Wednesday, November 18, 2009

Crisis and Leviathon

Crises tend to expand the role of government, which then never subsides. The theme of Robert Higgs' Crisis and Leviathon was that wars and great depressions create a ratchet-like movement toward ever bigger government. The process involves government taking on new functions more than expanding traditional ones. In the end a distant set of bureaucrats regulates everything, but nothing well. Most functional units have specialized argot, data, processes, and contacts, and new employees takes months to know enough to be productive. A regulator has a few weeks at best, probably a few days, to review an organization. How is he to find problems, let alone fix them?

In practice, regulators ask for a select set of reports, usually highlighting statistics that would have been useful in the last crisis, and make bland statements about the desirability of 'clear lines of authority' or a 'prioritization of risk management' (see the Fed's new Senior Supervisors Group Issues Report on Risk Management Practices).

I've talked to many risk managers at large financial firms lately, and there appears an increased focus on regulators: what do they want? This is in contrast to asking, what do we need? The latter question draws on the parochial expertise of people who have to create products and services worth more than they cost to produce, the former draws on the results of endless committee meetings by people who are far removed from the front line.

The subprime crisis has discredited internal financial risk management, so now, instead of thinking about how to manage risk better, large firms have taken the understandable course of action in our Brave New World, of deferring such judgments to the regulators. Appeasing regulators determines whether one can, say, hire immigrants under H1B visa program, or pay a dividend, or worst of all, be labeled 'undercapitalized', creating a self-fullfilling death spiral necessitating an acquisition.

Firms, and the individuals therein, are in the best position to better their practices. With this recent crisis, they have strong top-down directives to placate the government, and cease all innovation because that was the kind of thinking that led to CDOs! Talk about a bad take-away. I expect banks to respond to their lack of productivity by increasing lobbying efforts to squelch competition, because that is really the only way for non-innovative organizations to make profits.

There's an East German joke that goes "What would happen if the desert became communist? Nothing for a while, and then there would be a sand shortage." An important part of this joke is the 'nothing for a while'. Bad policies don't usually produce an immediate catastrophe, rather, they weaken the trend, barely observable when initially implemented. Only after a long while do people notice that the new system is a morass of dysfunctional duties that are done mostly out of precedent, no efficiency. For example, the socialist countries started to great enthusiasm by western intellectuals; so too with busing in schools, large scale public housing, the Department of Education. At best these are wasted resources, more often they create unintended consequences at the root of the next crisis.

A friend of mine lost his job in the financial sector. He got a new job with the FDIC. As a country we have decided to allocate more resources to government, more power to government, at all levels. I fail to see how moving more people out of private firms, that create wealth and pay taxes, to regulators, that impose costs and cost taxes, will make our financial system more robust. From the Great Depression, to the Carter Credit Controls of 1980:3Q, to the S&L crisis, to the Subprime Crisis, Government was not standing athwart history saying 'stop', rather, it was encouraging the very behavior that turned out, with hindsight, to be the root of the problem.

7 comments:

J said...

Excellent note with the proviso that sand shortage is no joke. Israel is 60% desert but we face a severe shortage of sand http://www.forward.com/articles/14632/ that has to be imported from the Kingdom of Jordan. Israeli sand is the habitat of the lesser Egyptian gerbil and the Middle Eastern short-fingered gecko which cannot be disturbed. You dont have to be a Communist to create a shortage of sand in the desert and in the case of California, of water in the Delta of the Sacramento River.

J said...

Excellent note with the proviso that sand shortage is no joke. Israel is 60% desert but we face a severe shortage of sand http://www.forward.com/articles/14632/ that has to be imported from the Kingdom of Jordan. Israeli sand is the habitat of the lesser Egyptian gerbil and the Middle Eastern short-fingered gecko which cannot be disturbed. You dont have to be a Communist to create a shortage of sand in the desert and in the case of California, of water in the Delta of the Sacramento River.

AHWest said...

Excellent post. www.aynrand.org points to the solution. Without an ethical revolution, there will be no change in political direction.

Anonymous said...

>From the Great Depression, to the Carter Credit Controls of 1980:3Q, to the S&L crisis, to the Subprime Crisis, Government was not standing athwart history saying 'stop', rather, it was encouraging the very behavior that turned out, with hindsight, to be the root of the problem.

Notice how all these crises originated, not in socialist countries, but in the USA, the lighthouse of capitalism.

> instead of thinking about how to manage risk better, large firms have taken the understandable course of action in our Brave New World, of deferring such judgments to the regulators.

Large firms were never interested in risk management (worse example : Paul Moore, HBOs). That is not a feature of a socialist economy but a stockholder's economy. Such problems are less likely to occur with partnerships, for example.

> I fail to see how moving more people out of private firms, that create wealth and pay taxes, to regulators, that impose costs and cost taxes, will make our financial system more robust.

That comment is disingenuous. The FDIC and other agencies are not moving anyone of private firms. They are moving them, probably a small proportion of the total, out of unemployment because they are facing challenges in the aftermath of the crisis.

The Randian discourse was never meant to become a practical recipe for policy. Quite the contrary, its unrealistic demands and the conclusion that follows from it - government will always be the problem - provides the eternal blame shifting weapon that, ironically, allows every entity (individual, organization) who adopts this point of view to be absolved of its own failures, or worse, the ones imposed upon others.

Anonymous said...

Here's another E German joke:

Everything they had told about socialism was a lie but everything they had told us about capitalism turned out to be true.

Brian Peters (FRBNY) said...

BTW, as a regulator, I can certainly agree that firms should be first understanding their needs, and constructing risk management programs around the specific risks of their institutions. Unilaterally adopting a regulator's specification changes risk management into compliance (witness how firms have all aligned their VaR calibration, in the process losing knowledge about how and why they used VaR in the first place).

Brian Peters (FRBNY) said...

I do want to take issue with the assertion that "regulators ask for a select set of reports, usually highlighting statistics that would have been useful in the last crisis, and make bland statements about the desirability of 'clear lines of authority' or a 'prioritization of risk management' (see the Fed's new Senior Supervisors Group Issues Report on Risk Management Practices)."

Sorry if I don't see that as a fair representation of the SSG's findings.

As to "highlighting statistics that would have been useful in the last crisis" second SSG report ("Risk Management Lessons from the Global Banking Crisis of 2008") states:

** Firms repeatedly cited credibility as the primary criterion for stress and scenario analysis to influence management behavior, even after the events of September-October 2008. For this reason, the most common stress tests conducted have generally been those subjecting trading or credit accounts on extreme historic events.

** While more firms now perform stress tests based on hypothetical scenarios, many others still do not have the necessary infrastructure to allow them to develop easily and consider forward-looking scenarios, representing a significant weakness for the industry as a whole. Even when forward looking stress tests are conducted, the process is resource intensive, owing to infrastructure limitations. Reverse stress testing, a forward-looking approach advocated in CRMPGIII (p. 84), was reported to still be in its infancy; only two firms indicated that they run a reverse stress test designed to identify scenarios or risk factors that can cause a significant stress event for the firm or business line.

SSG2 also reports on firm's self-assessment results:

** Firms rated their practices associated with identification and measurement of risk, transfer pricing, counterparty monitoring, and stress testing as those that were least aligned with recommendations (Table 2). The supervisors agree with this assessment. Supervisors, however, view the challenges associated with closing the gaps as more critical and difficult than do the firms, in aggregate, and note that resolution of each of these areas will likely require substantial investments in technological infrastructure.

It seems from this statement that the firms' who were reliant on historical events, and that a combination of infrastructure weaknesses and business line and senior management unwillingness to consider highly-stressful events, rather than regulators proscriptions, that were to fault.

I also re-read the reports to see where we may have made "bland statements about the desirability of 'clear lines of authority' or a 'prioritization of risk management'" As best I can tell, you are referring to our observations about firm's self-assessments against best practice guidance, much of which was industry generated expectations (CRMPG2, IIF)

In our summary, based on both our reading of the self-assessments and meetings with twenty firm's management teams concludes:
An overarching observation that relates to many of the areas singled out for improvement is that weaknesses in governance, incentives, and infrastructure undermined the effectiveness of risk controls and contributed to last year’s systemic vulnerability. ... These failures reflected four challenges in governance:
1. the unwillingness or inability of boards of directors and senior managers to articulate, measure, and adhere to a level of risk acceptable to the firm,
2. arrangements that favored risk takers at the expense of independent risk managers and control personnel,
3. compensation plans that conflicted with the control objectives of the firm, and
4. an inadequate and often fragmented infrastructure that hindered effective risk identification and measurement.

Again, not our own pronouncements but what the industry reported to us.

Happ to go over chapter and verse of what the two reports stated.