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Thoughts & Comments
The Geithner Plan: Where's the Beef?
It's short on specifics, and fails to address the most fundamental problem of all: mark-to-market accounting.

Gary Townsend
Posted 02/11/2009
Hill-Townsend Capital
gary.twnsnd@gmail.com

Treasury Secretary Geithner did no one any favors yesterday when he served up an all-bun bank-stabilization plan; it lacks essential details and sufficient scope. Judging from the market’s reaction, it won’t likely have the effect the Geithner intends. Thus did the administration waste an opportunity to improve market confidence.  And Geithner’s presentation skills make Henry Paulson’s look smooth by comparison.  Is Geithner enough of a politician to be a successful Treasury Secretary?

Clearly, much of the “plan” has yet to gel.  With regard to the private-public fund, for instance, no analysis is possible.  Stress testing banks that seek additional public assistance isn’t a plan, it’s a technique--and not a very reliable one, at that.  There’s no aggregator bank, or asset-guarantee program, either. Where, indeed, is the beef?  

Worse, if any imaginative thinking is going on at Treasury, it must have been smothered.  Why, for instance, no mention of mark-to-market accounting for illiquid and hard-to-value investments?  As I’ve argued here before, pricing issues are the centerpiece of the whole debate. The original TARP and now the aggregator good/bad bank stumbled on the issue.  A consensus has developed that FAS 157 results in unrealistic valuations, even as it creates very real capital adequacy and solvency problems in banks, insurers, and others.  For example, the Bank of New York Mellon reported that in the fourth quarter, it wrote down its $5 billion investment portfolio of Alt-A residential MBS by $1.4 billion, or about 25%.  If the bank had accounted for the securities as loans, it estimates these same assets would have been impaired only $208 million, just 4% of the portfolio’s face value. The difference between the two accounting treatments: more than $1 billion.

One Alt-A MBS expert, Thomas Patrick, chairman of New Vernon Capital and a former Merrill Lynch vice chairman, calls mark-to-market accounting a “swamp” in this environment, an “accounting fiction” better reflecting the “financial desperation of sellers than the value of the securities sold.” 

 In 3,700 mortgage securitizations he examined, Patrick found that of $1.4 trillion in Alt-A mortgages, $948 billion were current on interest and principal, while $452 billion were delinquent more than 30 days.   Further, banks carried the performing mortgages at an average 50% of par.  Patrick observes that if owned directly as loans, the banks would carry the mortgages closer to par.  He concludes that the mark-to-market fiction has created enormous financial difficulties.

Patrick proposes that these securities be dismantled.  Banks would be allowed to rebook performing mortgages as loans at par less appropriate reserves.  Accounting gains would absorb remaining losses in the non-performing mortgages. 

Similarly, Dutch banking authorities evaluated a $39 billion portfolio of Alt-A MBS owned by ING and marked-to-market at 65% of par.  They subjected the cash flows of the 600,000 loans comprising the securities to severe stresses (principal assumptions were another 10% decline in home prices, and a 50% decline from peak prices in Florida and California) and concluded that the bonds were likely to return 90% of their original value. 

There are many causes of the current troubles, but the solution set has to include changes in the absurd mark-to-market accounting rules.  So far, we’ve seen few fully formed solutions coming from the new administration, while creative and imaginative private sector approaches fall on deaf ears.

What do you think? Let me know! 

Related:

The "Aggregator" Bank: A Good Idea, Depending On . . . . 

Mark-to-Market Insanity


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KC Kid Posted On 2/11/2009 2:54:35 PM

Excellent article Gary. It is very disappointing! The mark to market tail wags the banking dog. It continues to amaze me that so few understand the value of marking to a GOOD model in order to engender stability as opposed to embracing the costly wild swings fostered by the manic/depressive nature of Mr. Market. Marking to a good more static model with reasonable assumptions tends to break up the positive feedback (destabilizing) loop introduced by the downward-reinforcing mark to market function when combined with the resulting forced capital raises. Everyone should understand by now that both markets and models can be grossly inaccurate depending upon the assumptions. However, much of the emotion can be taken out of models if the rules are appropriate. In contrast Mr. Market will very often be highly emotional (overpricing or under pricing) in the short run. Thus, holding period is one of the main keys in determining a reasonable price. If I'm holding for long-term cash flow and it is currently impaired by 10% then I should probably take a roughly 10% balance sheet hit not the 30, 40, 60, or 90% hit set by a thin and jittery market. On the other hand if I absolutely positively have to sell today then I'll probably have to take the big hit to my balance sheet. Either way the stock market can decide what it thinks of my decision as a banker. Thankfully I'm not a banker although I have great respect for the good ones. The government can apparently change this huge write-down difference with a simple rule change rather than spending trillions of taxpayer dollars. And then FASB really should recruit some good control system engineers/scientists from NASA or industry who fully understand the nature of feedback loops and their impact upon the stability of dynamic systems. This could help save us from another potentially disastrous positive feedback loop implementation. I hear some refer to procyclical (simply defined as positive correlation with

KC Kid Posted On 2/11/2009 3:02:30 PM

I hear some refer to procyclical (simply defined as positive correlation with or without a feedback element) as negative feedback. Control engineers all understand feedback systems very well and they know that negative feedback generally is stabilizing while positive feedback (reinforcing current direction whether upward or downward) can be extremely de-stabilizing. FAS 157 clearly introduced a downward moving positive feedback loop (procyclical feedback element) with the help of capital raise requirements, the naturally leveraged nature of banking, ultra short ETFs like SKF, and no uptick rule. Obviously bad decisions by bankers, politicians, and others sure didn’t help. If we'd rather spend trillions of taxpayer’s dollars to maintain our naively stubborn "the market is always right" belief then we’ll be cutting off our noses to spite our faces. It should be much cheaper and easier to simply send M2M to the trash bin of failed experiments for what I think would be the second time in the last 100 years. FASB didn't do their homework on this rule since history, basic observations, and expert advice from dynamic systems experts all could have helped them foresee the problems. If the market is always right & the universal answer then why do we see so many bubbles from tulip bulb mania to Y2K to the recent oil bubble, housing bubble, etc. The market is only right if I absolutely positively have to buy or sell today. We really need to introduce more adjustable negative feedback elements to improve the stability to our dynamic banking system and probably the economy as well. We need system-feedback watchdogs with very short tails. From November 2007 when FAS 157 became a requirement the market started down. One thing that does bother me, however, is that I don't hear many bankers defending their questionable assets. If I thought the market was giving me a raw deal I’d be out there vigorously defending myself. Maybe we’ll hear some of that today. Other

Idon'thaveapseudonym Posted On 2/11/2009 4:18:09 PM

Bravo. Why didn't anybody think of this before? After all, these MBS consist of loans, and no on [yet] is panicking the way they are with securities. If we deconstruct to a level where there is an accepted methodology for determining impairment, good sense is more likely to prevail. Even if the total security can't be deconstructed, at least there is greater transparency of the parts, and the % of good loans can be identified and rebooked. The sludge at the bottom can be addressed by a different segment of investors. My question then is about the mechanics of the workout process. Are we dealing with aggregated loans in the form of MBS because of the difficulty of the analysis, or because someone out there is just too lazy?

Tad Gage Posted On 2/11/2009 5:54:34 PM

The mark to market connundrum was even pointed out by the big bankers "on trial" in the congressional hearings. Even if a security is safe, sound and solid, how can you responsibly mark to a currently illiquid investment, or perhaps one where the only comps available are related to fire sales? The concept is noble, and the accountants are so terrified that they are marking prices at whatever they can find. But does that do justice to the true long-term value of certain investments? These noncash impairments are offering a capital adequacy belly-blow to banks holding solid securities that have tanked along with everything in the marketplace. One size fits all nevver worked in retail, and it certainly isn't working now. The losers are banks holding solid non-government securities, whose prize fish are caught up in the same crab pot as banks with worthless investments. Is anyone listening?

ACEMAN Posted On 2/11/2009 7:03:08 PM

While it is true that there are all sorts of accounting tricks associated with mark to market the other side of this sleazy coin is mark to fair value. The problem for both accounting tricks is the question of who is doing the valuation and if they are bogus estimates and selling or transferring the toxic assets by fair market value and accounting for an instant gain the so-called suppressed profits created as a result of initially accounting for the toxic assets at far less than their marked up fair market value. Who then does the valuing and what regulator is going to audit a pool of MBS that might contain a low percentage of toxic assets but still have some highly rated ones. That is why it sounds counter intuitive that a toxic asset should provide a windfall profit, but, in fact it does!

Tombob1 Posted On 2/11/2009 7:57:22 PM

If there r buyers &sellers u have a MIT what is the problem.

KC Kid Posted On 2/11/2009 9:32:35 PM

Very well stated Tad Gage.

TeeKee Posted On 2/11/2009 11:37:11 PM

The simple rule is this: Spot market pricing should not be used to value long term assets. It is insane as the spot market is very volatile and subject to wild swings. This will be the first recession induced by FAS. Accountants are morons.

TheFrenchITook Posted On 2/12/2009 1:27:13 AM

Mark To Model is Enron. Market to Market is the fall of Enron. Refresher courses in physics and math would enlighten some and blind others. All models are true its the element of time that mortals wish to avoid

Erich Riesenberg Posted On 2/12/2009 6:54:57 AM

Are you at all curious why super investors such as yourself do not take advantage of the absurdity and ignorance of the market which has mismarked these assets? I would think super investors such as yourself would be giddy with joy rather than complaining there are too many opportunities!

OM Posted On 2/12/2009 9:04:38 AM

Things are worth what you can sell them for. When entities purchase long-term assets with short-term money, they expose themselves to market risk. When entities substantially leverage their assets to take advantage of the differential between short and long rates, they expose themselves to even greater risk. If an entity wants to be in the arbitrage business, it should structure and fund itself as such. A bank is a publicly supported institution and should conduct itself as such. Any fool can make a fortune using a great deal of leverage in a favorable environment. Every fool will lose a fortune when they are highly leveraged and the market is unfavorable. The "mark-to-market" issue is a canard. The institutions in difficulty were mismanaged.

rsd57 Posted On 2/12/2009 5:33:53 PM

The basic problem with mark to market accounting is that it assumes asset markets are very efficient. We know this not to be the case for many markets. A proper solution is likely a compromise which has a definable test for using mark to market for those assets deemed to be efficiently priced and another method of pricing in the case of inefficiently priced and/ or assets in markets where there is little or no reliable market.

RW Posted On 2/16/2009 11:29:01 AM

How is a NegAM option ARM treated now--with FVA--and how would it be treated if FVA were done away with? For the purpose of our example, assume the borrower is making minimum payments and that NegAm accumulation means the loan is likely to recast in a year.

KC Kid Posted On 2/16/2009 12:36:31 PM

Sometimes an analogy helps.-------------------- If you were to "Mark to Market-ize" (M2M-ize) the cruise control on your car you would need to reverse the action it now takes when your car slows down or speeds up. -------- As the car slows down instead of pushing the accelerator pedal down to speed the car back up, as a normal cruise control would do, the M2M-ized version would instead let up on the pedal. --------- Thus the car would slow down even more causing the M2M-ized cruise control to lift the pedal up even more. --------- This cycle would be repeated until the engine eventually was at idle and the car stopped moving or was moving at minimum speed (assuming a flat road). Of course the reverse is also true. --------- So when this type of seeming logical yet improper feedback is introduced into the banking system it tends to help produce (destabilizing) boom and bust cycles. Of course if you are an active trader that's great but if you are a retired long-term investor it's pretty scary. --------- If M2M is to be kept, which I'm not in favor of, we need to find some way to help stabilize the system. ------- That's why the counterintuitive recommendation from some of inverting the capital raise requirements makes sense from a dynamic system analyst's perspective. ------ Right now anything that causes capital raise requirements, which M2M does in a down economy, will tend to cause banks to let up on the lending pedal. ------ That in turn reduces the velocity of money and economic activity (MV=PQ) thereby causing more defaults driving the market marks down even further. And, the cycle repeats itself until the economy comes to a standstill or is finally reversed with gigantic sums of new money. This process is particularly troubling because the banking system is naturally leveraged.
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