal Reserve.) The same institutions would have been subject to today's tough minimum liquidity rules and limits on balance-sheet leverage. 

Dimon points out big banks today must also maintain a fourth layer of capital cushion called "T-LAC" (unsecured, long-term debt subordinated to deposits, or "Total Loss-Absorbing Capacity"). 
If Lehman's long-term debt had been treated as a T-LAC capital-like cushion, then the firm would have had a capital base of over $130 billion, not less than $20 billion. T-LAC rules today would have pushed bank supervisors to convert $120 billion of debt into capital, a capital cushion that would have permitted Lehman to get through the crisis.

He has a long list of other laments or "things to discuss:"

The capital requirements for mortgage lending and exposures are too onerous, or they don't grant relief for banks that book well-structured, lower-risk loans. Regulation requires banks to maintain capital for worst-case risks of losses in the mortgage portfolio. Dimon argues that all mortgages aren't the same. 

Along the way, he expressed frustration the bank must comply with over 3,000 federal and state rules just to stay in the mortgage business, enough frustration to cause the bank to question its commitment to the business. 

He acknowledged the criticism levied at many financial institutions and corporates after the reductions in tax rates from last year's new tax legislation. New tax laws had a favorable impact on income, including JPMorgan Chase's 2018 earnings ($33 billion in net income last year). Critics observed many institutions didn't reinvest the extra gains, but used them to reward shareholders with higher dividends and share buy-backs. Dimon counters the gains and possible reinvestments (in loan growth at a bank) should be measured over time. 

A "fortress balance sheet" is a favorite Dimon term for a long time.  He referred to this objective long before the crisis.   A fortress balance for a big bank often means the bank is well-capitalized and isn't vulnerable to unexpected in the loan portfolio and in trading.  A fortress balance sheet means bank has substantial cash and liquid securities to respond to nervous institutional depositors or other short-term lenders. In 2019, the balance sheet has climbed above $2.4 trillion in total assets, but rising levels of capital (over $250 billion in book equity) support a growing loan portfolio that now tops $900 billion. 

He refers to the fortress balance sheet in the latest later, and it may be the title of the inevitable book he writes to reflect on his long career in banking when his days are done. 

Tracy Williams

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Friday, March 15, 2019

Easing Up on Stress Tests

Big banks operating in the U.S. might be able to stress out less over regulatory stress tests
The tide had already begun to turn in the past two years.  Bank regulators in the U.S. had begun to ease on the toughest aspects of bank regulation. 

And in Feb., 2019, the Federal Reserve in the U.S. amended some of the rules, requirements and expectations of stress tests administered to big banks after it had significantly changed requirements in May, 2018, with amendments to U.S. Dodd-Frank regulation.  

In just the past two years, there are likely a hundred or so banks around the country quietly applauding such changes in stress-test requirements.   In 2019, the Federal Reserve didn't abolish stress tests; it modified requirements by applying less pressure on banks to prove they will have substantial amounts of capital during prolonged periods of stress.  

The stress tests for big banks still exist. The 2018 amendments to Dodd-Frank granted relief to medium-size banks: They are no longer subject to regulatory stress testing, although they should conduct them on their own. 

The tests for the big banks (based on asset size) are administered and run by regulators using regulators' own models and scenarios.  And big banks must still seek to pass the tests. In the latest episode of changing bank regulations, regulators promised not to apply hard pass-fail rules to the "qualitative" phases of the stress tests, the rules that make judgment calls on how banks assess whether future capital levels will be sufficient as they growth their businesses. 

Stress tests of all kinds and conducted in any manner, based on assumptions and models to show how a bank would endure a period of systemic and economic stress, are still important.  Dodd-Frank II permitted fewer banks to be subject to the Federal Reserve-administered tests. But bank regulators still expect banks to run their own tests and submit results to supervisors.  Banks don't mind it when they manage their own tests, using their data and devising their own models.  They become concerned if they are subject to tests based on others' models, especially when the details of such models are not widely available. 

The Federal Reserve version of stress testing assumes big banks will be subject to a nine-quarter period of an macro-economic downturn (adverse case, severely adverse case, etc.). The regulator performs calculations of how each big bank will perform under the scenario.  In most cases, banks will amass big losses.  The regulator doesn't guess at the losses; it calculates them as precisely as possible. It determines whether the bank under review has sufficient capital to withstand the calculated losses and meet conventional capital requirements under Basel III and U.S. Dodd-Frank rules. 

In banking (whether for regulators or for ongoing internal risk management), there are numerous kinds of stress tests:  Stress tests for loan portfolios; stress tests for trading positions and investment portfolios; stress tests focusing on liquidity, funding and deposits; stress tests for operational risks (especially related to business continuity and cybersecurity), and stress tests related to country and political risks. 

There is scenario-testing, as well:  What happens to the loan book and deposits when interest rates rise or fall by 100 basis points? 200 basis points? What happens to trading positions when interest rates rise or equity markets fall by a certain percentage? What happens in trading activity when trading counterparties default or can't meet trading terms? What happens when the value of collateral in loan exposures or trading positions declines suddenly? The scenarios are countless in number. The bigger banks run models that look at thousands of variables and scenarios. 

Most banks are well-equipped to develop the required sophisticated models to quantify such risks--whether the risks are overnight or are prolonged over a two-year period. They also develop models with the understanding that bank supervisors will have chances to review model integrity and second-guess the results.  (Models are "back-tested" to evaluate whether they successfully predicted the amount of worst-case losses.)

Stress tests provide comfort for bank risk managers, bank investors and even regulators. They permit the bank to identify shortfalls in risk management, over-exposed business activities (in the loan book or in trading positions), and single out business units that aren't bringing in the rewards for the risks they absorb.  They also help banks determine how much capital is necessary for today's balance sheet and for balance sheets in the periods to come. Stress tests contribute to bank decisions about whether they can increase dividend payouts or buy back shares. 

Risk management in banking ultimately leads to the question of whether there are sufficient amounts of capital to absorb identifiable and unforeseen, hidden risks. Capital absorbs losses and prevents losses for creditors, depositors, trading counterparties, and ultimately central governments and deposit-insurance schemes that may feel the need to bail out failing banks.  

Regulators obsess over capital adequacy. Banks obsess over calculating optimal capital levels.  They want to make sure they have capital for today's operating environment and capital to pass tests. They embrace having excess amounts of capital, but they also don't want too much capital.  Too much capital, they reason, implies wasted amounts of capital.  They rationalize increased dividends or buy-back programs if there is excess beyond excess.  

Stress tests, therefore, help regulators and banks in these calculations of what is the right amount of capital on an ongoing basis.  

In the past year, the Federal Reserve reaffirmed the value of stress testing. But they provided relief for small banks (by not subjecting them to regulators' versions of the tests) and eased up on the pass-fail requirements for big banks. 

Ease up or not, the last thing bank supervisors want is for big banks to learn how to mastermind or "game" the regulatory stress-test model to permit them to pass stress tests without difficulty. 

Tracy Williams 

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