Economics 04/08/2009: NAMA, Liam Carroll & Short Termist Bonds

I should make it a habit to direct every NAMA post reader to my proposal for NAMA 3.0 here.


Yeps, Supreme Court came in on the side of the Government, throwing a lifeline to NAMA and forcing taxpayers into deeper losses. My earlier note stand now (see here) with all the gory implications for losses on Mr Carroll's loans now being back in the NAMA court.

But two birdies have chirped to me that there is more brewing up in the land of NAMA-fantasy. Apparently, the rumor has it, the Government plan is to issue short term bonds to cover NAMA liabilities. Given that NAMA will start issuing bonds in 2010 for this undertaking, the short term nature rumored is for a 2011-2012 bonds.

This, if true, makes no sense for several important reasons. Here are some:

(1) Issuing short-term debt with maturity before 2013 is equivalent to a financial suicide. The reason is simple - there is no credible (or for that matter even an incredible one) commitment from the ECB that

• such issuance can be rolled over at the same or lower interest rates to cover maturing bonds; and
• the EU will allow these bonds to remain off the balance sheet of the Government upon the roll over.
  

(2) Issuing short term bonds will be a fiscal suicide, for their maturity, and roll-over date, will fall dead on in the years of heavy Exchequer borrowing and maturity of other - 2008-2009 issued bonds. Given that the market demand for fixed income paper worldwide will be thinner then (due to increased appetite for equities-linked risk), a flood of rolled over bonds can risk derailing the borrowing programmes for Irish sovereign debt. Now, if you are a forward-looking investor, expect Irish yields to run away from the benchmarks once again, then.

(3) Short term maturity does not take into account the main risk to NAMA valuations, namely that by 2011 or for that matter 2013, the assets taken over by NAMA will be priced at any significant upside relative to what NAMA will pay for them, implying that, under short-term issuance, this Government will face the need to

• engage in a massive refinancing operations
  
• at the time when its balance sheet liabilities will be almost at their peak (see Department of Finance projections);
• pay higher expected cost of borrowing than today; and
• potentially, load the NAMA liabilities onto Government own balancesheet, while
• facing market prices and demand for real assets that is well below the valuations applied by NAMA.
  

If you look at the latter point. DofF uses 7 year U-shape cycle as its basic assumption. Peter Bacon last week stated that the cycle is expected to be 5-10 years. My estimations, based on NBER research (here), show that the average duration of the U-shaped cycle in historical data for OECD economies for 1970-2003 episodes of house prices collapse co-measurable with the one we are experiencing today is between 18 and 23 years. This range is dependent on how you time the cycle, but it refers to a nominal price cycle, unadjusted for Forex devaluations that accompanied such cycles in other countries and inflation. Japan (in down cycle since 1989-1990), Germany (since 1972-73), Italy (since 1981) and Sweden (since 1979) have not recovered to date.

Considering rolled up interest charges on impaired loans, banks' restructuring of interest payment schedules on so-called 'performing' stressed loans that in any other country would be classified as having defaulted, NAMA will be purchasing assets from the banks at an extremely shallow effective discount.

For example, a discount of 30% applied to a loan with 1.5 years (since July 2008 through December 2009) rolled up interest at 10%, and a built in re-financing cost of 1% will be equivalent to an effective discount of just 18.1% relative to the original principal of the loan itself. If, in the mean time, the underlying asset value itself has depreciated by, say 40%, then
NAMA will be buying a Euro 60 asset for Euro81.86. Now, in order for NAMA to recoup the original cost of purchase (not counting the cost of financing the purchase and managing the asset etc), the asset value needs to appreciate by a compound 36.4% within the span of the bond
finance. Thus between now and 2011 when the alleged bonds should mature, the annualized rate of appreciation required on the assets for NAMA just to recoup the original loan amount would have to be 16.8% per annum!

If anyone in the Department of Finance thinks this is a sane bet on a market turn-around, God help us.

Short-term financing of long-term obligations, as we should have learned in the current crisis, is equivalent to giving steroids to an unfit athlete and sending him out to run a marathon.

Though to repeat once again - this is just a speculation at this moment in time although two independent sources have tipped me on this one.

Economics 04/08/2009: NAMA & Liam Carroll - the saga continues

Oh, you have to love the drama and tension surrounding NAMA.

The latest thing to hit the rumour mill as we expect this afternoon our Suprem Court's rulling on Liam Carroll's appeal of the High Court decision to deny his companies examinership protection is that, allegedly, BofI and AIB are considering a buy-out of ACC Bank. Now, this is a rumor at this moment in time, and I have to stress this once again - it is a rumor - but given that:

• ACC can be, probably had for ca Euro130-140mln;
• ACC's books are so toxic (30% plus impairement across the property portfolio, 39% impairment across commercial property alone that its parent Rabo Bank would simply love to get rid of it for any sort of money;
• ACC's removal from the challenge to Liam Carroll and other developers would allow the big 3 of Ireland to continue on their chosen paths to the taxpayer-financed feeding trough of NAMA;
• ACC's buyout wouyld please the masters in the Government; and
• NAMA would more than compensate the buyer for the extra cost (say ACC is bought at a 50% discount to the book, then NAMA buys roughly 75% of former ACC 'assets' at 30% discount, implying a nifty return of Euro 5 per original expenditure of Euro 100, and you get to keep 25% of the ex-ACC assets too...

It would be no brainer for the AIB or BofI to load up on more toxic stuff to swap it for taxpayers cash.

From our, taxpayers' perspective, this is equivalent to throwing children off the sleigh in hope of holding back the wolves. The only hope we have at this stage is that a swift turning down of Carroll's appeal by the Supreme Court throws these schemes wide open.

Economics 03/08/2009: EU unemployment - no Green Shoots in sight

EU unemployment still climbing up: in June - the latest available data - 21.5 mln people, 8.9% of the labour force - were out of work in the EU27. The unemployment rate reached 9.4% for the Eurozone, the highest level since 1999. Spain (18.1%), Baltics (Latvia 17.2%, Estonia 17%, Lithuania 15.8%) led the EU27 in unemployment rate, followed by Ireland (12.2% and catching up).

The number of people unemployed increased by 246,000 in June relative to May. This is much slower than the gain of 646,000 recorded in March, but it nonetheless a continued increase.

So see if you can spot the 'green shoots' or bottoming out in unemployment that the EU has been talking about on the back of the latest figures (chart above). No flattening in the rate of increase since April 2009 moderation on March disastrous figures...

The above tow charts are rather telling as well.

Economics 03/08/2009: Lessons from Roubini for NAMA, Euro area GDP, Wages Falling in Ireland

NAMA has dominated newsflow in this country and on this blog. But the world around us still evolves to the laws that ignore the existence of the Senile Trio of Brian+Brian+Mary. So to recognize this - few housekeeping items that built up over the week.

First, the Eurocoin is out and it is time to update my Euroarea GDP projections. Chart below summarizes.Main features to note:

• Eurocoin improved in July, for the 5th month in a row;
• My forecast for Eurocoin to move in August and September marginally down from its current -0.42 position to -0.44-0.45 and stay there through September/October, awaiting a decisive move (either up or down - a 50:50 chance from this point in time) for either an W-shaped recession or something with a single (albeir of unknown duration) bottom;
• My forecast for June and July Euro coin came in relatively well -0.52 as opposed to Eurocoin measured -0.61 to -0.42. Bang-on in the middle.

Nouriel Roubini’s RGE Monitor also expects “the cyclical recovery in the eurozone [to be led by Germany and France and] to lag recovery in the US, the BRICs and non-Central and Eastern Europe (CEE) emerging markets”. This is relatively consistent with my expectation for Eurozne to bottom out in the sub0cycle around November-December 2009. Assuming there is no double dip. “Among the main factors muting Europe’s recovery in 2010 are a permanent decline in potential output; unwinding pressures of large internal imbalances leading to deflationary pressures; a more restricted monetary and fiscal policy response compared to the U.S. and especially to China; a leveraged financial sector with too-big-to-fail institutions and too-big-to-save features; and a strong reliance on bank funding by the corporate sector subject to a larger financing gap than that seen in the US.”

There are interesting NAMA-related bits in Roubini’s forecasts: “In order not to impair the banking sector’s lending ability permanently, a quick disposal of bad assets is warranted. Lending to the private sector is slowing quickly, and for small and medium sized enterprises with no access to capital markets, bank credit lines represent the only recourse for liquidity. Based on IMF and ECB estimates, total bank losses in the eurozone will amount to between $650 billion and $900 billion, implying substantial additional recapitalization costs.” So two things jump out:

1. NAMA is going to draw down ca €90bn of taxpayers funds to repair, hmmm €90bn in banks bad debts. Across the entire Eurozone, a 7% Tier 1 capital requirement against the backdrop of $650-900bn in total banks losses expected by Roubini will require (RWA inclusive) around €52-73bn in recapitalization costs – €37-51bn. The idiocy of NAMA is that we will spend more in recapitalizing our puny banking system than would be required to support the entire Eurzone! This shows why the IMF (see here) thinks that direct equity take over by injecting capital into the banks works more efficiently than what NAMA is proposing to do.
2. The second point of relevance to NAMA is that of speed of repairs. Roubini is clear that time is of essence. Of course, our Brian+Brian+Mary squad has sat on their hands for over a year now, doing preciously little other than panic-driven measures (blanket guarantees, rash recpaitalizations without proper equity transfers, nationalization of the dodgiest bank possible, followed by another rash recapitalization round, NAMA announcement, the extension of the guarantees…) But even more interesting is the fact that even if everything goes as planned by our Triumvirate, NAMA repairs will not bite in until January 2010 – 29 months after the crisis in the global financial markets started to unfold and 17 months after this Government bothered to recognize the reality of the challenges we face. If that is ‘a quick disposal of bad assets’ that ‘is warranted’ per Roubini, God help us.
   

In the mean time, ISME survey (2,000 firms participating) last week showed new rounds of wage cuts unfolding in Irish SMEs. main highlights are:

• 94% of SMEs have introduced pay cuts / freeze since the start of the year, 45% have introduced a pay cut, with 49% implementing pay freezes. Only 6% paid some wage increases;
  
• 50% of the companies cut working hours;
  
• Average pay cut was so far 13%;
• 26% of companies are still planning fresh redundancies in the next 3 months (August-October).

Summary tables (both courtesy of ISME):
Jack O'Connor of SIPTU was not available for a comment on these.

Economics 02/08/2009: An idiot's guide to tax policy

Remember that senile reply that the Irish Times has published to my conjecture that higher taxes in Irish airports will hurt Irish tourism and ultimately will cost the Exchequer? Feel free to refresh this case here and here - the original piece that caused the Irish Times editorial page implosion).

Well, don't take my word for it, or CSO's figures - these are not sufficient for our wise ex-IMF Directors. Here are the hard jobs...

"Ryanair, the World’s favourite airline, today (30 July 09) announced 20% flight cuts at its Dublin base for the coming winter schedule (09/10). Compared to winter 2008/09, when Ryanair based 18 aircraft, and operated 1,200 weekly flights, Ryanair’s Dublin schedule this winter will be cut by 22% to 14 based aircraft with 20% fewer flights at less than 1,000 each week. Ryanair estimates that its Dublin traffic this winter will decline by a further 250,000 passengers compared to last winter’s figures, as Dublin Airport loses over 2m passengers overall in 2009.

Ryanair’s decision to cut based aircraft flights at Dublin Airport is for the following reasons:
a) Dublin is one of Ryanair’s two most expensive base airports (Stansted is the other).
b) Costs at the DAA monopoly continue to increase at above inflation rates.
c) The Aviation Regulator continues to rubber stamp unjustified Dublin Airport cost increases while costs at most other UK and European airports are falling.
d) The Irish Govts €10 tourist tax makes Ireland an uncompetitive tourist destination at a time when other European Governments have scrapped their tourist taxes.
e) Traffic at Dublin airport is collapsing (down 11% or 1m fewer pax in the first half of 2009) under the weight of these high airport fees and this stupid tourist tax.

The fact that the DAA monopoly are proposing further price increases at a time when most other UK and European airports are reducing their prices, highlights the damage being done to Irish aviation and tourism by this high cost, inefficient, badly run airport monopoly. Ryanair has repeatedly called on the Government to scrap the €10 tourist tax which has had an equally devastating impact on Irish tourism. Ireland cannot grow tourism by taxing tourists. The Belgian and Dutch Governments have recently scrapped their tourist taxes, and the Spanish and Greek Governments have reduced their airport fees in some cases to zero this winter in order to reverse traffic declines.

Ryanair’s Michael O’Leary said: “...The high and rising costs at Dublin Airport, combined with an insanely stupid €10 tourist tax, are devastating tourism here in Ireland. These cuts come just one day after Ryanair announced 39 new routes to the Canaries this Winter where the Spanish Government has reduced airport fees to zero. Last week Ryanair announced 11 new routes to Oslo airports this winter where again airport fees have been substantially reduced. The response of the Government owned DAA monopoly to this 11% traffic collapse is to seek yet further price increases! The incompetent Irish Aviation Regulator has already proposed that Dublin airport charges for 2010 onwards will be “18% higher” than they would be if the DAA’s traffic was not declining. Sadly the DAA gets rewarded by the regulator with price increases for its abject failure to grow and stimulate traffic."

So how much revenue to the economy and the Irish Exchequer is being lost? May be Michael O'Leary can sum it up.

I have nothing to add, other than perhaps to ask the Irish Times editorial team to filter economically illiterate arguments out of its pages in the future - just because someone writing an article signed 'ex-director of IMF and career ex-civil servant from Ireland' doesn't mean that they actually have much to say that is valid. Quite likely, it means the opposite...

Economics 02/08/2009: Liam Carroll's case

For those of you who missed, here is my article from Saturday edition of Irish Daily Mail

An Irish person recently remarked to me in the context of NAMA that “If any other electorate in Europe, nay, the world, faced this scandal, their citizens would be on the streets.” They would. We have been led to believe that NAMA is a necessary solution for the banks having to write down the odious development debt acquisition of which over the years past was cheered on by the Government through tax breaks and the stamp duty widnfalls. In reality, NAMA is Ireland’s own financial Chernobyl – a self-inflicted devastation of taxpayers’ finances perpetuated for the sake of doing something about the crisis.

By denying the examinership to Liam Carroll’s six companies, the Irish High Court has put itself out as the sole branch of State that stands between the innocent taxpayers and this redlining reactor.

First, let me clearly state that I have no objection to proper developers who build what is truly demanded by the market. They too will be the victims of the NAMA debacle.

Pursued by a creditor, the ACC Bank, Liam Carroll has been languishing in the High Court for a better part of this week, awaiting a decision on whether he will be granted an examinership for six of his companies. An alternative for Mr Carroll was to face an appointment of a receiver – a sure bet that his companies will be shut down. This alternative has now come to its logical fruition – denying Mr Carroll the examinership, the court has forced him to face the music. Receivership is now all but inevitable.

The motivation behind this battle was NAMA. Mr Carroll would like his companies debt to be assumed by the state, allowing for them to continue as an ongoing concern. Mr Carroll even hoped to convince the folks running the bad bank to give him few quid to finish some of his
failed projects. A pipe dream for a businesses that, by his Senior Counsel’s admission generates just €22-23 million in annual revenue against the debts of roughly €1.4 billion. Now, do the maths – a company that was supposed to be bought by us, the taxpayers into NAMA will not be able to cover even 15% of its annual interest bill.

Mr Carroll’s case has serious implications for us all – the Irish taxpayers – as the underwriters of NAMA.

Mr Carroll’s Senior Counsel Michael Cush told the court that the six companies in question, had historically been very successful businesses. But he said more recently they had suffered credit problems, the downturn in the property market, and some “problems with investments”. Per Mr Cush, the companies are clearly insolvent and if liquidated, their unpaid debts will reach €1 billion. This indicates that there is no hope for a recovery of the business and that examinership was rightly denied to them.

But it also shows that there is not a snowballs chance in hell that NAMA will be able to recover any positive value from Mr Carroll’s companies, unless it forces his banks to write down at least €1 billion of some €1.4 billion in loans amassed. That NAMA will do nothing of the sorts, preferring to continue the circus of pretending that these businesses worth something in excess of their debts is clearly something that the courts disagree with.

The NAMA legislation published this Thursday states that the taxpayers will be paying for the current values of the banks loans, while the developers will be pursued for the original loans amounts. Mr Carroll’s case illustrates that currently insolvent businesses continue to accumulate liabilities (rolled up interest and fresh demands for continuity funding) that simply cannot be repaid, ever. These roll up debts are odious, for they are extended to the clearly insolvent companies in the hope that NAMA will simply cover them at a higher rate than the markets would were the banks to go out into the open trying to liquidate these development loans.
Which means that NAMA will be using our money to pay for the rolled up interest on top of already grossly overvalued loans of insolvent enterprises.

Do a simple math, with a 50% fall in the value of underlying assets, 11% interest charge on the non-performing loans and a 25% NAMA discount, the taxpayers will be overpaying for the assets they by to the tune of 70% plus. Put simply, imagine walking into a shop and seeing a TV set on sale. The sign reads: ‘Sale! Original price €100. Sale price €170”. That does look like Minister Lenihan’s bargain for the taxpayers.

Liam Carroll’s case also shows that over the last year, soft budget constraints for insolvent businesses, like Liam Carroll’s empire, were accepted by the banks solely on the anticipation of a state bailout. If not, these banks actively engaged in destroying their shareholders’ wealth by undertaking knowingly reckless decisions. Take your pick.

I have absolutely nothing against Mr Carroll's enterprises, other than the simple argument that if they are insolvent today, the should be shut down today and they should not be allowed to accumulate additional liabilities at our, taxpayers' expense.

The examinership case for Mr Carroll’s companies was not warranted from day one of his application to the court. Minimizing losses to the economy and the taxpayers resulting from his companies farcical ‘operations’ required an appointment of a receiver and no restructuring period under the examinership would have done any good to their solvency. If only the same wisdom of the courts can be applied to NAMA itself.

NAMA 3.0: A real alternative

I was bemused to learn that a number of my economics colleagues are apparently starting to 'discover' the idea of resolving the banking crisis through the use of a voucher-styled equity acquisition in Irish banks and disbursement of these to the taxpayers. Oh, it makes me glad that potentially some of them - possibly including even those who would not give me a fulltime job in their august departments - are now coming around to accepting some of my original ideas.

So to clearly draw a line in the sand, I espoused the idea of voucher-styled recapitalization of Irish banks on the pages of Business & Finance, with Prof Brian Lucey (the only person who saw, amongst academics, any merit in this idea from the start) in the pages of the Irish Times, in the Sunday Times and in the Irish Independent, as well as, of course, on this blog. But my entire view on how the banking crisis should be handled is summarized here:

Step 1: Require banks to take full mark-to-market writedown on their loan book;
Step 2: Travel down the capital ranks to draw down shareholder equity, deplete perpetual bond holders and so on to cover the writedowns;
Step 3: Force the bond holders into debt for equity swap;
Step 4: Open enrollment for a share-participation in Irish banks recapitalization to SVFs, vulture funds and any other form of private capital;
Step 5: Cover all remaining shortfalls in capital base with Government bonds swapped for equity after Steps 1-4 are completed and after an independent assessment of the value of the remaining loans is carried out to determine the true extent of banks under-capitalization;

Step 6: Hold equity in an escrow account (NAMA3.0) on behalf of the taxpayers, appointing a Supervisory Board to every bank recapitalized by the taxpayers money. The SB should consist of one appointee by the Minister for Finance, 3 direct independent representatives of the taxpayers, who are charged with explicitly guarding the taxpayers' interests, 1 representative of the bank board, 1 representative of NAMA3.0 and 1 independent director. Each member (other than those from NAMA3.0 and the bank) will hold a veto power. A requirement that risk and credit committees of NAMA3.0 include at least 51% majority of independent experts who cannot be employees of the state, NAMA3.0 or any other parties to this undertaking;

Step 7: NAMA3.0 accountability: no indemnity for negligence and incompetence for any employee or director of the escrow organization; no cross borrowing by the Exchequer from NAMA3.0 is allowed, so Brian Lenihan and his successors cannot raid the nest egg; ownership of shares in the account accrues to the taxpayers, not to the state or the public sector; NAMA3.0 cannot lend money to continue any of the banks' projects;

Step 8: NAMA3.0 transparency: full disclosure of all recapitalization acts and shares held in NAMA3.0 - on the web, updated live; full disclosure of all employment contracts, wages, bonuses etc, CVs of all managers and directors and disclosure of all potential conflicts of interest; full disclosure and updating of the comprehensive NAMA3.0 balance sheet, cost/benefit analysis of the undertaking and live weekly mark-to-market report on the value of shares held;

Step 9: NAMA3.0 operational efficiencies: NAMA3.0 can, with consent of the Minister for Finance and in orderly (market-respecting) fashion disburse all or a part of its shareholdings so as to maximize the return to the taxpayers. This disbursal should be fully notified to the public immediately post execution, with price achieved fully disclosed. NAMA3.0 will then have 30 days to issue every resident of this country - registered at the date of creation of NAMA3.0 - his or her share of the sale proceeds net of NAMA3.0 operating costs and a special withholding tax of 25% on CGT, in a form of the cheque;

Step 10: NAMA3.0 legal remit over assets: NAMA3.0 in recapitalizing the banks will have a mandate to help the banks collect on outstanding loans by aiding them in seizing requisite collateral. In doing so, NAMA3.0 will have to agree a procedure to address problems of cross-collateralization of specific assets. NAMA3.0 will have a right to impose seize borrower's property (applicable only to developers) when such property has been legally shielded from authorities or banks at any time after July 2008.

Step 11: Conditions for banks' participation in NAMA3.0 banks wishing to participate in this undertaking will be required to adhere to the following rules, including, but not limited to, the caps on executive compensation at the banks and the requirement to set up fully independent, veto-wielding risk assessment committee at each bank with a mandatory requirement for a position of a taxpayers' representative on the board that cannot be occupied by a civil servant or anyone who has worked in the Irish banking or development industry in the last 10 years;

Step 12: Re-legitimising the public system of regulation in Financial Services: as a part of NAMA3.0, the Government must address the ever-widening crisis of markets, investors' and taxpayers' trust in the Irish system of Financial Services regulation. Many steps must be taken to address this problem, and these can be worked out over time - suggest away. But in my view, there must be a stipulation that all and any regulatory authorities (and their senior level employees) that were involved in regulating the banking and housing sector in this country until now must be forced to take a mandatory pension cut of 50%, a salary cut to put them at -10% relative to their UK counterparts wages, and return any and all lump sum funds they collected upon their retirement. The Government must impose measures to prevent banks from beefing up their profit margins through squeezing their preforming customers. The measures to force the banks to reduce their cost bases by laying off surplus workers must be enforced. From now on, every regulatory office should be required to publish all minutes of its meetings, disclose all its voting, decisions and rulings to the public, create a public oversight board that must include members of the Dail from non-Governing Parties, a taxpayer representative and independent directors.

This is a sketch of NAMA3.0. Please feel free to build a bigger picture with me

Economics 1/08/2009: NAMA - alternatives Part IV

June 2009 paper from the IMF, titled The Economics of Bank Restructuring: Understanding the Options by Augustin Landier and Kenichi Ueda is something Minister Lenihan and indeed the entire Irish Cabinet should have read, and probably would have read if their economic advisers actually did their jobs. But, of course, the readers of this free (unlike Alan Ahearne's advice) blog can read it here.

Here is a summary (italics are mine):

"This note ...evaluates various restructuring options for systemically important banks. The note assumes that the government aims to reduce the probability of a bank's default and keep the burden on taxpayers at a minimum [a tall assumption for own Government, but hey...].

...If debt contracts can be renegotiated easily, the probability of default can be reduced without any government involvement by a debt-for-equity swap. Such a swap, if appropriately designed, would not make equity holders or debt holders worse off. However, such restructurings are hard to pull off in practice because of the difficulty of coordinating among many stakeholders, the need for speed, and the concerns of the potential systemic impact of rewriting debt contracts.

When debt contracts cannot be changed, transfers from the taxpayer are necessary. Debt holders benefit from a lower default probability. Absent government transfers, their gains imply a decrease in equity value. Shareholders will therefore oppose the restructuring unless they receive transfers from taxpayers.

The required transfer amounts vary across restructuring plans. Asset sales are more costly for taxpayers than asset guarantees or recapitalizations. [We know thi - NAMA will ask us to pony up €60bn in bonds, plus another €10bn+ in recapitalization funds on top of already awarded €7bn+ - all for bailing out a system that in its entirety is worth no more than €10bn]. This is because sales are not specifically targeted to reduce the probability of default. Guarantees or recapitalizations affect default risk more directly. Transfers can also be reduced if the proceeds of new issues are used to buy back debt.

Depending on the options chosen, restructuring may generate economic gains. These gains should be maximized. Separating out bad assets can help managers focus on typical bank management issues and thereby increases productivity. Because government often lacks the necessary expertise to run a bank or manage assets, it should utilize private sector expertise [Now, if you read NAMA legislation, the system will rely on NAMA-own employees to run risk and credit committees - what 'private sector expertise'?]. Low up-front transfers can help prevent misuse of taxpayer money [Well, NAMA will have up-front transfers of some €60bn!In contrast, my proposal for the banks to take market-driven writedowns before NAMA transfers would minimise this.]. Moreover, the design of bank managers' compensation should provide incentives to maximize future profits.

If participation is voluntary, a restructuring plan needs to appeal to banks. Bank managers often know the quality of their assets better than the market does. This means banks looking for new financing will be perceived by the market to have more toxic assets and, as a result, face higher financing costs. Banks will therefore be reluctant to participate in a restructuring plan and demand more taxpayer transfers. A restructuring that uses hybrid instruments - such as convertible bonds or preferred shares - mitigates this problem because it does not signal that the bank is in a dire situation. [Of course, NAMA is all about one instrument - taxpayers' cash] In addition, asset guarantees that are well designed can be more advantageous to taxpayers than equity recapitalizations. [Well, of course we had no 'well-designed' guarantees - we have a blanket guarantee. And thus we also have subsequent recapitalizations. And now NAMA. And after NAMA - more recapitalizations... I mean this Government and its advisers wouldn't last long in a junior policy research job at the IMF...] A compulsory program, if feasible, would obviously eliminate any signaling concerns. Information problems can also be mitigated if the government gathers and publicizes accurate information on banks' assets. [NAMA is a compulsory programme. And yet, despite the IMF advice, it is reliant on a sweet-heart deal for the banks with total disregard for the taxpayers' interests. Reckless? Venal? You decide.]

In summary, systemic bank restructuring should combine several elements to address multiple concerns and trade-offs on a case-by-case basis. In any plan, the costs to taxpayers and the final beneficiaries of the subsidies should be transparent. [NAMA legislation makes its operations fully concealed from any public scrutiny and fully indemnified against any charges of reckless waste of taxpayers' resources. It even makes it impenetrable to the courts.] To forestall future financial crises, managers and shareholders should be held accountable and face punitive consequences. [This is explicitly prevented in the NAMA legislation] In the long run, various frictions should be reduced to make systemic bank restructuring quicker, less complex, and less costly.

I rest my case. In a nutshell, even by IMF standards, NAMA is a monster that will willingly or recklessly defraud the Irish taxpayers.

Economics 01/08/2009: Wealth Tax

Someone asked me recently to confirm my assertion - made few months back on TV 3 programme - that a 100% tax on wealth of the Irish members of the Sunday Times Rich List 2009 will last this Government, oh, well, under 5 months.

After actually computing the total ROI-based wealth from the List and taking some adjustments, Table below shows clearly the break down of such a (extremely foolish) tax. Of course, this is a fantasy land, but it does highlight for me the idiocy of our Left wing fanatics.

As you can see, a brutish calculation puts the net take from such an exercise at a maximum of €30bn one-shot gain for the Exchequer - or an equivalent of 4 months and 22 days of Government spending (I was pretty much on target in my original statement).

Factoring in the fact that large chunk of this wealth is held by property investors and construction firms owners, whose wealth has been evaporating since December 2008 when the list was compiled and that the list reflects their wealth as assessed on last filed accounts (2007 or earlier), and taking into account that any half-sane person would diversify her holdings geographically, putting a share of her assets out of reach of the Irish Exchequer, this figure drops to €18bn, or 2 months 25 days worth of Government spending planned for 2010.

Taking into account legal costs and assets seepage during the process of collection, the entire Irish Top Rich List 2009 wealth, if it were seized by the Government, would last our Exchequer no more than 2 months and 17 days.

But, one has to take into the account the facts that:

• public spending economic multiplier is zero, while
  
• private spending multiplier is a positive number dependent on the Marginal Propensity to Consumer out of Wealth, Marginal Propensity to Invest out of Wealth-generated income, the returns to wealth and the velocity of money in this economy; and
• the fact that the Exchequer collects revenue from this wealth

all of which will be foregone if the Exchequer were to seize this wealth in one swoop.

When these factors are accounted for, the Exchequer will be covered for only 1 month and 27 days by the 100% levy on all wealth of the ROI Top Rich List 2009.

What a pack of morons represent economic arguments of the Left of this country!

Economics 31/07/09: NAMA Part III

The NAMA Legislation provides some stunningly simplistic and outright primitive economic analysis. This is contained in Part 5 of the Bill (once again, italics are mine):

PART5: VALUATION METHODOLOGY

Determination of acquisition values—valuation methodology.

58.—(1) In this section—
(a) a reference to the current market value of the property comprised in the security for a credit facility that is a bank asset is a reference to the estimated amount that would be paid between a willing buyer and a willing seller...
(b) a reference to the current market value of a bank asset is a reference to the estimated amount that would be paid between a willing buyer and a willing seller in an arm’s-length transaction...

[In other words, the difference between the two values is that the property value is a valuation of the collateral, while the asset value is the valuation of the loan drawn against this collateral as an asset. This difference should capture: counterparty risk, liquidity risk, expected return risk, lien risk and term structure risks. None are specified or explicitly required for pricing in the NAMA legislation.]

(c) a reference to the long-term economic value of the property [bank asset, per point (d) below] comprised in the security for a credit facility that is a bank asset is a reference to the value that the property can reasonably be expected to attain in a stable financial system when current crisis conditions are ameliorated and in which a future price or
yield of the asset is consistent with reasonable expectations having regard to the
long-term historical average...

[So, implicitly, this statement assumes an imposition of some assumptions on:

• What constitutes a stable financial system and how does this system impact the pricing in operative markets - something that is virtually impossible to ascertain as the only functional markets we have a history of relate to the property bubble period? Was our financial system stable when we were lending x10 times income to home buyers? Or was it stable when the likes of AIB were embroiled in a series of massive scandals?
  
• What constitutes an amelioration of the current crisis - with further issues arising as to what crisis is being meant in this context: the crisis in property markets? in banking? in credit supply? in money supply? in financial assets? in the economy at large? in the Exchequer revenue? in the labour markets? in the markets for land sites? or in demographics? or in all the above?
  
• What is the relationship that determines the future (expected?) price of an asset or a yield on the asset and what is the assumed relationship between the yield and the price? What determines the relevant expectations mechanism?
  
• What is the long-term historical average? A 10-year historical average taken from today back 10 years is one thing. A 5 year one is another. Yet a third number can be obtained if the historic average is taken back from some date in the past (say 2007 to 1998) and so on. In reality, there is an infinite number of long-term historic averages that can be taken. Which one will be selected and on what basis is never attempted to be answered in the document.]
  

(2) Subject to subsection (4), the acquisition value of a bank asset is its long-term economic value as determined by NAMA.

[Well, see above on long-term economic valuation, but in effect this is the statement that says it all - there is no price, there is no pricing model, there is not even a hint at the pricing model fundamentals. This is a botched economic analysis that would not warrant a permission to buy a typewriter for the DofF, let alone to 'invest' Euro 90bn into any undertaking. And this problem is compunded by the fact that this Bill seals the hatches on risk and credit committees operating NAMA by requiring that their members be NAMA employees or directors and not establishing any independent presence on these committees. This is like having a reactor heading into a meltdown and shutting down your monitoring systems because they are flashing red.]

(3) NAMA shall determine the long-term economic value of a bank asset by reference to the following:
(a) the current market value of the property comprised in the security for the credit facility that is the bank asset at a date specified by NAMA;
(b) the current market value of the bank asset, at a date specified by NAMA, by reference to market rates and accepted market methodology;
(c) the long-term economic value of the property referred to in paragraph (a) at the date referred to in that paragraph...

[This is incomprehensible gibberish, folks. It has neither any meaning nor economic or financial justification whatsoever. There are no accepted market rates, for there is no market for these securities and/or assets other than at extremely deep discounts that Minister Lenihan has already ruled out. The legislation provides nothing for testing the market - as I suggested in one of the required bullet points below.]

(4) NAMA may, if it considers it appropriate after consultation with the Minister, and subject to any regulations made by the Minister under subsection (5)... determine that the acquisition value to be assigned to particular bank assets or class of bank assets shall be—
(i) their current market value, or
(ii) a greater value (not exceeding their long-term economic value) that NAMA
considers appropriate in the circumstances.
[But not a lesser value, note. And once again, since there is no market value or a mechanism to attempt establishing some market value testing, this means NAMA will pay above market value for all assets. Furthermore, this section explicitly commits NAMA to use taxpayer funds to pay the real price or more for the given loan! Sickened yet? Ok, let me explain in a bit more detail. There is an auction with only one bidder. The bidder has stated up front that he will pay any price at or above the market price. But there is no market price. Where do you think the seller will set the opening bid at? If the implicit market value, known to the seller, but not the bidder is X, the seller will set an opening bid at X+y, where y is a positive premium on the 'stupidity' of the buyer or on the fact that the buyer has committed to buying the asset and is willing to pay above the market value for it. What will be the reservation price set by the seller? X+y+z, where z is a positive premium on 'desperation' of the buyer to acquire the asset. What will be the price paid by the buyer? X+y+z+v, where v is the premium on seller's skills in convincing the buyer to purchase the asset. v is also non-negative. Done. Basic auction theory, folks. Incidentally, adopting the approach advocated by me in the bullet points below removes: y through forcing the banks to take realistic writedowns first prior to NAMA; and removes z by requiring a simulative establishment of the market which can test the actual price of at least of the assets. One can't really remove v, for the smarter bankers will always be able to sell to the careless or incompetent, or both, authorities that can author this document in the first place.]

(6) In determining the acquisition value of a bank asset under subsection (2) or (4), NAMA shall have regard to the following:
(a) any value that the participating institution concerned submits as being, in its opinion, the current market value of the property comprised in the security for the credit facility that is the bank asset [that's X above];
(b) the acquisition value already determined in accordance with the valuation methodology of another similar bank asset [thats y derived from previous sales];
(c) the credit worthiness of the debtor or obligor concerned [that's v above];
(d) the performance history of the debtor or obligor in respect of that asset [that's v above];
(e) any reports furnished to NAMA in relation to the matters specified in subsection (7) whether prepared before or after the commencement of this Act [that's z above].

[So to recap: NAMA paid price for an Asset = X+y+z+v, where X is 'true' value of the asset; and (y+z+v) is a strictly positive premium accruing to the bank from the economic illiteracy written into this legislation!]

I have covered section 59 of the Act already in the previous post.


I will repeat the list of provisions that must be required before NAMA can be allowed to proceed in every post on NAMA from ehre on:

• Provisions for taxpayer protection and provision for a taxpayers' oversight board filled with only independent observers, who are not in the employment of NAMA, NTMA, the State or any other party to NAMA undertaking;
• Complete and comprehensive balance sheet and cost/benefit analysis of the undertaking;
  
• Exact upper and lower limits for banks equity the taxpayers will receive in return for NAMA funds and post-NAMA recapitalization funding;
• The exact procedures for divesting out of the banks shares in 3-5-7 years time with exact legal commitment by the state to disburse any and all surplus funds (over and above the costs) directly to the taxpayers in a form of either banks shares or cash;
  
• The formula for imposing a serious haircut (60%+) on banks bond holders, possibly with some sort of a debt for equity swap and a restriction that NAMA cannot purchase any rolled up interest acrued since the latest 'restructuring' of a loan;
• A recourse to all developers' own assets - applied retroactively to July 2008 when the first noises of a rescue plan started;
• The list of qualifications for any bank to participate in NAMA, including, but not limited to, the caps on executive compensation at the banks and the requirement to set up a truly independent, veto-wielding risk assessment committee at each bank with a mandatory requirement for a position of a taxpayers' representative on the board that cannot be occupied by a civil servant or anyone who has worked in the industry in the last 10 years;
• A requirement that risk and credit committees of NAMA include at least 51% majority of independent experts who cannot be employees of the state, NAMA or any toher parties to this undertaking;
  
• A condition that the banks must undergo loan book evaluation prior to transfer of any loans to NAMA, the results of which will be made public - on the web - instantaneously - and will impose a requirement on the banks to write down their assets, again before NAMA purchases any of them, by the requisite amounts to balance their own books in line with valuations;
• A condition that any loan purchased by NAMA be placed on the open market for the period of 2 weeks and that NAMA will not pay any amount in excess of the bids received (if any), with a prohibition for the participating banks to bid on these loans;
• A condition that every NAMA loan should be publicly disclosed, including its valuations and bids it receives in the auction stage of the process;
  
• A stipulation that all and any regulatory authorities (and their senior level employees) that were involved in regulating the banking and housing sector in this country take a mandatory pension cut of 50% and return any and all lump sum funds they collected upon their retirement;
• A provision for dealing with the speculatively zoned land to be acquired by NAMA, i.e orderly de-zoning of this land and transfer of this land to either public (if no bidders arise) or private use consistent with sustainable agricultural development, environmental improvements, public use or forestry;
  
• The measures to prevent banks from beefing up their profit margins through squeezing their preforming customers;
• The measures to force the banks to reduce their cost bases by laying off surplus workers;
• The measures for accounting (in a transparent and fully publicly accessible fashion) on a quarterly basis for NAMA operations and the performance of the state-supported banks.

If I forget something, please, let me know...

Economics 31/07/2009: NAMA Part II

And now slightly more on theat NAMAster:

Remember the levy that the Government dangled in front of the taxpayers as a sign of loss protection or minimization to be built into NAMA. Well, word 'lvey' does not appear in the entire legislation. Not even in a tocken fashion. Not even as a lip service.

And yet, bad and all as this idea might have been, the levy on the banks was announced by Minister Lenihan, repeatedly, as the only means for recouping losses on NAMA. As a friend and colleague remarked, "even that figleaf of taxpayer saving is gone'.


The document reads:
"In making regulations under subsection (1), the Minister may [my emphasis] have regard—
(a) to the rules in relation to State aid and any relevant guidance issued by the Commission of the European Communities [as if he can avoid this under the EU rules], and

(b) in relation to the determination of the long-term economic value of the property comprised in the credit facility that is a bank asset, to—

(i) the extent to which the price or yield of the asset has deviated from the long-term historical average [the half-wits who wrote this don't even understand that our historical averages are so severely skewed by a lengthy bubble in the property markets, that a return to these averages will take well over a decade],

(ii) supply and demand projections by reference to the type of asset and its location,
(iii) macroeconomic projections for growth in the gross domestic product and for inflation,
(iv) demographic projections,
[Who is going to supply these projections? Our forecasters - the DofF, the CB, let alone completely inadequate Forfas and Fas - are so grossly inaccurate in their usual predictions that you might as well use a crystal ball. One good example is the CB - this institution has been frantically issuing new forecasts on a monthly basis in order to catch up with the published forecasts by the private sector.]

(v) land and planning considerations (including national, regional or local authority development or spatial plans) that may exert an influence on the future value of the asset concerned,
(vi) analyses presented by the Minister of the Environment, Heritage and Local Government on the extent to which existing land zoning and planning permissions granted and in force meet or exceed projected growth requirements, and
(vii) analyses presented by the Dublin Transport Office and the National Transport Authority of existing and future transport planning and the associated supply and demand projections for land use.
[As I told the meeting of the Green Party recently, all of this means only one thing - the fig leaf of decorum awarded to the Green Ministers for their singing on the dotted line will see NAMA as a continuation of the development patterns that were based on utterly mad and unsustainable vision of spatial development in Ireland. In effect, the Green Party has lost all and any moral ground to stand on when it signed up to the development model (under NAMA) that cuts across the entire philosophy of the Greens.]

(c) in relation to the determination of the long term economic value of bank assets, to—
(i) the long-term economic value of the property comprised in the security for a credit facility that is a bank asset,
(ii) the net present value of the anticipated income stream associated with the loan asset,
(iii) in the case of rental property, current and projected vacancy rates,
(iv) loan margins,
(v) an appropriate discount rate to reflect NAMA’s cost of funds plus a margin that represents an adequate remuneration to the State that takes account of the risk in relation to the bank assets acquired by NAMA,
(vi) the mark-to-market value of any derivative contracts associated with the bank asset,
(vii) any ancillary security such as personal guarantees and corporate assets,and
(viii) fees reflecting the costs of loan operation, maintenance and enforcement, and

[This lengthy passage tells me right away that NAMA will operate as a banking sector's out of town office. The primacy of taxpayer protection absent in the legislation and the length afforded to the protection of the banks' bottom line is the destruction of the private sector economy on the vast scale. Incidentally, it is also a sealing of banks into servitude to the Exchequer, implying that from the day of NAMA instituion, Bank of Ireland, AIB, IL&P and other participating banks will be Japanese-styled zombies. A short-term pain relief turns a long term cancer!]


I will repeat the list of provisions that must be required before NAMA can be allowed to proceed in every post on NAMA from ehre on:

• Provisions for taxpayer protection and provision for a taxpayers' oversight board filled with only independent observers, who are not in the employment of NAMA, NTMA, the State or any other party to NAMA undertaking;
• Complete and comprehensive balance sheet and cost/benefit analysis of the undertaking;
  
• Exact upper and lower limits for banks equity the taxpayers will receive in return for NAMA funds and post-NAMA recapitalization funding;
• The exact procedures for divesting out of the banks shares in 3-5-7 years time with exact legal commitment by the state to disburse any and all surplus funds (over and above the costs) directly to the taxpayers in a form of either banks shares or cash;
  
• The formula for imposing a serious haircut (60%+) on banks bond holders, possibly with some sort of a debt for equity swap and a restriction that NAMA cannot purchase any rolled up interest acrued since the latest 'restructuring' of a loan;
• A recourse to all developers' own assets - applied retroactively to July 2008 when the first noises of a rescue plan started;
• The list of qualifications for any bank to participate in NAMA, including, but not limited to, the caps on executive compensation at the banks and the requirement to set up a truly independent, veto-wielding risk assessment committee at each bank with a mandatory requirement for a position of a taxpayers' representative on the board that cannot be occupied by a civil servant or anyone who has worked in the industry in the last 10 years;
• A requirement that risk and credit committees of NAMA include at least 51% majority of independent experts who cannot be employees of the state, NAMA or any toher parties to this undertaking;
  
• A condition that the banks must undergo loan book evaluation prior to transfer of any loans to NAMA, the results of which will be made public - on the web - instantaneously - and will impose a requirement on the banks to write down their assets, again before NAMA purchases any of them, by the requisite amounts to balance their own books in line with valuations;
• A condition that any loan purchased by NAMA be placed on the open market for the period of 2 weeks and that NAMA will not pay any amount in excess of the bids received (if any), with a prohibition for the participating banks to bid on these loans;
• A condition that every NAMA loan should be publicly disclosed, including its valuations and bids it receives in the auction stage of the process;
  
• A stipulation that all and any regulatory authorities (and their senior level employees) that were involved in regulating the banking and housing sector in this country take a mandatory pension cut of 50% and return any and all lump sum funds they collected upon their retirement;
• A provision for dealing with the speculatively zoned land to be acquired by NAMA, i.e orderly de-zoning of this land and transfer of this land to either public (if no bidders arise) or private use consistent with sustainable agricultural development, environmental improvements, public use or forestry;
  
• The measures to prevent banks from beefing up their profit margins through squeezing their preforming customers;
• The measures to force the banks to reduce their cost bases by laying off surplus workers;
• The measures for accounting (in a transparent and fully publicly accessible fashion) on a quarterly basis for NAMA operations and the performance of the state-supported banks.

If I forget something, please, let me know...

Economics 31/07/2009: NAMA legislation Part 1

Over the next few days I will be posting my thoughts on NAMA legislation. But here is a quick first installment:

A search of PDF document reveals that:

1. The word 'taxpayer' appears in the entire legislation only once. Despite the taxpayers being the sole payee for the scheme;
2. Words 'Taxpayers representation' do not appear in the document at all;
3. Words 'Taxpayers interest' do not appear in the document at all;
4. Words 'stop-loss' do not appear in the document at all;
5. Words 'transparency', 'public interest' (outside the scope of court decisions) and 'public information' do not appear at all;
   
6. 'Public disclosure' only applies to restricting such in the cases of expert opinions;
   
7. Word 'loss' appears in the legislation only in the areas of:
   

• Giving NAMA power to issue complex derivative instruments to hedge against "the risk of loss arising from changes in interest rates, currency exchange rates or other factors of a similar nature, to eliminate or reduce the costs of raising funds or borrowing or the cost
  of other transactions carried out in the ordinary course of business, or increasing return on investment. No stop-loss rules on these derivatives are envisioned, as if they are risk free;
• In making sure that "participating institutions to indemnify NAMA. 111.—(1) If NAMA or a NAMA group entity so directs, a participating institution shall indemnify NAMA or the NAMA group entity and its officers against any liability or loss..." In other words, the Government employees and NAMA will be protected from any loss claims, but not the taxpayers. Minister Leniham did his job of shielding his cronies well.

6. "30.—(1) As soon as practicable after the establishment day, the Board shall establish 3 committees, and appoint members to them, as follows: (a) an audit committee; (b) a credit committee; (c) a risk committee." There is no independent committee membership requirements, with all, save two members of each committee appointable by the Board of NAMA, and the remaining two - by the Minister.

Actually, worse that that: "(5) The members of the credit committee and the risk committee shall be members of the Board or officers of NAMA. At least 2 members of each of those committees shall be members of the Board." Thus, there will be no independent oversight over risk and credit decisions by NAMA. Not even in theory.

"31.—(1) The Board may establish such advisory committees as it considers necessary or desirable to advise it in the performance of its functions. ...(4) The Board shall determine the terms of reference and procedures of an advisory committee." There will be no statutory requirement for independent oversight of NAMA - cronies run cronies' loans.

7. "Indemnification of members of Board and officers of NAMA, etc. 32.—(1) This section applies to the following: (a) each member of the Board; (b) each officer of NAMA; (c) a director of a NAMA wholly owned subsidiary; (d) a director of a NAMA group entity; (e) a member of the staff of the NTMA. (2) A person to whom this section applies is indemnified in relation to anything done or omitted in the performance or purported performance or exercise of any of NAMA’s functions or powers under this Act, unless it is proved that the act or omission was in bad faith." So the incompetence can never be penalised - a standard practice for Mr Leniham's pets in the public sector.

And a succinct summary of the legislation (hat tip to Richard W):


More to come, so stay tuned, but this already bad enough...