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Why did the financial crisis happen? Why did no one see it coming? And how did our banks lose so much of our money? What's being done to sort out the banking industry? And will it work?
These are the questions that industry experts Adrian Docherty and Franck Viort cover in Better Banking: Understanding and Addressing the Failures in Risk Management, Governance and Regulation. They give a clear and thorough run-through of some of the key concepts and developments in banking, to enable the reader to understand better this vital yet perilous industry. Without excessive detail or jargon, they explain the most important issues in risk management, regulation and governance and build a comprehensive description of how failings in these areas resulted in the current financial crisis. In order to make the diagnosis clear, the authors illustrate their descriptions with a series of informative case studies. The book revolves around a critique of the current regulatory developments, which the authors feel will be ineffective in fixing the structural flaws in banking. Crucially, and as the title of the book suggests, they set out their own series of proposals to contribute to the development of a better, safer and more effective banking industry.
Docherty and Viort's book fills an important gap in the literature on banking and its role in the current financial crisis. It is at once a history, a primer, a critique and a manifesto. It does not take sides but works through a constructive diagnosis towards ideas that could lead to major improvements in the quality and stability of the financial world.
Better Banking: Understanding and Addressing the Failures in Risk Management, Governance and Regulation is a technical yet accessible book that seeks to engage interested readers of all kinds -- students, professionals, bankers and regulators but also politicians and the broader audience of citizens outside the banking industry, who are keen to inform themselves and understand what needs to be done to avoid a repeat of this crisis.
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Seitenzahl: 852
Veröffentlichungsjahr: 2014
Acknowledgements
1 Introduction
1.1 Overview and Objectives
1.2 Quick Start Guide to Banking Concepts and Regulation4
2 The Global Financial Crisis
2.1 From Deregulation to dotcom Crash
2.2 The Seeds of a Crisis
2.3 “Why Didn’t Anyone See This Coming?”
2.4 The Beginnings of a Crisis
2.5 The Crisis Intensifies
2.6 Meltdown: The Lehman Bankruptcy
2.7 Massive Intervention Internationally
2.8 Sovereign Crises
2.9 Aftershocks and Skeletons in the Cupboard
2.10 Who is to Blame?
3 Methodologies and Foundations
3.1 How do Banks Make or Lose Money?
3.2 What’s a Bank Worth? Key Issues in Accounting for Banks
3.3 What is Risk?
3.4 What is an RWA?
3.5 What is Capital?
3.5.1 Regulatory Capital
3.5.2 Hybrid Capital
3.5.3 Economic Capital and Ratings Capital
3.5.4 Cost-of-Capital and Return-on-Capital
3.5.5 Capital in a Stress Scenario
3.5.6 Bail-in Capita
3.6 What are Liquidity and Funding?
3.6.1 Concepts
3.6.2 Liquidity Management and Liquidity Risk
3.6.3 Interbank Funding, the Money Markets and Central Bank Support
3.6.4 Deposit Guarantee Schemes
3.6.5 Securitisation
3.6.6 Covered Bonds
3.6.7 Liquidity Stress Tests
3.7 What is a Derivative?
3.8 Mark-to-Market and Procyclicality
3.9 Role of Regulation, Supervision and Support
3.10 Ratings Agencies and Credit Ratings
3.10.1 Moody’s Bank Methodology
3.10.2 S&P’s Bank Methodology
3.10.3 Structured Finance Ratings
3.10.4 Use of Ratings in Regulation and Investment Policy
3.11 Analysts, Investors and Financial Communication
4 Regulation of the Banking Industry
4.1 The Relevance of Bank Regulation and Supervision
4.2 Regulation and Supervision of the Banking Industry Prior to “Basel I”
4.3 The Basel Capital Accord aka “Basel I”
4.3.1 Definition of Capital
4.3.2 Deductions Regime
4.3.3 Risk-Weighting Approach
4.3.4 Ratio of Capital to Risk Weighted Assets
4.3.5 Modifications to Basel I
4.3.6 Impact of Basel I
4.4 Basel II
4.4.1 Objectives of Basel II
4.4.2 The Three-Pillar Approach
4.4.3 Pillar 1: Minimum Capital Requirements
4.4.4 Pillar 2: Supervisory Review
4.4.5 Pillar 3: Market Discipline
4.4.6 Capital Calibration
4.4.7 Capital Supply and Mix
4.4.8 Implementation of Basel II
4.4.9 Critique of Basel II
4.5 Basel III
4.5.1 Definition of Capital
4.5.2 Deductions
4.5.3 Risk-Weighted Assets
4.5.4 Minimum Capital Levels
4.5.5 Leverage Ratio
4.5.6 Liquidity and Funding
4.5.7 Derivatives Risk Management
4.5.8 Implementation and Transition
4.5.9 National Versions of Basel III
4.5.10 Major Achievements of Basel III: Top Five
4.5.11 Major Issues with Basel III: Top Five
4.6 Resolution Regimes
4.7 Other Current Regulatory Workstreams
5 Case Studies
5.1 RBS
5.2 Dexia
5.3 HBOS
5.4 HSBC
5.5 Bear Stearns
5.6 Merrill Lynch
5.7 AIG
5.8 JP Morgan
5.9 Barclays
5.10 UBS
5.11 Northern Rock
5.12 Bankia-BFA
5.13 Australia
5.14 Canada
5.15 Summary of “Lessons Learned” from the Case Studies
6 Objectives and Design Principles
6.1 Free Market versus State Capitalism
6.2 Are There Alternatives to Banks?
6.3 Benefits and Limitations of Finance
6.4 How Much Risk Can We Tolerate?
6.5 The Role of Regulation and Supervision
6.6 The Role of “the Market”
6.7 Conclusions: Proposed Objectives and Design Criteria
7 A Blueprint for “Basel IV”
7.1 Risk Management
7.1.1 Valuation Approaches
7.1.2 Role of Internal Risk Assessments
7.1.3 Putting Risk Management at the Heart of Banking
7.1.4 Role of Risk Benchmarks
7.1.5 Assets Don’t Have Risk, Institutions Do
7.1.6 Risk Disclosure
7.2 The Guardian Angel
7.2.1 Key Aspects of the Guardian Angel Model
7.2.2 Creating the Supervisory Elite
7.2.3 Paying the Bill
7.2.4 Cross-Border Issues
7.2.5 The Role of Macroprudential Regulation
7.3 Human Capital
7.3.1 Competence and Incompetence in the Banking Industry
7.3.2 Compensation
7.3.3 Culture
7.4 Governance
7.4.1 How Does Governance Work in Theory?
7.4.2 Improving Governance of Banks
7.4.3 The Centurion Approach
7.5 Capital
7.5.1 The Role of “Capital”
7.5.2 Principles-Based Solvency Regulations
7.5.3 Need for Capital
7.5.4 Supply of Capital
7.5.5 Role of “Hybrid” Capital
7.5.6 Life without Capital Ratios
7.5.7 Minimum Capital Standards
7.5.8 Disclosure of Capital Assessment
7.5.9 Resolution of Failed Banks
7.6 Liquidity and Funding
7.6.1 Liquidity
7.6.2 Funding
7.7 The “Pillar 2” Mindset
7.7.1 Putting Scenario Assessment at the Heart of the Risk Management Process
7.7.2 Wargaming Instead of Stress Testing
7.7.3 Communication of Pillar 2 Findings
7.7.4 The Modular Approach to Risk Assessment
7.7.5 Risk Appetite and Reverse Stress Testing
7.8 Glasnost: Market Discipline and “Pillar 3”
7.9 Industry Structure
7.9.1 Different Types of Banks
7.9.2 Too Big to Fail
7.9.3 Cross-Border Issues
7.9.4 Ownership Structures
8 Challenges
8.1 Industry Entrenchment
8.2 Human Behaviour
8.3 Performance Management for Good Risk Management
8.4 Timing
8.5 A Positive Challenge: Technological and Social Progress
9 What Next? A Call to Arms
Glossary & Jargon Lookup
Index
Table 1.1
Table 2.1
Table 2.2
Table 2.3
Table 2.4
Table 2.5
Table 2.6
Table 2.7
Table 2.8
Table 3.1
Table 3.2
Table 3.3
Table 3.4
Table 3.5
Table 3.6
Table 3.7
Table 3.8
Table 3.9
Table 3.10
Table 3.11
Table 3.12
Table 3.13
Table 3.14
Table 3.15
Table 3.16
Table 3.17
Table 3.18
Table 3.19
Table 3.20
Table 3.21
Table 3.22
Table 3.23
Table 4.1
Table 4.2
Table 4.3
Table 4.4
Table 4.5
Table 4.6
Table 4.7
Table 4.8
Table 4.9
Table 4.10
Table 4.11
Table 4.12
Table 4.13
Table 4.14
Table 4.15
Table 4.16
Table 4.17
Table 4.18
Table 4.19
Table 4.20
Table 4.21
Table 4.22
Table 4.23
Table 4.24
Table 4.25
Table 4.26
Table 5.1
Table 5.2
Table 5.3
Table 5.4
Table 5.5
Table 5.6
Table 5.7
Table 5.8
Table 5.9
Table 5.10
Table 5.11
Table 5.12
Table 5.13
Table 5.14
Table 5.15
Table 5.16
Table 5.17
Table 5.18
Table 6.1
Table 6.2
Table 6.3
Table 6.4
Table 6.5
Table 6.6
Table 7.1
Table 7.2
Table 7.3
Table 7.4
Table 7.5
Table 7.6
Table 7.7
Table 7.8
Table 7.9
Table 7.10
Table 7.11
Table 8.1
Table 8.2
Figure 2.1
Figure 2.2
Figure 2.3
Figure 2.4
Figure 2.5
Figure 2.6
Figure 2.7
Figure 2.8
Figure 2.9
Figure 2.10
Figure 3.1
Figure 3.2
Figure 3.3
Figure 3.4
Figure 3.5
Figure 3.6
Figure 3.7
Figure 3.8
Figure 3.9
Figure 3.10
Figure 3.11
Figure 3.12
Figure 3.13
Figure 3.14
Figure 3.15
Figure 4.1
Figure 4.2
Figure 4.3
Figure 4.4
Figure 4.5
Figure 4.6
Figure 5.1
Figure 5.2
Figure 5.3
Figure 5.4
Figure 5.5
Figure 5.6
Figure 5.7
Figure 5.8
Figure 5.9
Figure 5.10
Figure 5.11
Figure 5.12
Figure 5.13
Figure 5.14
Figure 5.15
Figure 5.16
Figure 5.17
Figure 6.1
Figure 7.1
Figure 7.2
Cover
Table of Contents
Introduction
Chapter 1
Chapter 2
Chapter 3
Chapter 4
Chapter 5
Chapter 6
Chapter 7
Chapter 8
Chapter 9
Glossary
Index
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The concept of this book was driven by our profound belief, formed over many years at the coalface of the banking industry, including during this latest financial crisis, that banking can be truly “better”. Events of recent years have exposed massive problems in the banking industry. As practitioners on the ground, we are confident that we understand the root causes: failings in risk management, governance and regulation. We have been frustrated by the incomplete diagnoses that have been published, worried at the prospect of unintended consequences of policy actions and disappointed by the lack of effective dialogue in the industry. We have been encouraged to find that similar views to ours are widely held by many of the people whose opinions we most respect and who, in our opinion, understand what is really going on in banking. This book, therefore, aims to fill an important gap in the literature and give a voice to these crucial, progressive perspectives.
We have written this book in a personal capacity and it expresses our own personal views, rather than the views of anyone else or of our employers. Nevertheless, we have not written the book in a vacuum and so would like to acknowledge the input and support we have received from others.
We would like to thank our editor, Werner Coetzee, for his help and drive in getting this project off the ground, as well as all the excellent professionals at Wiley for their support and assistance. We had the good fortune of being supported greatly by our expert reviewers and friends Julien Carmona and Mark Kibblewhite during the drafting of the book and are supremely grateful to them both for their valuable input and suggestions. We would also like to thank Sonia Peterson and Joaqin Mercado, who helped out on several parts of the book with research and writing. Many other senior industry figures, colleagues, clients, professors and friends have contributed to our efforts and we owe them a sincere “thank you”: work on the book has reminded us of the immense intelligence and enthusiasm of the people around us. Lastly, we would like to thank our wives and families for their patience during the drafting of this book and apologise to them for our frequent neglect of familial duties during that period.
If the terrain and the map do not agree, follow the terrain.1
Today, the world is in its sixth year of a deep and damaging financial crisis. The cause of this crisis was a massive failure of risk management and governance: quite simply, we lost control of our financial system. As a result, we experienced a debt-fuelled boom that turned rapidly into an economic “bust”. Millions are suffering as a consequence: for example, youth unemployment has risen in the last ten years from 17.8% to 22.8% in the EU and from 12.0% to 16.2% in the United States.2
The problems could have been greater. The bankruptcy of Lehman Brothers could have led our modern, global economy to freeze. Such problems have been averted by the pumping of huge amounts of extra money into the financial system by central banks at low interest rates. These monetary policies are sure to have painful side-effects in the long term, but they have succeeded in keeping our economies moving and bought time to fix the causes of this financial crisis.
Banks are lead actors in the crisis. In many countries, large swathes of the banking industry failed and had to be supported by the state. In general, banks had been loosely supervised and some had been badly managed. Seeking ever-increasing profits, the banking industry took huge risks that were not apparent at the time but that we can now see were unacceptable. Problems emerged first in the US subprime mortgage market, which enabled poor people to buy expensive homes. New financial products used financial alchemy to turn this high-risk lending activity into seemingly low-risk investments for gullible investors. They were anything but low-risk: one study of $640bn worth of securities shows that investors lost two-thirds of their money.3 Many of the most gullible investors were banks themselves, often banks outside the USA. The subprime malaise of over-confidence followed by ruinous losses spilled over into other markets and other countries.
Common sense should have told us from the outset that this kind of alchemy was impossible and that someone stood to lose out. In the end, it was society that was bearing those risks unwittingly. When the banks failed, society was forced to stump up the financial resources to prop up the system or face chaos and oblivion.
The public is rightfully angry about the burden of those losses, but also with the odious behaviours in the banking industry that have been uncovered by the financial crisis: greed, incompetence, negligence, arrogance, contempt, deceitfulness. Several of the leaders of the banking industry, who had been lauded as superheroes and feted with honours and multi-million dollar bonuses during boom years, turned out to be incompetent or even downright villainous.
No-one disagrees that change is needed, in order to learn the lessons of the current financial crisis and enable us to reduce the likelihood, frequency and impact of future crises. There is a risk, however, that the diagnostic is incomplete and the remedial actions may be ineffective. This book aims to contribute to an improved understanding of the diagnostic as well as offering some additional and alternative proposals for consideration.
Current diagnoses tend to focus on the symptoms of the current financial crisis (e.g. the banks' excessive leverage, weak capital bases, poor funding profiles and insufficient liquidity buffers4) or play the blame game, singling out scapegoats in order to make the resolution of the problem punchier and more streamlined. Requiring higher levels of capital and exposing bad behaviour by bankers should solve the matter, apparently, all at little cost to the rest of us.
Such views are incomplete. A better diagnostic should do two things. Firstly, it should recognise the contribution of global macro-economic imbalances – especially the growing indebtedness of western consumer economies – to the current financial crisis. These imbalances are as much political as they are financial. They are also stubbornly difficult to reduce. Secondly, the diagnostic of the banking industry–s problems should centre squarely on failings of governance, regulation and risk management. Society failed to control adequately the banks and the banks failed to manage adequately the risks they were running. Problems of excessively aggressive financial profiles, bad behaviours and excessive pay are consequent symptoms of the failure of governance, regulation and risk management. Society – the ultimate owner of the banking industry ’ must accept its responsibility for heaping praise on the “banker’s new clothes”, to extend a recently used metaphor.5
In order to advance this diagnostic, there is a need to engage a broad audience. A discussion that is restricted to dedicated professionals from the banking industry and the authorities may miss the broader picture and get lost in cul-de-sacs. Certain arcane elements of the regulatory response to the financial crisis (known as Basel III and covered in Section 4.5) indicate that this is the case. “Expert” diagnostics may also fail to achieve acceptance from the public, who are, after all, the “society” that ultimately carries the can. In the spirit of active engagement, therefore, we seek to set out a basic understanding of the nature and fundamentals of banking, to act as a methodological backdrop to the discussion and assist a simultaneous broadening and simplification of the subject. For example, a basic common understanding of the notions of risk and capital will help any diagnostic on the solvency and resilience of our banks.
An elegant diagnostic and a critique of the current regulatory response would be a noble objective for this book, but it would not be sufficient. Therefore, we have tried to set out some concrete, high-level, novel proposals for “better banking”. All of these are to do with bank governance, regulation and risk management. To begin this task, we have had to assume at the outset that politically, a liberal free-market form of capitalism with moderate state oversight is the desired economic framework; and that society’s capacity for risk is low enough not to accept anything like the level of risk that was building up in the system in 2005/6. Our thesis is that finance and banking are important features of a modern, democratic society and liberal, capitalist economy. But the risks that are inherent need to be well managed, regulated and supervised. They can be mitigated, never tamed but, if we adopt the wrong approaches, they can be needlessly inflamed. So we propose a vision of a banking industry that is based firmly on free-market principles but supplemented by a benign and competent public authority, which ensures that risk is transparent and confronted through rigorous and intelligent risk management capabilities.
The proposals are set out in the immodestly titled Chapter 7: “A Blueprint for Basel IV”. They comprise suggestions on:
improved risk management processes, including better information and the use of dynamic “wargaming” over “stress testing”;
a hands-on “Guardian Angel” approach to supervision;
a more impressionistic and subjective approach to capital and funding;
some radical proposals on deposit funding (effectively, the nationalisation of guaranteed deposits by the central bank) and liquidity management (replacing investments in government bonds with a central bank overdraft);
increased rigour in governance processes and management accountability structures through the adoption of a meticulous “Centurion approach”;
the active engagement of market forces in bank governance by means of a new “glasnost” approach; and
relatively liberal and flexible common-sense views on human capital management and industry structure, which should be allowed to find their own form through market forces, good risk management and good governance.
These proposals are meant to be a “strawman”: “throw stones and it doesn’t hurt”. We have put these ideas forward because there are so few, coherent, credible responses to the lessons of the current financial crisis, even those of the most esteemed experts and banking authorities. The debate on the banking industry is polarised and not progressing at a great pace. Banks are engaged in “lobbying” to protect their vested interests; the authorities are keen to be seen as competent and in possession of the magic fix; almost everyone else is frustrated and feels disenfranchised. We do not feel that taking sides is appropriate: this is not a battle between two armies. Society needs banks, banks need to change and society needs to guide that change. There should be no opposing objectives between bankers and banked: there may be multiple viewpoints, but the objectives should be non-controversial. Status quo is not acceptable. To put it bluntly, we feel that the banking industry has still not been fixed and the current reform agenda is not going to change that.
We hope we are not naïve. We are aware of some of the challenges that our proposal would entail and have dedicated Chapter 8 to the consideration of some of these challenges.
The reader should be aware of some questions of style:
The subject matter is broad and raises many questions. This book skims the surface. We hope that the inquisitive reader will be left with a thirst to dig deeper into several areas.
We use quotes extensively, to demonstrate the views and nuances of experts in the industry and commentators, as there is no need to “reinvent the wheel” when others have already provided good material.
Too much of the technical debate on the banking industry is inaccessible: this book hopes to be highly accessible, insofar as that is possible with a highly complex, sophisticated and, let’s face it, intangible topic. In order to improve accessibility, we have a glossary of jargon. Data exhibits are kept to a minimum and are included only where they are highly relevant. We don’t use maths beyond what’s necessary and even then, only very basics of risk management or simple sums.
Thematically, the book has three main parts. Initially, we set out our diagnostic and methodological foundations; then, we consider 14 real-life case studies; lastly, we set out for consideration the proposals for “better banking”.
The banking industry is huge and important. Due to its central role in the economy, it stores or handles vast sums of money. To give some idea of scale, consider the following statistics in Table 1.1.
These numbers may not mean very much in isolation. But they hopefully illustrate that banks deal with big sums of money and getting it right is important. Imperfections or – worse – sloppiness are bound to have a disastrous effect.
Banking is an industry that is at the heart of our capitalist system. On the one hand, banks take money in and safeguard it; on the other hand, banks provide credit for people to buy homes and companies to make investments. Banks act as a bridge between these two needs and their expertise in credit and investment management keeps both sides of the business happy, if everything is working well. Banks also provide payments services to facilitate the transfer of money for purchases, though this aspect of banking is not a focus of this book.
Banking is risky and banking is about risk management. The classic bank product, a loan, consists of the up-front provision of money by the bank to the borrower, who promises to repay the debt within a certain timeframe. How can a bank be certain that the loan will be repaid? What can the bank do to ensure the loan is repaid? And what should the bank do in the event of non-repayment? On the other side of the business, how can a customer be certain that the bank will be able to honour their deposit?
It is an often-overlooked fact that a bank deposit is not backed with cash on reserve or gold. Or, as was said of one of the largest and best regarded banks in the world: “Turns Out Wells Fargo Doesn’t Just Keep Your Deposits in a Stagecoach Full of Gold Ingots”.6 In fact, most of any bank’s deposit base is lent out to borrowing customers, who may or may not repay their debt.
This intermediation function makes banks fragile. They rely upon the confidence and trust of those who entrust their funds to them. They need to manage their risks sufficiently well to be viable in the long term (solvent) and in the short term (liquid). So risk management rapidly becomes an issue of solvency capital management (being able to absorb losses when they come around, without depositors losing their money) and funding and liquidity management (being able to borrow from — and repay when requested — the bank’s depositors and creditors). This is the reason why bank regulation has been focused heavily on capital levels and liquidity measures.
Penetration
It seems – though admittedly the data is not clear – that around half of the world’s population has a bank account. One-third of small businesses have a credit line from a bank.7
Globally, there is one bank branch for every 6,000 people. This number varies from one branch for every 1,100 people in Spain to one branch for every 150,000 people in Congo.8
Size: balance sheet
The balance sheet size of the world’s largest 1,000 banks is more than $100,000bn.
9
Size: deposits
Deposit balances globally are reported to be 44% of world GDP,
10
or around $30,000bn. In richer countries, the average is 84% of GDP.
Size: derivatives
The face value of derivatives contracts is more than $400,000bn
11
(see Section 3.7 for an overview of derivatives).
Volumes
The value of all the payments transactions processed by banks is in the region of £78,000bn in the UK alone,12 or 50 times the UK’s annual GDP. If we gross that up a factor of about 30 (reflecting the UK’s share of global GDP13), then we would have an estimate equivalent to more than $3,000,000bn in payments globally.
In addition to these volumes, the world’s currency markets trade some $5,000bn per day14 or $1,500,000bn per annum.
Market value
The top 55 banks in the world have a market capitalisation of $4,000bn,
15
representing nearly 10% of the entire global stock market capitalisation of listed companies, which is $53,000bn.
16
In China and Australia, large banks make up more than a quarter of the stock market’s value.
Profitability
The top 1,000 banks make around $700bn per year in pretax profits.
17
In the USA, financial companies (including insurance companies as well as banks) made up 28% of corporate profits over the last three years.
18
Big banks
Fifteen banks currently have balance sheets bigger than $2,000bn:
Europe: Deutsche Bank, HSBC, Barclays, BNP Paribas, Crédit Agricole, Royal Bank of Scotland
Japan: Mitsubishi UFJ, Mizuho, Japan Post Bank
China: Industrial & Commercial Bank of China, China Construction Bank, Agricultural Bank of China, Bank of China
USA: JP Morgan Chase, Bank of America.
And a further 11 have balance sheets between $1,000bn and $2,000bn:
Europe: Banco Santander, Société Générale, ING Group, Groupe BPCE, Lloyds Banking Group, UBS, UniCredit, Credit Suisse Group
Japan: Sumitomo Mitsui Financial Group
USA: Citigroup Inc, Wells Fargo.
Table 1.1 Key figures on banking
If things don’t go well, banks can lose confidence and suffer from bank runs, where depositors try to get their funds out; the bank simply runs out of cash to meet its obligations and is forced to close. Bank runs are fortunately rare, though the current crisis is providing several new case studies. The banking industry can also suffer from system-wide crises, the financial busts that generally follow a period of boom.
If something is important yet fragile, it follows that it needs to be protected. This is why regulation and supervision are important. The regulatory discussion focuses a lot on “Basel”, the international club of banking regulators where such issues are managed. A basic understanding of the three Basel regulatory regimes (Basel I, Basel II and Basel III) will help to serve as a backdrop to the more prescriptive chapters later.
Society needs to ensure that the essential functions of banks are preserved, to avoid problems such as a “credit crunch”, when certain reasonable needs of the economy cannot find financing. Society also needs a “guardian” to ensure that financial stability is preserved, the value of deposits is safeguarded and banking ethics are applied.
Finally, if something is important and fragile, it needs to be well managed. This is the duty of everyone, from the regulatory and supervisory “guardians” to the owners of banks to the executives and middle-managers of banks. It is also the duty of society itself for – to adapt a well-known quotation – every society gets the banking system it deserves.
The following three chapters give a brief overview of how banks contributed to the current financial crisis, what the basic concepts of banking and risk management entail and the history of banking regulation to the present day.
1
Attributed widely to a Swedish Army training manual.
2
Labour Force Survey: Unemployment rate for age group under 25 years 2002–12, Eurostat.
3
Collateral Damage: Sizing and Assessing the Subprime CDO Crisis, Federal Reserve Bank of Philadelphia, May 2012.
4
Basel III: A global regulatory framework for more resilient banks and banking systems, Basel Committee, December 2010 (revised June 2011).
5
The Banker’s New Clothes
, Anat Admati and Martin Hellwig, 2013.
6
Dealbreaker.com
, 3 January 2013.
7
Global Financial Development Database, World Bank, April 2013.
8
Ibid.
9
Top 1000 World Banks 2012,
The Banker
, 2 July 2012.
10
Global Financial Development Database, World Bank, April 2013.
11
Mid-Year 2012 Market Analysis, ISDA, 20 December 2012.
12
Payments Council Quarterly Statistical Report, 18 March 2013.
13
World Bank.
14
BIS Quarterly Review
, BIS, March 2012.
15
World’s Largest Banks 2013,
relbanks.com
, 25 January 2013.
16
World Bank.
17
Top 1000 World Banks 2012,
The Banker
, 2 July 2012.
18
Table 6.16D, Bureau of Economic Analysis, 28 March 2013.
The current, ongoing financial crisis has shaken the world economy and the global banking sector. Many publications, of differing quality and emphasis, are available for those who wish to study the factual history of the financial crisis. Here, we consider the crisis more from a thematic rather than a narrative perspective: the goal is to derive insights into the causes of the crisis that might help us consider improvements in the banking industry, rather than simply recounting facts or telling a sensational story.
The world economy and financial system underwent a major change in the 30 or so years running up to the crisis. Politically, many nations embraced the free-market doctrines of Reagonomics and Thatcherism, which had appeared to triumph over various forms of socialism and centrally planned economies. Logistically, the world became smaller and more integrated through advances in communication and transport. Technologically, rapid increases in computing power enabled vastly enhanced data processing, storage and analytics. These factors shaped developments in the structure and innovation of the banking system.
Arguably, the changes were most pronounced in Europe. Deregulation of banking in the UK (the “Big Bang” of 1986) opened up the industry to new firms from abroad and kick-started a resurgence in London’s importance as the pre-eminent global financial centre. At the European level, the Single European Act in 1986 reinforced the concepts of competition, limiting barriers to trade. The foundations for the common currency to become the Euro that were laid during this period followed a similar objective of closer trade integration between members, but also involved the creation of a reserve currency that would compete with the US dollar and provide European borrowers with a vast and liquid capital market. And widespread privatisations in the 1980s and 1990s introduced the culture of share ownership to a European populace whose main financial asset had previously been the traditional bank deposit.
New types of companies entered the banking market. A breed of investment firms emerged that became known as “hedge funds”. The archetypal hedge fund was largely unregulated and aimed to exploit market imperfections, by finding trading positions that were offsetting yet differently priced and so certain to make a profit, no matter in which direction the financial markets moved. Hedge funds financed themselves with their founders’ and clients’ investment capital, together with short-term debt facilities from the banks with whom they traded. Since the hedge funds were active trading customers of the banks, the banks were keen to provide them with loans. The hedge funds employed highly intelligent quantitative analysts, who used the latest databases and computing power to build risk arbitrage models. The funds were hedging their positions and the number-crunchers’ models generally showed that the hedges were not perfect – but they were pretty good and only a very odd circumstance would cause problems. The models also demonstrated that such an odd circumstance would only be expected to occur once in every 10,000 years or so. Hence, the hedge funds felt like a pretty safe bet and a good source of earnings for all involved, so long as the disaster of biblical proportions didn’t show up.
In 1998, a disaster of biblical proportions did show up. Or at least, something highly unusual occurred, which the models had not anticipated. The financial markets were spooked by the unexpected default by Russia on its international bonds and this triggered a “flight to quality” reaction from international investors. Their sudden and massive shifts in investment preferences, for example moving their portfolios out of thinly-traded or illiquid bonds into safer and more liquid bonds, caused problems for a large hedge fund called “Long Term Capital Management” (LTCM). LTCM had credibility: it counted the winners of the 1997 Nobel Prize in Economic Sciences among its partners. Guided by their strong belief in the power of risk modelling (Myron Scholes and Robert Merton had helped develop the Black–Scholes option pricing model), they had a different way of thinking about the financial world and “by putting numerical odds on its likelihood of loss”,1 they were supposedly able to generate superior trading strategies, certain to win against all the less sophisticated investors. But its trading strategy failed and resulted in massive losses that threatened to destabilise the capital markets through contagion.
Had the failure of LTCM triggered the seizing up of markets, substantial damage could have been inflicted on many market participants, including some not directly involved with the firm, and could have potentially impaired the economies of many nations, including our own.2
The Federal Reserve orchestrated a bail-out by LTCM’s lenders, so that the hedge fund did not need to close its positions at “fire sale” prices into fragile markets. A crisis was averted. In the end, LTCM lost “only” around $5bn and its lenders did not need to write off their loans. In retrospect, however, the LTCM episode should have served as a forewarning of the risks that were building up in the financial system.
At the turn of the century, the “dotcom” bubble was a crisis that never happened. Investors chased technology and “new era” stocks higher and higher and were largely wiped out when most of the dotcom businesses failed to convert their concepts into profits and experienced share price crashes. The main benchmark of the dotcom era, the NASDAQ index, peaked above 5,000 in early 2000 having been around 2,000 two years earlier, and fell to just above 1,000 two years later.3 The value of the stock holdings of US households fell from $18,100bn in early 2000 to $9,900bn in the second half of 2002.4 Wall Street banks were subsequently investigated by New York Attorney Eliot Spitzer, leading to prosecution and settlement, owing to practices that mismanaged the conflict of interest between research departments and investment banking salespeople. But there was no banking collapse to accompany the collapse of the high-tech sector. This has puzzled some analysts:
The dotcom crash was of a similar magnitude to the subprime crisis while its output effects were small in comparison.5
and
The fall of dot-com stock prices just a few years earlier, which destroyed as much or more paper wealth – more than $8 trillion – resulted in a relatively short and mild recession and no major financial instability.6
Why did the dotcom crash not create a serious crisis? It is true that banks did need to write off some of the dud loans to high-tech companies. For example, WorldCom had debt of $41bn when it went bankrupt in 2002. But the losses on dotcom investments did not cause contagion and second-order problems, because they were, for the most part, not financed by debt. Investors saw their wealth grow, soar, explode and crash, but they were not left with a debt “hangover”.
Bubbles in themselves aren’t always bad. But when they leave behind debts, they can be disastrous.7
The specific problems and vulnerabilities that led to today’s crisis were not present during the dotcom crash. Nevertheless, the authorities were concerned at the economic slowdown that was induced by the end of the dotcom bubble and the terrorist attacks of 11 September 2001.
Had I been in love, I could not have been more wretchedly blind. But vanity, not love, has been my folly,8
The response of the authorities to the economic slowdown was to lower interest rates to spur economic activity. At the New York Federal Reserve (“the Fed”), Governor Alan Greenspan lowered interest rates and kept them low. By admitting that the Fed could “mitigate the fallout when it occurs and, hopefully, ease the transition to the next expansion”,9 Greenspan signalled there would be a safety net in case the market crashed, providing justification for a more aggressive approach to risk and “implicitly encouraged bankers to borrow short-term while making long-term loans, confident the Fed would be there if funding dried up”.10
American interest rates were below 2% throughout the three years 2002, 2003 and 2004. In retrospect, this overly accommodative monetary policy sowed the seeds of a boom that became the backdrop of the current financial crisis. Holding rates so low for so long was “the original sin of the Bernanke-Greenspan Fed” that was bound to lead to excessive risk-taking.11
The other implication of the actions of the authorities, notably the Fed, was to give investors a clear indication that action would always be taken to avoid calamity. The capital markets interpreted this as an implicit backstop to risk, a guarantee that distressed markets would be revived by public policy. In market-speak, this was termed the “Greenspan put”. Implicitly, it increased the risk appetite of the markets and reduced investors’ attention to downside risk. If things went wrong, the Fed would sort it out.
During this same period, global trade continued to grow and new, structural imbalances emerged that changed the nature of the international financial system.
The imbalance was caused by Western economies importing ever more goods from Asia. Western consumers were borrowing to finance their consumption and Western governments were borrowing to finance budget deficits, while Asian consumers and governments were saving and investing. The global financial system facilitated this imbalance and enabled the transfer of Asian savings to Western borrowers. A “savings glut” emerged, which kept market interest rates low despite the higher financing needs of the West. Developing economies were “shifting from being net importers of financial capital to being net exporters, in some cases very large net exporters”.12
This shift occurred at the turn of the century. According to official statistics,13 the current account of industrialised countries had moved from a surplus in 1999 to an annual deficit of 1.5% of world GDP in 2006. Emerging markets and oil-producing countries were the mirror image, as the graph in Figure 2.1 shows. Poorer countries were lending money to richer countries to buy their exports.
Figure 2.1 Current account surplus/deficit in % of world GDP
These trends were accompanied by the introduction of the Euro at the turn of the century, which created a new, deep and liquid capital market. For the first time, European borrowers could borrow efficiently from bond investors in their own currency, as American companies had been able to for decades.
Technological advances spurred financial innovation. New techniques for transferring risk boosted the activity of the bond markets. The biggest innovations were securitisation, funding arbitrage vehicles and the “credit default swap” (CDS). These are described below; they grew rapidly in size and complexity, while offering a seemingly perfect way for risk to be spread to new investors and thus reduce the overall risk in the system.
To illustrate the rapid and exponential growth in new financial products, consider the growth of the CDS market. A CDS is a contract where the seller gives protection against the default of the reference entity in exchange for a fee. It is like an insurance policy against default. Buyers of protection could use CDS to reduce their exposures for tactical or strategic reasons. Sellers of protection could use CDS to generate risk-based revenues, without the hassle of making loans. Traders could use CDS to take positions in the market where they felt there was value to be earned. The total of all credit default swap transactions grew from next to nothing in 2001 to $60,000bn in 2007 – see Figure 2.2.
Financial engineering took on the aura of alchemy and its complexity outstripped the sophistication of investors and regulators. All areas of the financial industry – including its regulators, managements and even its customers – were filled with such confidence that they began to ignore the fundamentals of risk.
The head of the Federal Deposit Insurance Corporation in the USA noted that there had arisen a “prevailing belief that financial markets, through financial engineering, had created a system where risks were easily identified and transferred from parties who were risk averse to those who were willing, ready and capable to assume these risks. The collapse of these markets calls these beliefs into question.”14
Figure 2.2 Growth in the credit default swaps market ($bn)15
Figure 2.3 Growth of the securitisation market in the USA and Europe ($bn)16
Just as technology has transformed the fields of communications and transport, making things possible that were unthinkable a couple of decades prior, so did people assume that finance could also leap forward and give them the ultimate “Holy Grail” of risk-free reward. In this pursuit, banks and investors were happy to trust the risk assessment of specialised third-party agencies, who had devised tools to identify and measure the risk in the capital markets. The credit ratings agencies gave ratings to securitisation bonds (see Section 3.6.5), which were made up of portfolios of mortgage loans or similar assets. By splitting up the portfolio into slices, different investors could take different risk profiles on the same pool of mortgages, some with higher risk and a higher return and others with less risk and a lower return. Investors – including some of the most sophisticated banks in the world – trusted the expertise of the ratings agencies and their assessment of the riskiness of the mortgage portfolio and how the individual slices spread that risk. In a nutshell, securitisation appeared to be the perfect tool to provide a high-yield, low-risk product for investors and low-cost finance for borrowers. The securitisation market quadrupled in the run-up to the financial crisis, as shown in Figure 2.3.
At the same time, there was the rise of a new type of funding arbitrage vehicle in the wholesale market: the “conduit” and the “Specialised Investment Vehicle” (SIV). Although the names make them sound complex, in fact they did something very straightforward. They invested in (supposedly) high-quality, long-dated investments and borrowed at low rates on a short-term basis. The arbitrage created a profit stream that seemed risk free, for the risk of their funding sources evaporating was not seen as a worry. Again, clever technology appeared to offer a breakthrough and people loved it.
Faced with a wall of money seeking a decent yield in a low-interest rate environment, the new efficiency of the capital markets led to an odd situation: money became too cheap. This is illustrated in a chart from early 2007, which featured in the Bank of England’s Financial Stability Report. The chart in Figure 2.4 breaks down the cost of borrowing into the cost a risk-free investment (the bottom layer), the risk of the borrower (middle two layers, both expected and unexpected loss, see Section 3.3) and the “residual” cost (the top slice in the chart). This slice can be thought of as the return that the lender gets by putting their money to work. It collapses to zero towards the end of 2006. Banks and bond investors were simply not being compensated for the provision of funds. Clearly, the disciplines of caveat emptor and market-based pricing were not being observed.
Figure 2.4 Decomposition of borrowing costs over time17
Note from the original source chart: Decomposition of borrowing costs for UK high-yield corporates. The decomposition assumes a debt maturity of 20 years. For details, see Churm, R and Panigirtzoglou, N (2005), ‘Decomposing credit spreads’, Bank of England Working Paper no. 253.
The factors set out above are the consequences of deeper imbalances in the global economy, in which “the US financial sector bridged the gap between an overconsuming and overstimulated United States and an underconsuming and understimulated rest of the world”.18
Note that, unlike many commentators, we do not single out the banks’ excessive leverage, lack of capital, scarcity of on-hand liquidity reserves or weak term funding structures as causes of the crisis. Why? Because we see these as second-order factors, symptoms of the underlying failure of risk management and over-confidence. Whilst it is true that banks would have fared better during the crisis if they had had better financial resources, it must be stressed that more capital, more liquidity and more funding are not themselves remedies for the weaknesses of the banking industry.
Feature
Impact
Politics and society
Massive confidence and belief in free markets
Poor oversight of the banking industry (by shareholders, management and supervisors)
Risk management failures and loose underwriting standards
Policy to increase levels of home ownership among the disadvantaged in the USA
Low interest rates
Policy-induced boom in asset prices and borrowing
Recycling of trade balance surplus in Asia into Treasuries keeping rates low
Global imbalances
Asian savings lead to savings “glut” and a Western borrowing binge
Widening of trade surplus in some countries
Introduction of the Euro
More liquidity, cheaper and greater levels of finance available
Abundant liquidity
No attention to liquidity risk: money is infinite and elastic
“Greenspan put”
Increased risk appetite due to limited downside
Financial innovation
More ways to manage risk but also easier ways for investors to misprice risk
Combination of the above
Decline of investor discipline and neglect of
caveat emptor
rule
Interconnectedness
Huge growth in the number and value of transactions between financial counterparties
Table 2.1 Factors contributing to the fragility of the financial system
A much wider cast of characters share responsibility for the crisis: it includes domestic politicians, foreign governments, economists like me, people like you. Furthermore, what enveloped all of us was not some sort of collective hysteria or mania. Somewhat frighteningly, each one of us did what was sensible given the incentives we faced. Despite mounting evidence that things were going wrong, all of us clung to the hope that things would work out fine, for our interest lay in that outcome. Collectively, however, our actions took the world’s economy to the brink of disaster, and they could do so again unless we recognize what went wrong and take the steps needed to correct it.19
This question, asked by many including Queen Elizabeth II at the London School of Economics in November 2008,20 has one very clear answer: they did. But no-one paid too much attention: the warnings were not acted upon. “The threats to global financial stability that were bound to result from the build-up of severe macroeconomic financial imbalances were noticed and widely commented upon, but did not lead to any concrete policy action aimed at reducing these imbalances”.21 Perhaps the clearest indicators of tensions and risk were the excellent analyses in the April 2007 edition of the Bank of England’s “Financial Stability Report” (FSR). As well as the chart referenced earlier (Figure 2.4), showing that borrowing costs were too low, the FSR gives very clear and accessible analyses that were, in aggregate, wholly supportive of the view that firm action of some sort was required. These analyses charted, amongst other items, the continuing rise in share prices, the declining risk premium demanded by investors, the increasing delinquency in American subprime home loans, the increasing indebtedness of UK corporates, and the rapid growth in the size of major international banks’ balance sheets. The FSR concludes its risk assessment, observing in classic British understatement that:
In practice, the vulnerabilities are unlikely to be exposed in isolation, since several are interdependent and a number could be triggered by common shocks. An increasingly likely stress scenario would be a sharp unwinding of low risk premia, which then triggered a pickup in corporate defaults as credit conditions tightened. The unwinding of leveraged positions in corporate credit markets could lower market liquidity, amplifying falls in asset prices. The sharp movements in some markets in late February and early March highlight the potential for a more marked adjustment in asset prices if underlying conditions were to change more fundamentally. If price falls led to a generalised retreat from risk-taking, and a rise in correlation across asset markets, the scope for diversification against such shocks would be reduced. In such a scenario, the sustainability of high revenues generated by “originate and distribute” business models could be called into question.22
In retrospect, the analyses are highly relevant, if not completely prescient. The FSR assumed that corporate credit defaults would be the major feature of any unwind, rather than the banking sector itself. But still, it is disappointing that such clear warnings from a leading authority had such little impact. At the time, several people observed that financial bubbles were like parties and “it is essential to take away the punchbowl when the party gets going”.23 But they all acknowledged the difficulty of such actions.
The fragility and risk of the monoline insurance industry was highlighted by Bill Ackmann at length well before the subprime collapse,24 while clear warnings during the early stages of the over-heating of house prices internationally were well documented by such authoritative institutions as the IMF.25
Later chapters deal with proposals meant to ensure that early warning signals are acted upon and that risk management remains at the fore, even when confidence is at a peak.
Advocates of market-led regulation were disappointed by the fact that market indicators did not anticipate the scale of the risks that were building up in the banking industry. If we look at a diverse set of five blue-chip banks in Table 2.2, we can see how unpredictive these market measures26 were:
Table 2.2 Overview of rating, equity valuation and CDS levels of major banks between 2007 and 2013
The same information for banks that needed to be resolved in some manner or other makes for grim reading (Table 2.3).
On the eve of the onset of the financial crisis, popular perception was that banks were a safe bet and the source of perpetual growth with little downside. Their profits were seen as real and not the product of an increasing level of risk. Typical of this sentiment was an article in mid-2006 in Fortune magazine entitled: “Why bank stocks are cash machines: With their high yields and low P/Es, they offer the potential for solid long-term gains with little risk.”27 Quite simply, the mood was optimistic – naïvely so.
August 2007
Northern Rock
S&P Credit Rating
A+ negative
Stock Price-to-Book Value Multiple
1.46
Credit Default Swap (5yr senior)
93
Lehman Bros.
S&P Credit Rating
AA− stable
Stock Price-to-Book Value Multiple
1.60
Credit Default Swap (5yr senior) (USD)
95
AIG Financial Products
S&P Credit Rating
AA stable
Stock Price-to-Book Value Multiple (AIG)
1.33
Credit Default Swap (5yr senior) (USD)
66
HBOS
S&P Credit Rating
AA− stable
Stock Price-to-Book Value Multiple
1.74
Credit Default Swap (5yr senior) (March 2008)
195
Hypo Real Estate
S&P Credit Rating
A− watch positive
Stock Price-to-Book Value Multiple (31 Dec 2007)
1.20
Credit Default Swap (5yr senior)
–
Table 2.3 Overview of rating, equity valuation and CDS levels of selected troubled financial institutions (as of August 2007)
Although the tensions were building during 2006, the first ominous sign of an impending crisis was the profit warning from HSBC on 7 February 2007 (see Section 5.4). It was disturbing, to say the least, for such a major bank to be announcing such a marked deterioration in the performance of its American business. However, for most people, the start of the financial crisis was marked by the announcement by BNP Paribas, on 9 August 2007, that it was freezing valuations on some of the funds that it administered on behalf of clients:
The complete evaporation of liquidity in certain market segments of the US securitisation market has made it impossible to value certain assets fairly regardless of their quality or credit rating. The situation is such that it is no longer possible to value fairly the underlying US ABS assets in the three above-mentioned funds. We are therefore unable to calculate a reliable net asset value (“NAV”) for the funds. In order to protect the interests and ensure the equal treatment of our investors, during these exceptional times, BNP Paribas Investment Partners has decided to temporarily suspend the calculation of the net asset value as well as subscriptions/redemptions, in strict compliance with regulations.28
The first months of the crisis were dubbed a “subprime crisis” and the jargon word “subprime” is now well understood around the globe. Of course, it refers to the mortgages provided to people who were unable to put down a large deposit for a house and unable, by conventional metrics, to pay down the mortgage balance over time. In fact, they were only able to service the interest payments due to subsidised introductory rates and only keen to take on the debt in the first place in the hope of profiting from rising real estate prices. Many subprime loans were for properties other than the primary dwelling of the borrower: they were speculative. The word “subprime” originates in the USA and it was in the USA that the market for subprime mortgages flourished. Banks and mortgage brokers were able to originate mortgages, parcel them up into securitisation structures and sell them off into the capital markets. The ratings agencies ran their cursory analyses and assigned AAA ratings to the vast majority of the mortgage pools. As we have seen, the quest for yield had led to investor myopia – they were duped by the superlative ratings and mispriced the risk.
When house price increases cooled off, the rising levels of mortgage delinquency led to losses in the subprime world. Several small subprime specialists had gone bust in 2006, but it was the HSBC profit warning that initiated a more intense market focus on subprime exposures. Day after day, financial institutions around the world disclosed their exposure to subprime and their estimate of the losses they faced. Evidently, the problem was not confined to just the loans themselves. In addition to subprime loans which the banks had themselves extended, exposure to the problem could arise via:
Pooled loans within securitisation bonds; for some banks, this included securitisations that they had been building up for selling on (so-called “warehouses” of loans).
CDOs: investments that had bought bonds from different securitisation pools and wrapped them together to create a pool-of-pools.
CDO-squareds, a kind of pool-of-pool-of-pools.
SIVs (Special Investment Vehicles), which some banks had established to invest in long-term subprime-related assets via short-term funding: quite simply, they were used as a low-risk “carry trade” (see Glossary).
Inventory held within trading operations.
And for all of these, exposures that had been guaranteed by buying default insurance from a specialised financial guarantor or insurance company – the “monolines”.
These new structures were not irrelevant. For example, SIVs may sound like an esoteric backwater of the banking industry, but in aggregate they were huge: total SIV assets were over $300bn. Examples of SIVs include those shown in Table 2.4.
And SIVs were specialised in holding bank paper and securitisation bonds (Table 2.5).
No-one could readily understand where the losses – which were clearly going to be enormous – would hit. The global nature of the financial markets and the complexity of the loans, which had been pooled and sliced multiple times and in myriad ways, made the question impossible to answer with any degree of certainty.
