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Friday, February 23, 2018
Monday, February 19, 2018
FDIC Chairman's "Living Will" Speech @ Wharton, NY Fed Revises GDP Down, FDIC Publishes Annual Report & Survey Shows Slight Wage Relief
You can learn a great deal by listening to the "public" speeches given by Fed leadership. It's one thing to give testimony on Capital Hill, it's quite another to give a speech in front of people that actually know what you're talking about. In this speech, Gruenberg, the Chairman of the FDIC, discusses the actions taken over the past 10 years to ensure against another "Great Recession".
He discusses the establishment of the Dodd-Frank Act and the authority it gave the FDIC to manage the orderly failure of banks in times of crisis. Among other things, the new authorities gave the FDIC:
The ability to place the financial firm, including its holding company, into a receivership process;
An Orderly Liquidation Fund to assure liquidity for the orderly wind down and liquidation of the failed firm;
Authority to impose a short stay on derivatives contracts; and
The ability to coordinate with foreign authorities in the case of a firm with global operations.
The Evolution of the Living Will Process
As a way to create a framework around an orderly bank liquidation, the FDIC created the living will process. According to Gruenberg, the living will "required both the Federal Reserve and the FDIC to consider the objectives of the process, the standards and the guidance that would need to be provided to the firms to achieve the objectives, and the means of engagement with the firms to assist them in following the guidance". This process required banks to provide a description of the following:
The firm’s strategy for orderly resolution in bankruptcy during times of financial distress;
The range of actions the firm proposes to take in resolution;
Liquidity and capital needs and resources of the firm;
A description of the firm’s organizational structure, material entities, interconnections, and interdependencies; and
The firm’s corporate governance process.
The only thing that really matters here is liquidity. With the right liquidity and capital resources, any crisis can be avoided or at least pushed off, but for how long?
The truth is, none of these changes would have saved Lehman Brothers or Bear. None of these resolutions would have made AIG confess to creating bad securities. The truth is, everything happened exactly how the banks wanted it to happen. They got a huge bailout, 10 years of free money, and trillions in reserves at the Fed. To top it all off, Dodd-Frank approved a resolution to pay banks for those reserves. Who pays the interest? We do. The American taxpayer. We don't control rates or the amount of reserves held at the Fed, but we have to pay whatever rate the Fed sets on those reserves. Sounds fair. This is why people are gravitating toward Bitcoin and precious metals.
In other news, Nowcast is a forecast of the upcoming GDP announcement. It was updated and revised down to 3.11%. The leading causes are due to a decline in:
- capacity utilization,
- industrial production,
- general business conditions (as reported in a daily brief last week); and,
- retail sales.
In other words, all things driven by consumer demand are starting to decline, while anything driven by debt (inflation, pricing and housing) are on the rise.
The Empire State Manufacturing Survey/Business Leaders Survey included a supplemental survey on wages, a critical piece of the consumer demand equation. Wages are of key interest because without wages, GDP will continue to fall -- not everyone has access to massive amounts of debt. What does the survey show? Job openings are taking longer to fill, manufacturers are hiring more, and starting pay is going up. Will it be enough to impact earnings? My guess is no. Why? Wall Street doesn't like wage increases.
Friday, February 16, 2018
The FDIC Lowers Credit Standards, Household Debt Jumps, General Business Conditions Fall & There's An Increase in Jumbo Loans
On February 14, 2018, the FDIC Board of Directors adopted a rule to permit the removal of "external credit ratings".
"The final rule removes references to external credit ratings and replaces them with appropriate standards of creditworthiness."
In other words, as long as a bank makes under $1 billion in total assets it doesn't need to reference external credit ratings in order to label an asset or security as "investment grade". These classifications are used for capital allocation and pledged assets. The rule reduces the need to classify assets as investment grade with a much lower bar -- as of this ruling "An entity has adequate capacity to meet financial commitments if the default risk is low, and the full and timely repayment of principal and interest is expected."
The rule also "adds cash to the list of assets eligible for pledging and separately lists Government Sponsored Enterprise obligations as a pledgeable asset category."
So mortgaged backed securities are now considered pledgeable assets as well as cash? And, if you have cash, why do you need to pledge assets?
Household Debt Jumps as 2017 marks the 5th consecutive year of annual growth based on the latest Quarterly Report on Household Debt and Credit.
The report reveals that total household debt reached a new peak in Q4 of 2017, rising $193 billion to reach $13.15 trillion. Balances climbed:
- 1.6% on mortgages,
- 0.7% on auto loans,
- 3.2% on credit cards; and,
- 1.5% on student loans.
According to the Empire State Manufacturing Survey, a monthly survey of manufacturers in NY conducted by the Federal Reserve, the general business conditions index fell five points to 13.1.
A report by the Fed regarding jumbo loans -- these are loans that are over ~$625,500 -- suggests the number is growing.
Thursday, February 15, 2018
Corporate "Skin in the Game", The Real Reason The Fed's Raising Rates, SECs 3.5% Budget Request Increase, The SECs New SCSD Initiative and Misleading Oil Prices
"Does More "Skin in the Game" Mitigate Bank Risk-Taking?"
So, instead of looking at this as a consideration for banks, let's extend it. This should be a consideration for all stocks. Perhaps the issue with the corporate state is that the shareholders don't have any personal liability. They are limited in the amount they can lose. What if the shareholder had to worry about being liable for legal or environmental issues? What if the shareholder had to worry about being sued for the corporation's irresponsibility? I suppose a lack of earnings equates to a sell-off, which is the ultimate punishment for the corporation.Excessive risk-taking by banks has long been a paramount concern of regulators. The basic problem arises in part due to misaligned incentives; under the current limited (single) liability structure, shareholders of a failed bank can lose no more than their initial investment. With this limited skin in the game, bank shareholders’ private incentives may lead them to take more risk than is socially optimal. If, by contrast, shareholders were liable for the entirety of a bank’s losses, their private risk-taking decisions may be more aligned with socially optimal risk‑taking.
Final thoughts: This article does nothing but shed light on the fact that we still have an incredible amount of power over the corporate state. Anything that can hurt earnings is a threat to the corporate state, including its own hubris. Couching gambling schemes in terms of limited liability structures doesn't hide what's happening. If anything, it is a concession to the system's vulnerabilities.
The Overnight Bank Funding Rate currently stands at 1.42%. Do not be confused. This rate is based on the interest rate on excess reserves (IOER rate), which is not the same as the interest rate on required reserves (IORR). Currently, both rates are the same, however (you can view both rates here)
If you're old like me, you remember when the rate was referred to as the fed funds rate. The name was changed when banks were given the ability to charge interest on reserves in 2008. Once this deal was made, the Fed started giving out "reserves" like candy in a scheme referred to as quantitative easing. Today, over $2.2 trillion sits in reserves at the Fed and we (the United States) are paying interest on all those reserves, both at the IOER and the IORR.
The overnight bank funding rate is reported every day. It will never be higher than the rate banks can get from leaving money at the Federal Reserve (IOER or the IORR).
Final thoughts: Every now and then I like to revisit this issue of rates. I hear people wondering if the Fed is going to raise rates and I wonder if they understand what's really going on. Ultimately, the real reason why the Fed is going to raise rates has very little to do with the state of the economy. And, the higher rates go, the more banks get paid. The issue for banks is that inflation is a four letter word. It means lenders will be paid back with less money. If you own $100,000 on your home, and the value of the dollar tanks by 50%, you still owe 100,000 of those dollars, but they're only worth $50,000. Inflation is great for borrowers. So, the game the Fed has to play is -- how do we make sure people still believe in the value of the dollar while raising rates? It has nothing to do with cooling off the economy.
The next article is about Deutsche Bank. The bank will have to pay $3.7 million to customers for misleading them about mortgage backed security prices. What's interesting to me is that this is supposed to be a fair settlement.
To settle the charges, Deutsche Bank agreed to reimburse customers the full amount of firm profits earned on any CMBS trades in which a misrepresentation was made. According to a payment schedule in the order, Deutsche Bank will distribute more than $3.7 million. Deutsche Bank also agreed to pay a $750,000 penalty. Solomon agreed to pay a $165,000 penalty and serve a 12-month suspension from the securities industry.$3.7 million is nothing in the trading world. We are supposed to believe this is the full amount of the profits made? What's funny is that the SEC apparently believes it. They also think that a 12-month suspension from the securities industry and a $165K penalty is going to stop this kind of activity. The penalty is nothing compared to rewards, even if you do get caught.
Final thoughts: As I've said before, the SEC has been rendered toothless over the years. What's funny is that the very banks that gutted the SEC's power are asking for its protection against Bitcoin. Good luck with that.
As an extension of what's going on at the SEC gutting, I think it's interesting that the SECs budget request is 3.5% higher than it was last year.
In order to keep up with the rapid pace of technology advancement in the areas the SEC regulates, the request seeks a $45 million increase in funding for information technology enhancements to support the agency’s cybersecurity capabilities, risk and data analysis, enforcement and examinations, and automation of business processes. The fiscal year 2019 budget request level is a 3.5 percent increase over the fiscal year 2018 budget request of $1.602 billion.The total request is for $1.658 billion.
On Monday, the SEC launched the Share Class Selection Disclosure Initiative (SCSD) to encourage self-reporting. The SEC has no way to enforce this really -- how can they enforce fiduciary responsibility when its antithetical to capitalism? So they've created a hotline to encourage self-reporting. This is also funny. Here's an excerpt that sums up the effort:
The Commission has long been focused on the conflicts of interest associated with mutual fund share class selection. Differing share classes facilitate many functions and relationships. However, investment advisers must be mindful of their duties when recommending and selecting share classes for their clients and disclose their conflicts of interest related thereto. In the past several years, the Commission has charged nine firms with failing to disclose these conflicts of interest. These actions included significant penalties against the investment advisers, and collectively returned millions of dollars to clients.The reason this won't work is because there's no motivation to self-report. Advisers have to pay back all ill-gotten gains and admit to their customers that they mislead them, but the SEC won't impose a civil monetary penalty? C'mon.
Under the SCSD Initiative, the Enforcement Division will recommend standardized, favorable settlement terms to investment advisers that self-report that they failed to disclose conflicts of interest associated with the receipt of 12b-1 fees by the adviser, its affiliates, or its supervised persons for investing advisory clients in a 12b-1 fee paying share class when a lower-cost share class of the same mutual fund was available for the advisory clients. Among other things, for eligible advisers that participate in the SCSD Initiative, the Division will recommend settlements that will require the adviser to disgorge its ill-gotten gains and pay those amounts to harmed clients, but not impose a civil monetary penalty. The Division warns that it expects to recommend stronger sanctions in any future actions against investment advisers that engaged in the misconduct but failed to take advantage of this initiative.Final thoughts: Initiatives like this are the reason why the SEC is absolutely ineffective.
Finally, the Fed issued their weekly report on oil prices. It says that a "large drop in demand expectations decreased oil prices significantly". As a trader of crude oil, I know that the price of crude oil has gone nowhere but up since the middle of last year so I find this pronouncement humorous. Please note that gas prices are a key part of inflation. In fact, the Fed/FOMC credit low inflation with declining oil prices. In other words, the Fed is actively trying to suppress the true price of oil because.
Final thoughts: The Fed's pronouncements are incongruent. The headline is the opposite of the points used to prove the point. The headline reads "Gas prices down", while the bullet points read, "Gas prices headed up." This is a classic case of someone being told what to say when they don't have the data to support the conclusion.
Wednesday, February 14, 2018
Reason #1: The price of Bitcoin and cryptos in general falls every year in Q1. Each year, the price rebounds and soars by the end of the year.
As you can see from the charts above, this is a normal trend for Bitcoin and one that the community has come to expect.
Reason #2: Despite the call for regulation by central banks, nation states are starting to realize their own power. While the SEC and CFTC battle over who gets to regulate cryptocurrency, Arizona just passed a bill allowing it as a form of payment by the Department of Revenue. In other words, you will be able to pay your Arizona taxes in Bitcoin. There's also a resolution passed in Congress calling for a pro-bitcoin national policy. When/if that resolution gains traction, the price of Bitcoin will soar.
Reason #3: Third and perhaps most importantly, hedge funds and other large institutional players are just now getting into the market. They could not enter the market prior to Bitcoin futures which started in December 2017. Below is one of my favorite videos in support of this, hedge fund manager clearly explains what institutional players are doing right now.
It might take six to eighteen months, but Bitcoin is a much more valuable way to store your digital currency. Remember, only 9% of the world's currency is physical, the rest is digital. Institutions get it and they're getting on board.
Final thoughts: Bitcoin is extremely volatile. For this reason, you don't want to buy at the highs, but rather the lows. Bitcoin is officially in a low cycle and now is a great time to buy. If you don't buy now, save up to buy next year at this time.
Where to buy? You can buy Bitcoin from an exchange (Binance or Local Bitcoin) to hold yourself or you can purchase an investment product, like an IRA. Bitcoin IRAs have the same tax treatment as traditional IRAs.
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