6/10/17: Italian Banks Tested EU Banking Reform. It Failed.

My article on the patent failures in the EU Banking Crisis resolution reforms exposed by the 2017 events surrounding Italian banking sector is out via @ManningFinancial http://issuu.com/publicationire/docs/mf_autumn_2017?e=16572344/54030271.

10/7/16: Europe's Banks: Dinosaurs On Their Last Legs?

Europe's banks have been back in the crosshair of the markets in recent weeks, with new attention to their multiple problems catalysed by the Brexit vote.

I spoke on the matter in a brief interview with UTV here: http://utv.ie/playlists/default.aspx?bcid=5026776052001.

Now, Bloomberg have put together a (very concise) summary of some of the key problems the banks face: "Europe's banks have been a focal point of investor skittishness since Britons voted to leave the European Union, but reasons to be worried about financial firms pre-date the referendum. Whether it be the mountain of non-performing loans, the challenge from fintech firms and alternative lenders encroaching on what was once their turf, or rock bottom interest rates eroding margins, the problems facing Europe's lenders are mammoth."

To summarise the whole rotten lot: European banks (as a sector)

• Cannot properly lend and price risk (hence, a gargantuan mountain of Non-Performing Loans sitting on their books that they can't deleverage out, exemplified by Italian, Slovenian, Spanish, Portuguese, Cypriot, Greek, Irish, and even, albeit to a lesser extent, German, Dutch, Belgian and Austrian banks);
• Cannot make profit even in this extremely low funding cost environment (because they cannot lend properly, while controlling their operating costs, and instead resort to 'lending' money to governments at negative yields);
• Cannot structure their capital (CoCos madness anyone?);
• Cannot compete with more agile fintech challengers (because the dinosaur mentality and hierarchical structures of traditional banking prevents real innovation permeating banks' strategies and operations);
• Cannot reform their business models to reflect changing nature of their customers demands (because they simply no longer can think of their customers needs); and
• Cannot succeed in their traditional markets and services (despite being heavily shielded from competition by regulators and subsidised by the governments).

Instead of whingeing about the banks' plight, we should focus on the banks' resound failures and stop giving custom to the patrician incumbents. Let competition restructure Europe's banking sector. The only thing that sustains Europe's banks today is national- and ECB-level regulatory protectionism that contains competition within the core set of banking services. It is only a matter of time before M&As and organic build up of fintech players will blow this cozy cartel up from the inside. So regulators today have two options: keep pretending that this won't happen and keep granting banks a license to milk their customers and monetary systems; or open the hatches and let the fresh air in.

15/4/16: Banking Union, Competition and Banking Sector Concentration

One of the key changes in recent years across the entire U.S. economy has been growth in market concentration (lower competition) and regulatory burden increases in a number of sector, including banking. A good summary of the matter is provided here: http://www.americanactionforum.org/research/market-concentration-grew-obama-administration/ .

However, an interesting chart based on the U.S. Fed data, shows that even with these changes U.S. banking sector remains relatively more competitive than in other advanced economies:

Source: @HPSInsight

Interestingly, European banks are also becoming more regional, as opposed to global, players as discussed here: http://www.nakedcapitalism.com/2016/03/the-us-is-beginning-to-dominate-global-investment-banking-implications-for-europe.html

Chart next shows market shares of the European Investment Banking markets accruing to banks originating in the following jurisdictions:

Source: @NakedCapitalism

As an argument goes: “Deutsche Bank and Barclays are the only Europeans left in the top seven for the EMEA market. But they are likely to lose their positions because Deutsche Bank is currently undergoing a major reorganisation and Barclays is in the process of executing the Vickers split. In the investment banking field, the only pan-European banks will all soon be American. This has the corollary, for good or bad, that European national and EU-level authorities, such as the European Commission, will have rather less direct control over them. A key part of the European financial system is slipping out of the grasp of the European authorities.”

Which begs two questions:

Does Europe need more regulation-induced consolidation in the sector, aiming to make TBTF European banking giants even bigger and even less diversified globally, as the European Banking Union and European Capital Markets Union, coupled with increasing push toward greater regulatory constraints on Fintech sector are likely to do?

Or does Europe need more disruptive and more agile, as well as risk-diversified, smaller banking systems and more open innovation culture in banking and financial services?


Note: you can see my analysis of the European Capital Markets Union here: http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2592918

27/7/15: IMF Euro Area Report: The Sick Land of Banking

The IMF today released its Article IV assessment of the Euro area, so as usual, I will be blogging on the issues raised in the latest report throughout the day. The first post looked at debt overhang.


So here, let's take a look at IMF analysis of the Non-Performing Loans on Euro area banks' balance sheets.

A handy chart to start with:

The above gives pretty good comparatives in terms of the NPLs on banks balance sheets across the euro area. Per IMF: "High NPLs are hindering lending and the recovery. By weakening bank profitability and tying up capital, NPLs constrain banks’ ability to lend and limit the effectiveness of monetary policy. In general, countries with high NPLs have shown the weakest recovery in credit."

Which is all known. But what's the solution? Ah, IMF is pretty coy on this: "A more centralized approach would facilitate NPL resolution. The SSM [Single Supervisory Mechanism - or centralised Euro area banking authorities] is now responsible for euro area-wide supervisory policy and could take the lead in a more aggressive, top-down strategy that aims to:

• Accelerate NPL resolution. The SSM should strengthen incentives for write-offs or debt restructuring, and coordinate with NCAs to have banks set realistic provisioning and collateral values. Higher capital surcharges or time limits on long-held NPLs would help expedite disposal. For banks with high SME NPLs, the SSM could adopt a “triage” approach by setting targets for NPL resolution and introducing standardized criteria for identifying nonviable firms for quick liquidation and viable ones for restructuring. Banks would also benefit from enhancing their NPL resolution tools and expertise." So prepare for the national politicians and regulators walking away from any responsibility for the flood of bankruptcies to be unleashed in the poorly performing (high NPL) states, like Cyprus, Greece, Ireland, Italy, Slovenia and Portugal.
• And in order to clear the way for this national responsibility shifting to the anonymous, unaccountable central 'authority' of the SSM, the IMF recommends that EU states "Improve insolvency and foreclosure systems. Costly debt enforcement and foreclosure procedures complicate the disposal of impaired assets. To complement tougher supervision, insolvency reforms at the national level to accelerate court procedures and encourage out-of-court workouts would encourage market-led corporate restructuring."
• There is another way to relieve national politicians from accountability when it comes to dealing with debt: "Jumpstart a market for distressed debt. The lack of a well-functioning market for distressed debt hinders asset disposal. Asset management companies (AMCs) at the national level could support a market for distressed debt by purchasing NPLs and disposing of them quickly. In some cases, a centralized AMC with some public sector involvement may be beneficial to provide economies of scale and facilitate debt restructuring. But such an AMC would need to comply with EU State aid rules (including, importantly, the requirement that AMCs purchase assets at market prices). In situations where markets are limited, a formula-based approach for transfer pricing should be used. European agencies, such as the EIB or EIF, could also provide support through structured finance, securitization, or equity involvement." In basic terms, this says that we should prioritise debt sales to agencies that have weaker regulatory and consumer protection oversight than banks. Good luck getting vultures to perform cuddly nursing of the borrowers into health.

Not surprisingly, given the nasty state of affairs in Irish banks, were NPLs to fall to their historical averages from current levels, there will be huge capital relief to the banking sector in Ireland, as chart below illustrates, albeit in Ireland's case, historical levels must be bettered (-5% on historical average) to deliver such relief:

Per IMF: "NPL disposal can free up large volumes of regulatory capital and generate significant capacity for new lending. For a large sample of euro area banks covering almost 90 percent of all institutions under direct ECB supervision, the amount of aggregate capital that would be released if NPLs were reduced to historical average levels (between three and four percent of gross loan books) is calculated. This amounts to between €13–€42 billion for a haircut range of between zero and 5 percent, and assuming that banks meet a target capital adequacy ratio of 13 percent. This in turn could unlock new lending of between €167–€522 billion (1.8–5.6 percent of sample countries’ GDP), provided there is corresponding demand for new loans. Due to the uneven distribution of capital and NPLs, capital relief varies significantly across euro area countries, with Portugal, Italy, Spain, and Ireland benefiting the most in this stylized example."

A disappointing feature, from Ireland's perspective, of the above figure is that simply driving down NPLs to historical levels will not be enough to deliver on capital relief in excess of the average (as shown by the red dot, as opposed to red line bands). The reason for this is, most likely, down to the quality of capital held and the impact of tax relief deferrals absorbed in line with NPLs (lowering NPLs via all but write downs = foregoing a share of tax relief).

Stay tuned for more analysis of the IMF Euro area report next.

30/5/15: The New Financial Regulation: Part 10: Legal v Operational Logistics

My post for @learnsignal blog on EU financial regulation covering operational logistics is now available: http://blog.learnsignal.com/?p=188.

15/5/15: New Financial Regulation: Part 8: An Overconfidence Bias Awaits

My latest blog post on European Union innovations in financial regulation, continuing coverage of the European Banking Union is now available here: http://blog.learnsignal.com/?p=181

8/5/15: Three Strikes of the New Financial Regulation – Part 7: Fundamentals Matter

My latest blog post on European Union innovations in financial regulation, continuing coverage of the European Banking Union is now available here: http://blog.learnsignal.com/?p=178

1/5/15: Three Strikes of the New Financial Regulation – Part 6: Banking Dis-Union

My latest post on the ongoing developments in financial regulation in the EU is now available on Learn Signal blog: http://blog.learnsignal.com/?p=177. This week, I am continuing coverage of the European Banking Union system.

22/4/15: Three Strikes of the New Financial Regulation – Part 5: European Banking Union

My latest post on Financial Regulations innovations courtesy of the European Union is now available on @learnsignal blog: http://blog.learnsignal.com/?p=175. This one starts coverage of the European Banking Union.

17/11/2014: All the years draining into banking cesspool...

So the tale of European banks deleveraging... record provisions, zero supply of credit for years, scores of devastated borrowers (corporate and personal), record subsidies, record drop in competition, rounds and rounds of 'stress testing' - all passed by virtually all, the Banking Union, the ESM break, forced writedowns in some countries, nationalisations, various LTROs, TLTROs, MROs, ABS, promises, threats, regulatory squeezes ... and the end game 6 years into the crisis?..

Per Bloomberg Brief, the sickest banking system on Planet Earth is... drum roll... Wester European one.

It is only made uglier by all the efforts wasted.

H/T for the chart to Jonathan. 

28/10/2014: Page 75... ECB Washes Out Its Big Bazooka QE with New NPLs...

In the previous (lengthy) post I covered my view of the ECB stress tests results. But, per chance, you have missed two core points on these, here they are, in a neater summary:

Point 1: Stress tests are weak compared to expectations and independent analysts' estimates of capital shortfall (by a factor of up to or in excess of10:1).

Point 2: Stress tests have raised non-performing loans levels in the euro area banking system by EUR136 billion to EUR879.1 billion or close to 9% of the euro area GDP. The increases were recorded in all categories of loans, which in simple terms means the banks have been under-providing for loans losses across all categories of their core assets.

Now, that puts into perspective the ECB's 'big game all-in' shot for TLTROs and ABS purchases targeting to raise ECB balancesheet exposures by... you've guessed it... EUR1 trillion.

Why, despite improving asset markets, stoic rhetoric of deleveraging and historically low cost of central banks' funds, the NPLs are climbing... and by the end of the ECB's big bazooka firing, that EUR1 trillion is probably will be just about enough to cover the outstanding NPLs. Assuming economy does not tank any more, in which case, it might fall short.


Update: Here's WSJ Blogs analysis of the effects application of the tougher quality tests for Core Tier 1 capital would have had on ECB stress test results: http://blogs.wsj.com/moneybeat/2014/10/27/tough-new-rules-would-have-caused-ten-more-stress-test-fails/

26/10/2014: Mind the ECB 'Stress Tests' Gap

The pain of European economy's Japanification is going to be proportionate to the cheering of the ECB 'stress tests' results.

The real problem faced by European economy is that of the depressed domestic demand (investment and consumption). This problem is fuelled by:
1) declining real incomes of those working,
2) continued sky-high numbers of those who are not working (unemployed, discouraged and never-once-employed workers left out in the cold),
3) growing unease amongst older workers about the state of their pensions,
4) rising burden of the state (including state debts),
5) growing pressure of redistribution of income from households and SMEs to politically favoured white elephant projects (e.g. renewables subsidies, large infrastructure spending, farm supports, regional integration etc),
6) un-abating waste at the EU and national levels anchored to corporatist politics selectively rewarding specific interest groups interests at the expense of entrepreneurs, younger workers, ordinary households and domestic firms, and
7) demographic collapse spreading across the continent as populations age and children remain dependent on ever older parents to support their education and transitioning into joblessness.

This real problem is driving down domestic demand, and with it depressing economy, but also spreading rot across the banks balance sheets.

And yet, despite the obvious and ever-deepening macroeconomic crisis of depressed demand, the ECB stress tests released today provide no insight into what can happen to the banks balance sheets should Japanification set in. Worse, the entire exercise of 'stress tests' is once again not much more than a PR stunt dreamed up by the folks who are 'would be' chief economists for the sell-side equity research.


Here's why.

Back in January 2014, two academics published a preliminary assessment of the Euro area banking union capital shortfalls: http://www.voxeu.org/article/what-asset-quality-review-likely-find-independent-evidence.

This identified stressed shortfalls estimated at between €82 billion and €176 billion (4% benchmark capital ratio) and €509 billion to €767 billion (7% capital ratio) based on book capital.  Take the average to compare to ECB results: ca EUR295-470 billion. "The market capital shortfall estimates indicate a capital shortfall of €230 billion (4% benchmark capital ratio) or €620 billion (7% capital ratio) for the 41 publicly listed banks". Take the average to compare to ECB results: EUR425 billion.

Worse, "estimates of SRISK or the capital shortfall in a systemic financial crisis (40% market decline over a six-month period) is €579 billion; 41% is due to downside correlation with the market, while 59% is due to the leverage of these institutions." So compare to 20% decline under ECB tests (across property assets, 30% decline) and get roughly half of the above figure at EUR290 billion.

Ugly? Try next: "Capital shortfall estimates when writing down their net non-performing loan portfolios range from €232 billion (using the C Tier 1 ratio and an 8% threshold as in the AQR) and €435 billion (using the tangible equity/tangible assets ratio and a 4% threshold)." Again, average these out at EUR330 billion or so.

And get this: "There is a high rank correlation between the shortfalls based on book and market capital ratio measures [but] no significant correlation between shortfalls calculated using regulatory (i.e. risk-weighted asset-based) capital ratios and shortfalls calculated under market or book capital ratios… this highlights how flawed risk-weighted asset-based measures can be."

Take the conclusion in with a deep breath: "Cross-country variation in our capital shortfall estimates indicate that:

• French banks are leading each book and market capital shortfall measure, both in absolute euro amounts and relative to national GDP. The capital shortfall ranges from €31 billion (using the equity/asset ratio and a 4% threshold) to €285 billion (using the tangible equity/tangible asset ratio and a 7% threshold). The SRISK stress scenario suggests a shortfall of €222 billion, which corresponds to almost 13% of the country’s GDP.
• German banks are close seconds, although they benefit from a stronger domestic economy with a higher GDP and a greater capacity for public backstops.
• Spanish and Italian banks appear to have large capital shortfalls when non-performing assets are fully written down. Both countries account for about a third of the total shortfall after write-downs. Market-based measures such as SRISK amount to about 6.5%–7.6% of the GDP of both countries."

So a close common value for estimated shortfalls, comparable to the ECB tests is around EUR290 billion for 41 listed banks (not 150 tested by EBA/ECB).

Oh dear, now think ECB stress tests: The ECB stress tests found virtually none of the above problems to be present or pressing (see full release here: http://www.ecb.europa.eu/pub/pdf/other/aggregatereportonthecomprehensiveassessment201410.en.pdf?d2f05d43d177c25c57e065ebdbf80fe7). Instead, the ECB tests estimated shortfall in the banks to be EUR24.6 billion as of December 2013 and that all but EUR9.5 billion of this has been already rectified by the banks.

This is plain mad not only because it is more than 10 times the number averaged out above, but also because the same ECB review found that some EUR136 billion of loans held by the banks as assets should be classed as non-performing. That is an 18 percent hike in one sweeping year. 85% of banks tested had to revise up their bad loans exposures. And this implies that EUR47.5 billion worth of losses is required to bring these 'assets' in line with their true values.

These losses will have to be covered from either more tightening of existent loans costs or via capital raising or by shrinking returns on equity or all of the above. And these losses are at the lower (as noted by independent analysts) end of the range. And these losses are going to impact future capital access by the banks too, as who on earth would want to stake a house on investing in sick banks hiding the true extent of their losses to the tune of 18 percent?!

All in, Euro area banks now have a hole of EUR879 billion in non-performing loans, facing losses of some EUR300 billion, plus. Based on already stretched (by extend-and-pretend measures adopted to-date) loss rate on non-performing assets. Oh, dear…

Table below summarises sources of NPL increases by category of assets:

As of the end of 2013, per ECB own assessment, some 1/5 of all major banks were in the position of facing high risk of going bust. Forward nine months into this year - what has changed? Nothing, save for the following factors:

1. ECB funding became temporarily cheaper (rates down), but LTROs are being replace by higher priced TLTROs and this means cost of funding going slightly up;
2. Assets valuations have improved on massive monetary stimuli. These being gradually reduced (outside the euro area) is going to depress carry trades that have been helping asset prices boom. Asset values might not fall, but realising these values in the markets forward and counting on their further significant appreciation would be equivalent to taking serious risks.
3. Real economic conditions have deteriorated. Which is far from being trivial, as in the long run, asset values and availability and cost of funding should start reflecting this reality. Once they start, there'll be pain on balance sheets. 

What are the safety cushions post-ECB tests? Ugh, rather thin. Of 130 banks tested by the ECB, 25 failed, 31 had core capital ratio below 10% - the safety threshold accepted in the markets. 28 more banks were within a 10-11 percent range. Thus, 84 out of 130 banks tested were either in an ICU or on ventilators.

Looking back at the main findings from January 2014 paper by Viral Acharya and Sascha Steffen, what is striking is the position of the German and French banks. ECB found virtually no problems in both countries banking systems (see Table below):

Table: Banks that failed ECB tests

Look at geographic distribution of losses under stressed scenario:

Setting aside the proverbial 'periphery' (and Slovenia) there are virtually no problems in the stress case across the national banking system anywhere, save for Belgium, the Netherlands, and Luxembourg. Even Italian system is within 1 percentage point of the median losses. You have to be laughing, right?

And the above only holds for 57% of all assets of the tested banks. That's right, the AQR exercise did not cover all assets held by the 130 banks tested.

Meanwhile, macroeconomic risks factored in are rapidly becoming not stringent enough. The ECB tests were based on EU Commission forecasts from Q1 2014. Since then, the forecasts have seen consistent downward revisions. Instead of focusing on the risk of deflationary recession and stagnation (Japanification), the risks tested were based on bond markets stress, plus recession.

There is virtually no material deterioration in ECB assessment results for German banks compared to previous tests. How? We can only scratch our heads. In the last 2 years, German economy has gone from moderate growth to slow growth and is heading into stagnant growth.

Emerging markets risks exposures were non-existent in the view of the ECB tests, except via higher interest rates impact spillover from the US (assumed by the ECB). Neither were the risks arising from the global slowdown in trade flows. So here's a kicker, if rates are higher and there is a global slowdown, impact on banks balance sheets will be most likely lower than if rates are low (and with them lending margins), but there is a secular long term growth crisis in the euro area itself. Second order effects will be smaller than first order effects.

All in, the 'stringent' tests carried by EBA and ECB took 150 banks and banks subsidiaries and found that 25 of these were short of EUR24.6 billion in capital: 16.7% of banks failed, average capital requirement per failed bank EUR984 million, average capital required per all banks tested: EUR164 million. Contrast this with 2011 when EBA tested 90 banks, failed 20 of these (failure rate of 22.2% much higher than 16.7% in this round of tests), requiring them to raise EUR26.8 billion in capital which amounts to EUR1.34 billion per failed bank (much higher than ECB stress tests this time around) and EUR298 million per bank tested (much higher than ECB tests). Yet, 2011 tests were labeled a farce by the markets.

Today's tests are no better. If not worse.

Worse because they fail to account for the real risks arising in the Euro area today and worse because they create a false sense of security within the system. Or maybe they do not. In which case the entire exercise is a PR stunt, with ECB having a different and more descriptive picture of what is really happening in the banking sector. Maybe so… in which case, does the whole charade qualify as market manipulation by the soon-to-be super regulators? Take your pick, either the regulators-to-be are wearing rose-tinted glasses, or they are fixing the market. Neither is a pretty option...

17/5/2014: That costly alphabet soup behind the European Banking Union

Two main building blocks of the Single Resolution Mechanism for future banks bailouts in the EU involve Deposit Guarantee Scheme Directive (DGSD) and the Bank
Recovery and Resolution Directive (BRRD). The issue at hand is funding the future bailouts.


The EU Member States are required to establish two types of financing arrangements:

• BRRD sets up the Resolution Fund to cover bank failure resolution. This will be used after 8% of losses gets covered by the bail-in of depositors and some funders.
• DGS covers deposits up to EUR100,000 in the case of a bank failure. 

There are several issues with both funds. For example, DSG funds (national level) will have to run parallel with the EU-wide Eurozone Single Resolution Fund (until the DSG pillar is integrated at a much later date into EBU). This implies serious duplication of costs over time and creation of the 'temporary'  but long-term national bureaucracy / administration which will be hard to unwind later.

By 2016, EA18 euro area members will have national DSG running parallel to EU18-wide single resolution runs (SRM) which cannot be merged together absent (potentially) a treaty revision, not EA-18 EU members will have national DSG and national resolution fund, which can be merged together.

What is worse is that national contributions to DSG cannot count toward national contributions to the resolution fund (SRM or in the case of non-EA18, to national resolution funds). This means that total national banking system-funded contributions to both funds will be 0.8% of covered deposits for DSG, plus 1% for SRM = minimum of 1.8% of covered deposits. Ask yourselves the simple question: given that banking in majority of the EU states is oligopolistic with high (and increasing) concentrated market power, who will pay these costs? Why, of course the real sector - depositors and non-financial, non-government borrowers.

It is worth noting that the 1.0% contribution to the resolution fund will cover not just covered deposits, but actually is a function of liabilities. In other words, it will be much larger proportion of covered deposits than 1%.

That is a hefty cost of the EBU and this cost will be carried by the real economy, not by financialised one. The taxpayers might get off the hook (somewhat - see here: http://trueeconomics.blogspot.ie/2014/04/1742014-toothless-shark-eus-banking.html) but the taxpayers who are also customers of the banks will be hit upfront. And who wins? Bureaucrats and administrators who will get few thousands new jobs across the EU to manage duplicate funds, collections and accounts. The more things change… as Europeans usually say…

10/2/2014: Six Years to Admit the Obvious? Call in Europe...

There are two things to be said about the latest comments from Euro area's chief banking regulator, Danièle Nouy issued recently (see FT's piece from yesterday: "Let weak banks die, says eurozone super-regulator" for more):

• They are so trivially obvious, that given it took EU 'leaders' 6 years to come up with them, one has to wonder if the EU mandarins have any capacity to supervise banks in the first place, and
• Danièle Nouy deserves praise for speaking to the reality.

Here are the main points of what she said:

1. “One of the biggest lessons of the current crisis is that there is no risk-free asset, so sovereigns are not risk-free assets. That has been demonstrated, so now we have to react.” Correct. But don't expect any change soon. 
2. On the upcoming ECB tests: some banks need to fail for tests to be credible. 
3. “We have to accept that some banks have no future,” she said, parrying speculation that a wave of consolidation could save the currency bloc’s weakest lenders. “We have to let some disappear in an orderly fashion, and not necessarily try to merge them with other institutions.”

You'd think all of the above should be trivial. And you would be right. Which makes the fact that these statements are front-page news in Europe ever so more amazing.

26/12/2013: Don't Bank on the Banking Union: Sunday Times, December 15

This is an unedited version of my Sunday Times column from December 15, 2013.


Over the last week, domestic news horizon was flooded by the warm sunshine of Ireland's exit from the Bailout. And, given the rest of the Euro area periphery performance to-date, the kindness of strangers was deserved.
Spain is also exiting a bailout, and the country is out of the recession, officially, like us. But it took a much smaller, banks-only, assistance package. And, being a ‘bad boy’ in the proverbial classroom, it talked back at the Troika and played some populist tunes of defiance. Portugal is out of the official recession, but the country is scheduled to exit its bailout only in mid-2014, having gone into it after Ireland. No glory for those coming second. Greece and Cyprus are at the bottom of the Depression canyon, with little change to their misery.

In short, Ireland deserves a pat on the back for not being the worst basket case of the already rotten lot. And for not rocking the boat. Irish Government talks tough at home, but it is largely clawless vis-à-vis the Troika. Our only moments of defiance in dealing with the bailout came whenever we were asked to implement reforms threatening powerful domestic interests, such as protected sectors and professions.

However, with all the celebratory speeches and toasts around, two matters are worth considering within the broader context of this week's events. The first one is the road travelled. The second is the road that awaits us ahead. Both will shape the risks we are likely to face in the medium-term future.


The road that led us to this week's events was an arduous one. Pressured by the twin and interconnected crises - the implosion of our banking sector and the collapse of our domestic economy - we fell into the bailout having burnt through tens of billions of State reserves and having exhausted our borrowing capacity. The crater left behind by the collapsing economy was deep: from 2008 through today, Irish GDP per capita shrunk 16.7 percent, making our recession second deepest in the euro area after Greece. This collapse would have been more benign were it not for the banking crisis. In the context of us exiting the bailout, the lesson to be learned is that the twin banking and growth crises require more resources than even a fiscally healthy state can afford. Today, unlike in 2008, we have no spare resources left to deal with the risk of the adverse twin growth and banking shocks.

Yet, forward outlook for Ireland suggests that such shocks are receding, but remain material.

Our economic recovery is still fragile and subject to adverse risks present domestically and abroad. On domestic side, growth in consumer demand and private investment is lacking. Deleveraging of households and businesses is still ongoing. Constrained credit supply is yet to be addressed. This process can take years, as the banks face shallower demand for loans from lower risk borrowers and sharply higher demand for loans from risky businesses. On top of this, banks are deleveraging their own balance sheets. In general, Irish companies are more dependent on banks credit than their euro area competitors. Absent credit growth, there will be no sustained growth in this economy. Meanwhile, structural reforms are years away from yielding tangible benefits. This is primarily due to the fact that we are yet to adopt such reforms, having spent the last five years in continued avoidance of the problems in the state-controlled and protected domestic sectors.

On the Government side, Budgets 2015 and 2016 will likely require additional, new revenue and cost containment measures. Post 2016, we will face the dilemma of compensating for the unwinding of the Haddington Road Agreement on wages inflation moderation in the public sector and hiring freezes.
To-date, Irish economy was kept afloat by the externally trading services exporters, or put in more simple terms - web-based multinationals. Manufacturing exports are now shrinking, although much of this shrinkage is driven by one sector: pharmaceuticals.

Meanwhile, the banking sector is still carrying big risks. Heavy problems of non-performing loans on legacy mortgages side, unsecured household credit and non-financial corporates are not about to disappear overnight. Even if banks comply with the Central Bank targets on mortgages arrears resolution, it will take at least 18-24 months for the full extent of losses to become visible. Working these losses off the balance sheets will take even longer.
Overall, even modest growth rates, set out in the budget and Troika projections for 2014-2018, cannot be taken for granted.


This week, the ongoing saga of the emerging European Banking Union made the twin risks to banks and growth ever-more important. The ECOFIN meetings are tasked with shaping the Bank Recovery and Resolution Directive, or BRRD. These made it clear that Europe is heading for a banking crisis resolution system based on a well-defined sequencing of measures. First, national resources will be used in the case of any banks' failures, including in systemic crises. These resources include: wiping out equity holders, and imposing partial losses on lenders and depositors. Thereafter, national funds can be used to cover the capital shortfalls and liquidity shortages. Only after these resources are exhausted will the EU funds kick in to cover the residual capital shortfalls. This insurance cover will not be in the form of debt-free cash. Instead, the funding is likely to involve lending to the Government and to the banks under a State guarantee.

When you run through the benchmark levels of capital shocks that could qualify a banking system for the euro-wide resolution funding under the BRRD, it becomes pretty clear that the mechanism is toothless. For example, in the case of our own crisis, haircuts on bondholders under the proposed rules could have saved us around EUR15-17 billion. In exchange, these savings would have required bailing in depositors with funds in excess of the state guarantee. It is unlikely that we could have secured any joint EU funding outside the Troika deal. Our debt levels would have been lower, but not because of the help from Europe.

This last point was made very clear to us by this week’s events. After all, our historically unprecedented crisis has now been 'successfully resolved' according to the EFSF statement, and as confirmed by the European and Irish officials. The 2008-2010 meltdown of the Irish financial system was dealt with without the need for the Banking Union or its Single Resolution Mechanism.

With a Banking Union or without, given the current state of the Exchequer balance sheet, the buck in the next crisis or in the next iteration of the current crisis will have to stop at the depositors bail-ins. In other words, banking union rhetoric aside, the only hope any banking system in Europe has at avoiding the fate of Cyprus is that the next crisis will not happen.


Second issue relates to the continued reliance across the euro area banks on government bonds as core asset underpinning the financial system. In brief, during the crisis, euro area banks have accumulated huge exposures to sovereign bonds. This allowed the Governments to dramatically reduce the cost of borrowing: the ECB pushed up bonds prices with lower interest rates and unlimited lending against these bonds as risk-free collateral.

The problem is that, unless the ECB is willing to run these liquidity supply schemes permanently, the free lunch is going to end one day. When this happens, the interest rates will rise. Two things will happen in response: value of the bonds will fall and yields on Government debt will rise. The banks will face declines in their assets values, while simultaneously struggling to replace cheap ECB funding with more expensive market funds.

Given that European Governments must roll over significant amounts of bonds over the next 10 years, these risks can pressure Government interest costs. Simple arithmetic says that a country with 122 percent debt/GDP ratio (call it Ireland) and debt financing cost of 4.1 percent per annum spends around 5 percent of its GDP every year on interest bills, inclusive of rolling over costs. If yield rises by a third, the cost of interest rises to closer to 6.6 percent of GDP. Now, suppose that the Government in this economy collects taxes and other receipts amounting to around 40 percent of GDP. This means that just to cover the increase in its interest bill without raising taxes or cutting spending, the Government will need nominal GDP growth of 3.9 percent per annum. That is the exact rate projected by the IMF for Ireland for 2014-2018. Should we fail to deliver on it, our debts will rise. Should interest rates rise by more than one-third from the current crisis-period lows, our debts will rise.


The point is that the dilemmas of our dysfunctional monetary policy and insufficient banking crisis resolution systems are not academic. Instead they are real. And so are the risks we face at the economy level and in the banking sector. Currently, European financial systems have been redrawn to contain financial exposures within national borders. The key signs of this are diverged bond yields across Europe, and wide interest rates differentials for loans to the real economy. In more simple terms, courtesy of dysfunctional policymaking during the crisis, Irish SMEs today pay higher interest rates on loans compared to, say, German SMEs of similar quality.

Banking Union should be a solution to this problem – re-launching credit flowing across the borders once again. It will not deliver on this as long as there are no fully-funded, secure and transparent plans for debt mutualisation across the European banking sector.

Box-out:

Recent data from the EU Commission shows that in 2011-2012, European institutions enacted 3,861 new business-related laws. Meanwhile, according to the World Bank, average cost of starting a business in Europe runs at EUR 2,285, against EUR 158 in Canada and EUR 664 in the US. Not surprisingly, under the burden of growing regulations and high costs, European rates of entrepreneurship, as measured by the proportion of start up firms in total number of registered companies, is falling year on year. This trend is present in the crisis-hit economies of the periphery and in the likes of Austria, Germany and Finland, who weathered the economic recession relatively well. The density of start-ups is rising in Australia, Canada, the US and across Asia-Pacific and Latin America. In 2014 rankings by the World Bank, the highest ranked euro area country, Finland, occupies 12th place in the world in terms of ease of doing business. Second highest ranked euro area economy is Ireland (15th). This completes the list of advanced euro area economies ranked in top 20 worldwide. Start ups and smaller enterprises play a pivotal role in creating jobs and developing skills base within a modern economy. The EU can do more good in combatting unemployment by addressing the problem of regulatory and cost burdens we impose on entrepreneurs and businesses than by pumping out more subsidies for jobs creation and training schemes.

3/12/2013: GoldCore research note on deposits bail-ins

GoldCore have published an insightful guide to banks bail-ins of depositors that the EU is rapidly falling toward as a default policy for resolving future banks crises.

Here's an inforgraphic from the report:
http://dzswc0o8s13dx.cloudfront.net/goldcore_bloomberg_chart1_03-12-13.png

And the link to the report itself:
http://info.goldcore.com/what-savers-and-depositors-need-to-do-to-protect-their-savings-and-deposits-from-bank-bail-ins

9/11/2013: Stress testing zombie banks: Sunday Times, November 3

This is an unedited version of my Sunday Times article from November 3, 2013.


In the marble and mahogany halls of European high finance HQs, the next few months will be filled with the suspense of the preparation for the banks audits.

Much of this excitement will be focused on matters distant to the real economy. Truth is, saddled with zombie banks, and public and private sectors’ debt overhangs, euro area is incapable of generating the growth momentum sufficient to wrestle itself free from the structural crisis it faced since 2008. The latest ECB forecasts for the Euro area economy, released this week, predicted real GDP contraction of 0.4 percent for 2013 and growth of 1 percent in 2014. With these numbers, the end game is the same today as it was two years ago, when previous stress tests were carried out. The system can only be repaired when banks absorb huge losses on unsustainable loans.

New stress tests are unlikely change this. However, the tests are important within the context of the weaker banking systems, such as the Irish one. The reason for this is that the ECB needs to contain the sector risks as it goes about building the European Banking Union, or EBU.

The good news is – there are low- and high-cost options for achieving this containment in Ireland’s case. The bad news is – neither involves any relief on the legacy banks debts necessary to aid our stalled economy. The worse news is – the Government appears to be pushing for exiting the bailout without securing the low cost option, leaving us exposed to the risk of being saddled with the costlier one.


The IMF data suggests that Euro area-wide banks’ losses can be as high as EUR350-400 billion - or just under one third of the total deleveraging that still has to take place in the banks. The ECB needs to have an accurate picture of how much of the above can arise in the countries where banks and Government finances are already strained beyond their ability to cover such losses. The ECB also needs to deliver such estimates without raising public alarms as to the levels of losses still forthcoming.

Taken together, the above two points strongly suggest that in the case of Ireland, the banks will come out of the stress tests with a relatively clean bill of health shaded somewhat by risk-related warnings. Pointing to the latter, the ECB will implicitly or explicitly ask the Irish Government to secure funding sources for dealing with any realization of such risks. Such precautionary funding can only come from either a stand-by credit line with the IMF and/or European stabilization funds, or a commitment to set aside some of the NTMA cash. An NTMA set-aside will cost us the price of issuing new Government debt. This is potentially more than ten times the price of IMF credit line.

In short, Ireland should be using ECB’s concerns over our banking system health to secure a cheaper precautionary line of credit. Judging by this week’s comments from the Government, we are not. One way or the other, it is hard to see how continued uncertainty build up within Irish banks can help our cause in obtaining both a precautionary line of credit and a relief on legacy banks debts.


The ECB concerns about Irish banks are not purely academic. Our banking crisis is far from over.

Consider the latest data on three Pillar Banks: AIB, Bank of Ireland and Permanent tsb, covering the period through H1 2013 courtesy of the IMF and the EU Commission reviews published over recent weeks. On the surface, the three banks are relatively well capitalised with Core Tier 1 capital ratio of 14.1 percent, down on 16.3 percent a year ago. Meanwhile, the deleveraging of the system is proceeding at a reasonable pace, with total average assets declining EUR30.5 billion year on year.

The problem is that little of this deleveraging is down to writedowns of bad loans. This means that high levels of capital on banks balance sheets are primarily due to the extend-and-pretend approach to dealing with nonperforming loans adopted by the banks to-date. All members of the Troika have repeatedly pointed out that Irish banks continue to avoid putting forward long-term sustainable solutions to mortgages arrears and that this approach can eventually lead to amplification of risks over time.

Loans loss provisions are up 11 percent to EUR28.2 billion and non-performing loans are up to EUR56.8 billion. Still, while in H1 2012 non-performing loans accounted for 22.2 percent of all loans held by the banks, at the end of June this year, the figure was 26.6 percent. Non-performing loans are now 35.5 percent in excess of banks’ equity, up from just 4.7 percent a year ago. As a reminder, Irish Exchequer holds 99.8 percent stake in AIB, 99.2 percent share in Ptsb and 15.1 percent stake in Bank of Ireland. This means that should capital buffers fall to regulatory-set limits, further writedowns of loans will mean nullifying the Exchequer stakes in the banks and crystalising full losses carried by the taxpayers.

Continued weaknesses in the solvency positions of the banks are driven primarily by three factors. Firstly, as banks sell or collateralise their better loans their future returns on assets are diminished. The second factor is poor operational performance of the banks. Net losses in the system fell between H1 2012 and H1 2013. However, this still leaves banks reliant on capital drawdowns to fund their non-performing assets. The third factor is the weak performance of banks’ non-core financial assets. Over the last 12 months, Irish banks holdings of securities grew in value at a rate that was about 12-15 times slower than the growth rate in valuations of assets in the international financial markets.

In short, the IMF review presented the picture of the banking sector here that retains all the signs of remaining comatose. This was further confirmed by the EU Commission report this week, and spells trouble for the Irish banks stress tests.

In 2011 recapitalisation of Irish banks, the Central Bank assumed that banks operating profits will total EUR3.9 billion over the 2011-2013. So far the banks are some EUR4.5 billion shy of matching the Central Bank’s rosy projection.

This shortfall comes despite dramatic hikes in interest margins on existent and new loans, decreases in deposit rates, and reductions in operating costs. Compared to H1 2011 when the PCARs were completed, lending rates margins over the ECB base rate have shot up by up to 138 basis points for households and 59 basis points for non-financial companies. Rates paid out on termed deposit have fallen some 103 basis points. As the result, banks net interest margins rose.

On top of that, the funding side of the banks remains problematic. The NTMA is now holding almost half of its cash in the Pillar Banks, superficially boosting their deposits. Private sector deposits continue to trend flat and are declining in some categories. This is before the adverse impacts of Budget 2014 measures, including the Banks levy and higher DIRT rates start to bite.

Behind these balance sheet considerations, the economy and the Government are continuing to put strains on households' ability to repay their loans. This week, AA published analysis of the cost of mortgages carry (the annual cost of financing average family home and associated expenses). According to the report, the direct cost of maintaining an average Irish home purchased prior to the crisis is now running at around EUR 21,940 per annum. Under Budget 2014 provisions, a married couple with two children and combined income of EUR 100,000 will spend one third of their after-tax earnings on funding an average house. In such a setting, any major financial shock, such as birth of another child, loss of employment, extended illness etc., can send the average Celtic Tiger household into arrears.


All of this, means that any honest capital adequacy assessment of the Irish banking system will be an exercise in measuring a litany of risks and uncertainties that define our banks’ operating conditions today and into the foreseeable future. Disclosing such weaknesses in the system will risk exposing Irish banks to renewed markets pressures, including possible failures to roll over maturing debts coming due. It can also impair their ability to continue deleveraging, and fund assets writedowns. On the other hand, leaving these stresses undisclosed risks delaying recognition of losses and exposing us to pressure from the ECB down the line.

Not surprisingly, as the ECB goes into stress tests exercise, it is exerting pressure on Ireland to arrange a stand-alone precautionary line of credit. While it is being presented as a prudential exercise in light of our exit from the bailout, in reality the credit will be there to cushion against any potential losses in the banking system over 2014-2018, before the actual EBU comes into force. Should such losses materialise, the Exchequer will be faced with an unpalatable choice: hit depositors with a bail-in or pony up some more cash for the banks. Having a stand by loans facility arranged prior to exiting the Bailout will help avoid the latter and possibly the former. The cost, however, will be an increase in overall interest charges paid by the State, plus continued strict oversight of our fiscal position by the Troika.

A rock of interest charges and Troika supervision, a hard place of zombiefied banking, and a rising tide of risks are still beckoning Ireland from the other side of the stress tests.

Box-out: 

The latest data from the retail sector released by the CSO this week painted a rather mixed picture of the domestic economy’s fortunes. Controlling for some volatility in the monthly series, Q3 2013 data shows that despite very favourable weather conditions over the July-September 2013, Irish core retail sales (excluding motors sales) fell in volume by some 0.3 percent compared to Q3 2012. On the other hand, there was a 0.6 percent increase in the value of sales over the same period. Currently, the volume of total core retail sales in Ireland sits 4.3 percent below 2005 levels. Non-food sales, excluding motor trades, fuel and bars sales, fell 2.1 percent on 2012 in volume and is up 1.2 percent in value. The inflation effects imply that when it comes to core non-food sales, the volumes of retail trade are now down 22 percent on 2005 levels, while the value of sales is up almost 2 percent. Consumers are still on strike, while retailers are getting only a slight prices relief in the unrelenting crisis.

21/6/2013: Europe's Capacity Deficit Illustrated

Want an example of Europe's 'capacity deficit' I mention here: http://trueeconomics.blogspot.ie/2013/06/1962013-european-federalism-and-emu.html

Look no further than the latest set of quotes fired off by ECFIN E-news letter:

Let's take them through reading.

Mr Rehn says that 'Banking Union is not about bailing banks'. Of course he is right - the EU has bailed out the banks before it conceived the EBU. However, one major objective of the EBU is about systematising future bailouts of the banks, in theory - to restrict taxpayers' expected liabilities in such bailouts, and to regulate future depositors' liabilities. And EBU is - according to the EU Commission and the ECB - a necessary element of the sovereign-banks 'break' that includes ESM. Now, ESM is about bailing out the banks.

Is EBU 'about getting a banking system that serves the real economy'? Well, nothing in the EBU proposals so far has much to do with the 'real economy' in a positive sense of serving it. At least nothing that requires an EBU and cannot be done absent EBU. Deposits insurance? Doesn't need an EBU. Joint supervision and regulation? Hardly much to do with the real economy, unless one is to make a claim that the two are fail-proof way of ensuring that a new crisis won't happen. In fact, when it comes to the real economy, the EBU is a part of the policy instruments package that includes depositors  bail-ins, mechanism for sovereign liabilities imposition and fiscal harmonisation - these are about the real economy, but there is little in terms of 'support' here. More like 'limiting damage' by 'spreading the cost'. Reality check: UK has an EBU equivalent, US and Japan have one... all had banking crises that cost their real economies dearly...

So Mr Rehn is just plain propagandising, right? Well, sort of - the EBU is a necessary, but not a sufficient condition for the survival of the Euro. If you accept the thesis that Euro's survival is the 'service' that real economy needs, then you have 1/2 of Rehn's equation there.

Onto Mr Lamy who says that Europeans need something new to drive their attention away from the bad things that are old. Contemplating the past is disuniting the peoples of Europe. Giving them something new to desire (may be a promise of a new iPad for everyone would work?) will shift them to work toward the future, presumably forgetting and forgiving the past and the present. How did the Soviet leaders not think this one up? 'We promise you this better future because we screwed up your past and present' school of politics...

Ireland's Taoiseach is honestly thinking that EBU is necessary to give credibility to European leaders because they promised EBU. Neither the concept of 'do we need A in the first place', nor the irony of his party pre-election promises not being delivered on strike Mr Kenny as being a touch testing. And then there's 'following through on decisions is the very least our citizens expect and demand'. Not really. Citizens demand that political leaders (a) adopt right decisions, then (b) implement right decisions. Having not established that EBU is right fails both (a) and (b).

But the most priceless bit of Mr Kenny's statement is that he believes that something is crucial because it is a credibility test. Mr Kenny's logic here is risking a resemblance to a schoolboy's logic who, in fear of hearing 'Chicken! Chicken!' from a schoolyard bullies heads off to carrying out a silly and dangerous deed, lest his 'credibility' be challenged.

This, per the EU's powerful, is 'leadership' at the time of a crisis?..