12/6/16: Few Thoughts on Anglo Trial Verdicts

A friend recently did me a small service by summing up my comments on twitter on the Anglo Irish Bank - Irish Life & Permanent roundabout loans verdict:

I have provided an expert testimony on the matter in April in a court case involving the Central Bank, the Department of Finance and the Attorney General of Ireland, focusing precisely on the nature of the relationship between the Irish Financial Regulation authorities and the misconduct by banks and banks boards prior to 2008 Global Financial Crisis.  Quoting from my expert opinion:

"Part 4: Regulatory enforcement effectiveness and efficiency

46. In my opinion, and based on literature referenced herein, objectives of the function of enforcement in financial regulation are best served by structuring enforcement processes and taking robust actions so as to:
1. Target first and foremost the core breaches of regulatory and supervisory regimes, starting with systemic-level breaches prior to proceeding to specific institutional or individual level infringements [Targeting];
2. Timely execute enforcement actions, both in the context of market participants’ timing and timing relevant to the efficiency and effectiveness of uncovering the actual facts of specific alleged infringements [Timely execution];
3. Prevent or at the very least reduce, monitor and address any potential conflicts of interest in enforcement-related actions [Conflict of interest minimisation];
4. Assure that enforcement actions are taken within the constraints of the regulatory regime applicable at the time of alleged committing of regulatory breaches, while following well-defined and ex ante transparent processes [Applicability and quality of regulation and enforcement];

5. Assure that regulatory enforcement actions do not contradict or duplicate other forms of enforcement and remedial measures, including legal settlements [Consistency of legal and administrative frameworks]."

In simple terms, systemic lack of imposition of meaningful sanctions on senior policy, regulatory and supervisory decision-makers active in the Irish financial services in the period prior to the Global Financial Crisis severely undermines the signalling and deterrence functions of regulatory enforcements. Convicting bankers for mis-deeds is fine, but not sanctioning regulatory and supervisory officials is not conducive to establishing any tangible credibility to the regulatory enforcement regime. Worse, it establishes a false sense of security that the system has been repaired and strengthened by convictions achieved, whilst in reality, the system remains vulnerable to exactly the same dynamics and risks of collusion between regulators and supervisors and the new financial services executives.

It is, perhaps, telling that my counterparts providing expert opinions in the case on behalf of the Central Bank, Department of Finance and the Attorney General of Ireland have based their analysis on the axiomatic assumption that no regulatory, supervisory and enforcement staff can ever be held liable for their actions or inactions in the events and processes that led to the Global Financial Crisis. No matter what they have done or refused to do. Full impunity must apply.

21/8/2013: FinReg Appointment

The Central Bank announced the appointment of the new FinReg. Announcement is here:
http://www.centralbank.ie/press-area/press-releases/Pages/NewDeputyGovernorFinancialRegulationAppointed.aspx

My (sketchy) views on the appointment are here:
http://uk.reuters.com/article/2013/08/21/ireland-regulator-idUKL6N0GM1AF20130821
and here:

Critically, I do not know Mr Roux stand on key points of regulatory and strategic affairs relating to the financial services in Ireland and Europe, including:

1. Role of competition in provision of services and securing systemic stability;
2. Role of consumer protection in delivering the same;
3. Role of implicit and explicit state subsidies to the incumbent institutions and the issue of TBTF institutions;
4. Legacy debt, risks and business strategies and the regulatory approaches for dealing with these;
5. Capture risk of regulatory and supervisory systems in the environment of social partnership and closely linked society, such as Ireland;
6. Recent regulatory activism, e.g. shorting bans;
7. Recent policy shifts toward centralised regulatory oversight and controls, unified banking supervision and regulation, FTT, etc.

There are other potentially important questions to be asked in days to come. 

I most certainly hope Mr Roux can continue with the competent and professional work that Mr Elderfield has started. 

To the credit of its top management team, the Central Bank today is a different institution, transformed from at the top, and still being transformed down the ranks (it takes long time to work through rank-and-file cadre pool). The transformations that took place to-date are for the better and serve as an example of what can be achieved in the rest of Irish public sector. This is not to say that the CBI is free of criticism, but to point out that there have been strongly positive changes in the institution that started with Mr. Elderfield and Prof. Honohan's appointments.

Economics 6/10/10: Mortgages arrears and paying FR staff

The latest, highly irritating, half-talk about the real issues comes courtesy of our FR. Per Matthew Elderfiled, Ireland's mortgage arrears figures stand at 36,000 borrowers or 4.3% of the borrowers. Now, the number clearly does not include:

• Those who have renegotiated their mortgage terms (acknowledged by Mr Elderfield), forced to do so by... err... inability to pay; and
• Those who are in the receipt of state aid to pay their mortgage interest, due to their... err... inability to cover their mortgage; and
• Those who are missing some of the payments, without triggering actual arrears (say paying 5 months out of every six, thus sliding in and out of arrears)

Here's a question Mr Elderfield should be answering: Why wouldn't his office demand from the banks full disclosure of the above information? "

It's a hugely difficult subject," Mr Elderfield told the Dail Committee today. Really? What's all the highly paid FR staff for, then? To write speeches for the Regulator and arrange events calendar?

Another question for Mr Elderfield. Q1 2010 estimate by NIRSA showed that 32,321 mortgages were in arrears 90 days or over. Figures from the Central Bank show that 36,438 mortgages were in arrears for more than 90 days at the end of June 2010. What's the value of Mr Elederfiled's latest statement if it offers no new information?

And just when you get the idea that Mr Elderfield should have been answering more questions than he did, here's the last one: What is his office doing to prevent banks from savaging more vulnerable (to increases in the cost of mortgage finance) ARM mortgage holders?

Economics 21/03/2010: Reckless expectations, not competition

This is a lengthy post - to reflect the importance of the issue at hand. And it is based largely on data from Professor Brian Lucey, with my added analysis.

The proposition that this post is proving is the following one:

Far from being harmed by competition from foreign lenders, Irish banking sector has suffered from its own disease of reckless lending. In fact, competition in Irish banking remains remarkably close (although below) European average and is acting as a stabilizing force in the markets relative to other factors.


I always found the argument that ‘too much competition in banking was the driver of excessive lending’ to be an economically illiterate one. Even though this view has been professed by some of my most esteemed colleagues in economics.

In theory, competition acts to lower margins in the sector, and since it takes time to build up competitive pressure, the sectors that are facing competition are characterized by stable, established players. In other words, in most cases, sectors with a lot of competition are older, mature ones. This fact is even more pronounced if entry into the sector is associated with significant capital cost requirements. Banking – in particular run of the mill, non-innovative traditional type – is the case in point everywhere in the world.

As competition drives margins down, making quick buck becomes impossible. You can’t hope to write a few high margin, high risk loans and reap huge returns. So firms in highly competitive sectors compete against each other on the basis of longer term strategies that are more stable and prudent. Deploying virtually commoditized services or products to larger numbers of population. Reputation and ever-increasing efficiencies in operations become the driving factors of every surviving firm’s success. And these promote longer term stability of the sector.

Coase’s famous proposition about transaction costs provides a basis for such a corollary.

This means that in the case of Irish banking during the last decade, if competition was indeed driving down the margins in lending (as our stockbrokers, the Government and policy analysts ardently argue today), then the following should have happened.

1. Banks should have become more prudent over time in lending and risk pricing,
2. There should have been broader diversification of the banks lending portfolia, with the bulk of new loans concentrating in the areas relating directly to depositor base – corporate and household lending, and a hefty fringe of higher-margin inter-mediation lending to financial institutions, and
3. Banks would be seeking to ‘bundle’ more services to differentiate from competitors and enhance margins.
   

In Ireland, of course, during the alleged period of ‘harmful competition’ exactly the opposite took place. Let me use Prof Brian Lucey’s data (with added analysis from myself) to show you the facts.

Firstly, Irish banks became less prudent in lending – as exemplified by falling loans approvals criteria, and by rising LTVs:

1. Lending to private sector as % of GDP was ca 50% in 1995, reaching 100% in 1998 and rising to 300% in 2009
2. Vast increases in lending to developers: in 1997 there were €10bn lent out to developers against €20bn in mortgages; in 2008 these figures were €110bn and €140bn respectively
3. Over the time when lending to private sector rose 600%, mortgages lending rose 550%, our GDP rose by 75%
   

Secondly, banks reduced their assets and liabilities diversification (charts 1-3 below) setting themselves up for a massive rise in asymmetric risk exposures.

On the funding side, out went customers deposits, in came banks deposits, foreign deposits and bonds and Irish bonds.
Capital ratios fell out of the way.

And so there has been a change in the world of Irish banking that no other competitive and mature sector of any economy has ever seen. Why? Was it because foreign banks started pushing the timid boys of BofI and AIB and Anglo and INBS out into reckless competitive lending?

You’ve gotta be mad to believe this sop. In reality, the Irish banks’ assets tell the story.

Business loans collapsed, personal loans (the stuff that allegedly, according to the likes of the Irish Times have fuelled our cars and clothing shopping binge during the Celtic Tiger years) actually declined in importance as well. Financial intermediation – the higher margin, higher risk thingy that so severely impacted the US banks – was down as well. No, competition was not driving Irish banks into the hands of higher margin lending. It was driving them into the hands of our property developers. We didn’t have a derivatives and speculative financial investment crisis here – the one that was allegedly caused by the foreign banks coming in and forcing our good boys to cut margins on run-of-the-mill ordinary lending. No, we had an old fashioned disaster of construction and property lending.

And this lending could not have been driven by foreign banks. It came from the total expansion of credit in the economy, presided over by our Central Bank and Financial Regulator, our Government and ECB.

Just how dramatic this change was? Take a look at the ratio of private sector credit to national income in the chart below.
Even a child could have seen the bust coming. The reason that our Financial Regulator and Central Bank failed to see this, despite publishing all this data in the first place, is that they were simply not looking. The former probably obsessed with the pension perks, the latter – well, may be because all the fine art in the Central Bank’s own collection was just too much of a distraction. Who knows? But judging by the above chart lack of significant correction during the crisis – we know who will pay for this in the end. Us, the taxpayers.
As chart above shows, the fundamentals for the boom – in lending and in construction – were never there, folks. And the banks missed that completely. As did our regulators and our policymakers. Brian Lucey of TCD School of Business provides evidence on what was really going on in the Irish banks (again, note that some of the analysis below is mine).
Chart above, based on the Central Bank Credit Survey, basically shows the impact three major forces: expectations of increased competition by the banks, improved banks outlook on the Irish economy three months ahead, and LTVs expectations had in Irish banks willingness to increase lending. Scores above 3 represent tightening of credit conditions (as in banks expecting to cut lending to households), while scores below 3 show forces driving looser credit to households.

If the proposition that foreign banks competition pressures drove Irish banks into looser credit supply were to be correct, one would expect the blue line above to reach far deeper into ‘below 3’ scores than the other two lines. Alas, it did not dip. In fact, competition from other banks was recognized by Irish Bankers themselves to be the least improtant factor contributing to credit supply expansion. Instead, their over-optimism about economic prospects (red line) and their willingess to give away cash at massively inlfated LTVs (the orange line – also a proxy for Bankers’ optimism regarding future direction of house prices) were the two main drivers of credit boom.

Where’s the evidence on ‘harmful competition’ that so many Central Bank leaders, the stockbrokers and Government spokespersons have decried in recent past?

The delirium of our bankers was actually so out of any proportion that, as the surveys data shows, even amidst the implosion of the housing markets since early 2008 they were still saying “hang on....we expect that changes in LTV and economic prosoects will cause us to loosen in the next 3 months". In other words, they were chasing the deflating bubble, not the imaginary foreign banks competitiors.

Let’s take another look at Brian Lucey’s data. Take the scores for Ireland in the above surveys and take their ratios to the Euro area average scores. If the ratio is in excess of 1, then the said factor has contributed to greater tightening in credit supply in Ireland than in the Euro area. If it is less than 1, then the said factor has contributed more to loosening in lending in Ireland than in the Euro area.
So, really, folks, competition in Ireland was actually more of a stabilizing force, than de-stabilizing one. LTV’s optimism and lack of realism in economic forecasts were the two main driving forces of the boom.

Lastly, ECB Herfindahl Index (ratio of Ireland to “big5” EU states) provides exactly the same conclusions:
Again, what above shows is that on virtually every occasion, Irish reading for Herfindahl Index (measuring degree of concentration in banking sector) is in excess of the average Index reading for top 5 EU countries. In other words, there was no such thing as ‘too much competition’ going on in Irish banking sector. If anything, there was somwhat too little of it, compared to Germany, France, Italy, UK and the Netherlands.

And now, for the test of all of this. The chart below regresses each survey factor on the private sector credit index. The negatively sloped line – for LTV and economic prospect factors combined - shows that when this factor scoring in the survey increased, lending became tighter. Positively sloped line – for competition – shows that when competition pressures rose (factor reading declined), lending actually got tighter. And the statistical significance of the LTV and expectations factors is more than double that of competition...
Let’s just stop talking nonesense about too much competition in Irish banking sector drove unsustainable lending. More likely – an anticiaption by our bankers that no matter what they do, they will never be allowed to fail by the state, plus an absolutely rediculous expectations about opur economy drove our banks to the brink.

Economics 27/02/2010: How to reform our broken risk pricing system

This is an unedited version of my article in March 2010 edition of Business & Finance magazine:


There are several deeply rooted problems with the current analysis of the ongoing financial crisis. These relate to the sources of the crisis itself and to the solutions proposed for ensuring that a new financial bubble will not emerge out of the ashes of systemic risk under pricing that characterized the period of 2003-2007 around the globe.

So far, the public aspects of the regulatory responses to the crisis have been focused on ‘political’ topics, such as executive compensation. Fine: the incentive for banks executives to structure their own compensation to reflect short term gains is well established.

Political issues are non trivial as well. We all are aware of the fact that politicians – from Bill Clinton to Gordon Brown to Bertie Ahearn and on – have strong incentives to placate voters through fattened Exchequer revenue, expanded public spending and broadened access to credit irrespective of risks. Active encouragement of loose lending standards (especially in the case of the US SGEs: Fannie Mae, Freddie Mac and Ginnie Mae) were enshrined in regulatory and legislative mandates. And look no further than Greece, Portugal, Spain and Ireland as to the troubles this can cause – politicised spending breeding scores of vested interest groups that cannot be disentangled from the feeding trough.

All of these forces, underlying the crisis emergence, are well known. What is less frequently discussed in the media is that wrong incentives alone are not a sufficient condition for markets malfunctioning, since in efficient markets, a contrarian view should be able to price out those players aligned with wrong incentives.

It is a much deeper question as to whether this has happened in the case of the current financial crisis. Anecdotal evidence suggests that this was indeed so. Early in 2007-2008, a number of short positions, including those taken well in advance of the crisis, were generating the payouts consistent exactly with the rapid pricing-out of the malfunctioning lending strategies. Ironically, banning short sales has resulted in the restoration of the mis-aligned incentives in the market. An act by the regulators aimed at restoring order in the financial markets turning out to be nothing more than reinforcing the very causes of the crisis.

This means that we must look back beyond the immediate crisis to find any evidence to either support or dispute the proposition that mispricing of risks by the financial system was systemic (in the sense that existent models of risk pricing could not have allowed for contrarian pricing strategies).

It remains a puzzle that the main villains of the game, sub-prime mortgage packages (the famed ‘Collateralised Debt Obligations’), seem to have been so badly mispriced. This apparent mispricing lay not so much in the slicing of the mortgages but in the failure to price into the packages as a whole the apparent systematic risk due to the general response of property prices to the business cycle.

Suppose that the current view that greed blinded markets participants to the fact that CDOs packages were not properly pricing risks is correct. This explanation requires that not a single market participant was willing to take a contrarian strategy betting against the consensus view. Alas, this is patently untrue.

So ‘collective madness’ explanation does not hold and the crisis roots lie somewhere else – more likely, in the balance of incentives. My suggestion is that on the margin, regulatory and market incentives led to favouring of underpricing risks inherent in CDOs and MBSs. Thus, on the margin, excess returns to unpriced risk for going long on mortgage-backed products were made greater than the expected returns to shorting mortgage-backed products once the price of insuring / shorting these products was taken into account.

In other words, it was a combination of:

• Artificially low perceived cost of long positions;
• Artificially high cost of shorting; and
• Recklessly elevated correlations between product risk (mortgages risk) and insurer risk (AIG)

that drove the bubble formation. The reason why this understanding is important is the following:

If contrarian strategy could have been formulated based on existent risk pricing systems, then short sellers were ‘fundamentally’ justified in their positions and their gains were not ‘speculative’. Furthermore, this would imply that the current crisis is not systemic from the financial point of view, but is driven by incentives and regulatory failures.

If, however, existent risk pricing systems were not sufficient to support the contrarian investment strategy and those short sellers who were betting against the consensus obtained speculative profits, then the markets are not efficient and the crisis is systemic in nature.

So, if we take information about the markets available pre-August 2007, could the crisis been pre-priced? Put differently, were Irish or for that matter UK or US property and credit bubbles predictable on the back of fundamentals or were they random events?

The systemic crisis argument supporters show that since Irish property prices have indeed collapsed on the back of weaker-than-expected ‘fundamentals’ market price risk discounting has failed.

Those opposing the argument point out that the fundamental in the housing market is ultimately driven by income dynamics, which in turn are driven by productivity. In the case of Ireland, productivity growth (income growth) should follow a random walk because innovation is largely unforecastable and in the case of a small open economy it is also subject to global trends. In other words, Irish productivity growth should be following a random walk that is even ‘more random’ than the productivity growth processes in the rest of the world.

Both are wrong. It turns out that close to the crisis – at least from 2003 on – Irish property prices appeared to become a non-stationary process having been largely stationary in the previous decade. Ditto for the US and UK, and even Spanish, Russian and Dutch property prices.

This means that the conditional forecast of the property prices in Ireland was best modelled by a reference to the current prices. More importantly, from the point of view of risk pricing, expected conditional volatility of house prices was a scale factor of the observed current volatility. In other words, the degree of risk 6 quarters from, say February 2003 was simply 6 times greater than very low volatility observed back in February 2003.

The scaling relationship, alas, failed to hold in the real world. As the property boom became, using Bertie Ahern’s terminology, ‘boomier’ through 2003-2006, property prices stopped following non-stationary process and their volatility became largely trend driven. The trend presence means that at least in part, future risk could have been priced into lending decisions by the banks and regulators. Alas, it was not. All evidence on lending suggests that the banks lending margins were heading down during 2003-2008 period, not up. In other words, Irish mortgage lenders, with tacit consent of the regulators, were pricing in decreasing risks into the future during the bubble inflation time. Ditto for all other countries that have experienced the collapse of property markets.

So whilst the financial markets were correct in pricing risks, subject to significant regulatory incentives constraints that skewed their willingness (and later ability) to actually adjust their risk pricing positions, mortgage lenders and regulators were grossly mispricing risks. This realisation leads to two major conclusions.

It shows that globally, financial crisis of 2007-2010 has been driven by the risk mis-pricing that originates in the very institutions whose business is preventing this from happening – the banks and the regulatory bodies.

And it shows where the future reforms attempting to address the issue of financial bubbles formation must lie. And it certainly has nothing to do with bankers compensation packages. The main solution to the problem suggested today is heavy re-regulation of bank risk; moving Basel I and II up to Basel III to include a pro-cyclical risk capital provision.

While a useful idea, greater buffer reserves of risk capital built over the years of credit expansion cycle, are not a panacea to the problem outlined above. The reserves are only sufficient in so far as they reflect actual risk expectations. Missing risk forecast will, in the end, still imply sub-optimally low levels of capital.

Instead, the answer to the problem of how can we prevent future bubble formation similar to the one that has been deflating since August 2007 lies in a more holistic approach to risk pricing reforms. This approach must involve several policy changes along the following directions.

Firstly, a more transparent early warning system must be deployed across the financial markets that would make short trading positions a part of open market pricing mechanisms. Put more simply, short trading must be allowed to operate on unrestricted basis, but all short trading positions must be disclosed and reported in the market in the same way in which we current disclose long positions.

Secondly, property must be treated as investment instrument, with full price and hedonic information disclosure rules mirroring those required for liquid financial instruments under MiFID.

Thirdly, there must be a clear set of strict ‘no pain, no bail out’ rules that will impose severe penalties on the management, bondholders and shareholders in financial institutions seeking public assistance. If countries can change governments within weeks after elections, banks can be weeded of their failed management as a matter of months. Instead of restricting their pay, in the future, we must make bankers accountable for their failures.

Third, regulatory authorities must be beefed up with independent, fully protected risk analysis boards drawn across the broader economy. These boards must be politically unconstrained, free of interest groups influence and must be operated behind a strict Chinese Wall relative to the entire regulatory process. A formal requirement must be imposed that at least 1/3 of the board members should be drawn from outside financial services sector, with the same proportion of members being required to hold a publicly verifiable policy positions that are contrarian to the consensus.

What the current crisis has taught us is that in the environment where politicians and industry drive risk pricing-related policies, failures of the market to cope with distorted incentives and incomplete regulatory oversight will be spectacular. Crises are a natural way for the markets to reassert proper order on inept regulatory and institutional systems.

Daily Economics 22/04/09: IMF's GFSR

IMF's Global Financial Stability Report (available here) is a lengthy read worthy of attention, both for its finance world-view and a diplomatically correct version of the 'Office' comedy. Subtle language turns tell more of a story of IMF's desperation from looking at APIIGS' incompetent macroeconomic management than the direct phrases. That said, there is little in the report, aside from two tests of financial contagion, that is either new or forward-looking.

"The United States, United Kingdom, and Ireland face some of the largest potential costs of financial stabilization given the scale of mortgage defaults."

Emphasis on the word 'mortgage' is mine, of course, added precisely because the IMF concern has not been, to date, echoed by many Irish economists or banks. In fact, all Irish banks currently assume that mortgage defaults will not happen. Instead, policymakers (via NAMA and debt issuance), bankers (via impairment charges and recapitalization funding) and economists (via RTE / Irish Times opinion pages) have been preoccupied with 'toxic' assets (development loans). Poor households have largely been left out of the 'They deserve help too' circle. The Government actually is so confident that mortgage defaults will not be a problem, that it is taxing households into the recession. As I have noted before, this presents a problem - should inflationary pressures rise, interest rates will regain upward momentum and Ireland will be plunged into a mortgages implosion.

How costly are Lenihan's commitments?
Moving on, two illustrations from the IMF report are worth putting together: First, the sheer size of the so-called 'costless' (Brian Lenihan's grasp of economics), guarantees written by Ireland Inc on our banks:Second, the real-world cost of these guarantees...I've identified this link between the throwaway promises Irish Government has been issuing since September and the cost of our debt before. It is nice to see IMF finally saying the same: "Figure 1.37 highlights that the spread on the issues guaranteed by sovereigns perceived as less capable of backing their guarantee is wider than for those that are deemed well able to stand behind their promises, such as the United States and France."
But here is another proof of the link between Brian Lenihan's guarantees and the cost of these to you and me:
Note the coincident timing: September 2008, and spreads on Government debt shooting through the roof to reach banks bonds spreads and trending from there on side-by-side to Anglo's Nationalization (another spike), then to recapitalization (a slight decline)...

Go long, not short...
The IMF advises the Governments to switch debt issuance to longer term maturities. Exactly the opposite is the strategy adopted by the Irish Government that has launched increasing quantities of new 3-9mo bonds into the markets. "...Authorities should take the opportunity of the currently low level of real long-term yields to lengthen the maturity of issuance where possible to reduce their refinancing risk," says the IMF, implying in simple terms that you shouldn't really pile on short term debt at the time of a prolonged crisis.

For all its faults, even the IMF knows that you can't run the country on the back of credit card debt. But Brian, Brian & Mary wouldn't have a clue, would they? All their experience relates to managing a cash cow for the public sector unions that is our public purse.

Shock scenarios
More interesting stuff is in the IMF's modeling of financial shocks: Scenario 1 (pure credit shock with no fire sale of assets - more like a situation in the US in recent months) v Scenario 2(credit shock with fire sale of assets - a more relevant case scenario for the likes of AIB). Here are the results of the latter test:
In scenario 2, Australia shows 7 double-digit responses to shocks to other countries' financial systems, Austria, Italy, Portugal, Sweden & UK 6; Canada, Japan, Spain & US 5; France 8; Belgium, Germany & Ireland 9; The Netherlands 12; Switzerland 13. This hardly supports an assertion that we are driven by external markets crises in our own financial sector to any exceptional degree. Yes, we are less exposed than Switzerland and the Netherlands, but we are way more exposed than the many other countries.

The table below (it is the same table that was reported by me in December 2008) shows that we have the second highest (after Luxembourg) ratio of Bonds, Equities and Banks Assets to GDP in the world - a whooping 900%!

Furthermore, Table 23 provides some amazing evidence: Banks Capital to Assets in Ireland stood at only 4.1% in 2008, down from the high of 5.2% in 2003. Only Belgium and The Netherlands have managed to get lower ratio in 2008. Irish Central Bank actually provided these figures to the IMF and yet the CB has managed to do precious nothing to correct the steadily deteriorating capital ratios throughout 2003-2008 period. This, presumably is why we pay our CB Governor a higher salary than the one awarded to his boss, the ECB Chief.

So the 'comedy' part now being played in Dublin has a simple scenario that IMF, with its diplomatic mission, will not reveal to us, but that is visible to a naked eye though the prism of the IMF report:

1. Incompetent state regulators (CBFSAI and more) get golden parachutes for damaging the financial services sector and the economy;
2. Incompetent and greedy politicos are shielding their unions', banks' and developers' cronies from risk and pain caused by (1);
3. The ordinary people and businesses of Ireland are paying for (1) and (2).

And the markets still show willingness to powder this charade with 110% bids cover on Irish Government bonds? For how long?

IL&P: next in line? Update II

Per Irish Life & Permanent post last week - the predictions of the market downgrades for IL&P have materialised and by now are starting to be exhausted (barring any adverse news). IL&P is now likely to slide toward a general downgrade trend that has plagued the rest of the Irish banking sector.

Here are the updated charts reflecting the call I've made on IL&P last week.

Chart below shows that IL&P is still being pulled away from the rest of the banks, with the share price collapse being much more pronounced. The support for this momentum should be exhausted sooner rather than later, given a hefty sell volume hitting the market.
Chart above shows volumes relative to historic average, with current standing for IL&P sell-off at the local maximum. Again, in my view, this suggests some easing in volumes in days to come.

Chart below shows pure closing price (unadjusted for volume traded), with IL&P's nosedive being steeper than that for other banks. There is some room to travel down the price trend, but the downgrade over the last 3 trading days appears to me deep enough, so that, barring more adverse news, we should see settling of the share price into a gentler downward trend with wavering volume supports.
Finally, the chart below shows volume-adjusted sell-off of IL&P shares in line with the above charts.

Brian Lucey of TCD B-school was last night stressing the issues of the IL&P's uncertain balance sheet and the overall position of the bank in the greater scheme of financial services in Ireland (see Vincent Brown's program recording), although, sadly, this issue was not picked up by either Vincent or other panelists. It is time we put Anglo's saga behind us and start looking at the rest of the sector.

I am also starting to gradually shift into the unpopular view that while Anglo's own share support scheme (that €450mln loan-for-shares deal for the 'Golden Circle' investors) was wrong, ethically unsound and manipulative of the market, the 10 investors themselves (assuming the transaction was cleared by the Financial Regulator and other authorities) should not be scape-goated for their (stupid and financially ruinous) actions.

Instead of disclosing their names, we should demand the disclosure of the names of all incompetent (or negligent - take your pick) employees of CBFSAI who were engaged in clearing the Anglo deal. To date, the blame for the entire affair has been placed solely on the shoulders of private investors who took losses under their own commitments (reportedly covering 30% of the loans total). Instead, it should rest on the shoulders of the Irish regulatory authorities and those in the Department of Finance who knew of the deal and approved it. They are the truly rotten part of the system!

The end of the road?

Prepare for carnage once the markets open tomorrow. Per latest RTE report (here), Irish Life & Permanent admitted that it provided 'exceptional support' to Anglo Irish Bank following the taxpayers-paid-for Government [banks] Guarantee Scheme.

According to IL&P at the times of 'unprecedented turmoil' there was 'an acceptance that financial institutions would seek to provide each other with appropriate support where possible'. It is claimed that the transactions were fully and appropriately accounted for in the books and in regular reports to the Financial Regulator.

Anyone still surprised that the global markets are treating Irish equities as some sort of the corporate governance lepers? Any surprise that some institutional investors are no longer willing to hold any shares in the cozy cartel of 'supporters' that is Ireland Inc?

Here are some questions that must be asked immediately and with a view of taking up resolute corrective measures should any wrongdoing be uncovered:

1. Can these actions by IL&P be interpreted as a deliberate manipulation of the market? Corporate deposits are the components of bank's balance sheet that support share price valuations. Interbank loans - a normal procedure - are not. If deposits were made to provide 'support' to the Anglo, without an immediate publication of these deposits and their underlying causes to the markets, did IL&P and Anglo collude to alter the bank's balance sheet without revelation of this price-sensitive information?
2. Did IL&P deposits undermine own balance sheet and were they properly cleared through the risk-assessment process? Was IL&P shareholder value safeguarded in the process of making this gesture of camaraderie?
3. If IL&P did disclose such deposits to the Financial Regulator, why these deposits were allowed to proceed and why this information was not made public immediately? If the FR knew about the covert nature of deposits, were they de facto a party to concealment of a price-sensitive information?
4. We are all aware of the rumors that both the Guarantee Scheme and the Anglo's nationalization were carried out due to some critical events involving the Anglo and (in the case of the Guarantee) some other banks. Withdrawals of corporate deposits on a massive scale were rumored in late September and December 2008. Why is the Government unwilling to disclose the nature, the extent and the timing of these problems? After all, the Government is (largely rightly, I believe) using taxpayers money to shore up our financial system, committing tens of billions of our own and our children's funds to underpin the Guarantee, the nationalization and the bailouts.
   
5. At an even deeper level: has there been an implicit (hear-no-evil, see-no-evil) or explicit (via refusal by the Government to admit the nature and extent of the triggers for emergency measures) collusion between the Government and the banking sector to sweep under the rug the problems of governance and management at some of our financial institutions?

Not a single revelation about the mis-conduct events associated with the Anglo has been made public by the Government in a voluntary fashion. Not a single piece of information concerning the due diligence process in re-capitalisation decisions by the State has been made public by the Government. In light of this it is legitimate to ask questions of the Government as to the nature of the silence that shrowds the taxpayers' bailout of the banaking sector.

Over recent days there has been a lot of talk in the international finance circles about the skeletons hidden in the closets of Irish banks. Reputational capital of Ireland Inc is no longer running thin - it is, by now, about as hole-ridden as a slice of Swiss cheese!

Functioning markets require compliance with the letter and the spirit of law. The law requires that all price-sensitive information relating to the publicly listed companies should be disclosed in a timely and appropriate manner. The IL&P-Anglo case suggests that, potentially:

1. The law that supports functioning markets might have been severely breached; and
2. Public safeguards that were entrusted to enforce this market-supporting law might have comprehensively failed.

If this is the case, it is time for heads to roll. Now! Starting at the top of the Financial Regulator's office and right through to the companies involved.

And as per re-capitalization scheme, any injection of public money must be preceded by a comprehensive independent (internationally-administered) review of the banks' balance sheets and books, prior to any State-financed repairs can be made.