Investment risk management plea

Much of the past year has been deeply humbling for our industry. People are understandably angry and our industry has to account for its role in what has transpired.

Financial institutions have an obligation to the broader financial system. We depend on a healthy, well-functioning system but investors failed to raise enough questions about –

As policymakers and regulators begin to consider the regulatory actions to be taken to address the failings, I believe it is useful to reflect on some of the lessons from this crisis.

The first is that risk management should not be entirely predicated on historical data. In the past several months, we have heard the phrase “multiple standard deviation events” more than a few times. If events that were calculated to occur once in 20 years –

Our industry must do more to enhance and improve scenario analysis and stress testing.

Second, too many financial institutions and investors simply outsourced their risk management. Rather than undertake their own analysis, they relied on the rating agencies to do the essential work of risk analysis for them.  This was true at the inception.  It continued over the period of the investment.   They did not heed other indicators of financial deterioration during which time.

This over-dependence on credit ratings coincided with the dilution of the coveted triple A rating. In January 2008, there were 12 triple A-rated companies in the world.  At the same time, there were 64,000 structured finance instruments, such as collateralised debt obligations, rated triple A.  It is easy and appropriate to blame the rating agencies for lapses in their credit judgments.  But the blame for the result is not theirs alone.  Every financial institution that participated in the process has to accept its share of the responsibility.

Third, size matters.  …whether you owned $5bn or $50bn of (supposedly) low-risk super senior debt in a CDO, the likelihood of losses was, proportionally, the same.  But the consequences of a miscalculation were obviously much bigger if you had a $50bn exposure.   Failure of adequate investment risk management by managers of substantial funds will have a broader impact in the investment community.  This is because of the numbers of investors with smaller investable funds being affected (in their environment).

 

Fourth, many risk models incorrectly assumed that positions could be fully hedged.  After the collapse of Long-Term Capital Management –

were created to help offset a number of risks.

However, (our) industry, did not consider carefully enough the possibility that –

Fifth, risk models failed to capture the risk inherent in off-balance sheet activities, such as structured investment vehicles.  It seems clear now that managers of companies with large off-balance sheet exposure did not appreciate the magnitude of the economic risks they were exposed to:

Sixth, complexity got the better of us.  The industry let the growth in new instruments outstrip the operational capacity to manage them.  Operational risk increased dramatically and this had a direct effect on the overall stability of the financial system.

Last, and perhaps most important, financial institutions did not account for asset values accurately enough.  I have heard some argue that fair value accounting – which assigns current values to financial assets and liabilities – is one of the main factors exacerbating the credit crisis.  I see it differently.  If more institutions had properly valued their positions and commitments at the outset, they would have been in a much better position to reduce their exposures.

For Goldman Sachs, the daily marking of positions to current market prices was a key contributor to our decision to reduce risk relatively early in markets and in instruments that were deteriorating.  This process can be difficult, and sometimes painful, but I believe it is a discipline that should define financial institutions.

Authors Note. The above link reflects a strategy adopted by ContinuumFP as part of the investment risk management process for our clients.

 

Some lessons going forward

As a result of these lessons and others that will emerge from this financial crisis, we should consider important principles for our industry, for policymakers and for regulators.  For the industry, we cannot let our ability to innovate exceed our capacity to manage.  Given the size and interconnected nature of markets, the growth in volumes, the global nature of trades and their cross-asset characteristics, managing operational risk will only become more important.

Risk and control functions need to be completely independent from the business units.  And clarity as to whom risk and control managers report to is crucial to maintaining that independence.  Equally important, risk managers need to have at least equal stature with their counterparts on the trading desks: if there is a question about the value of a position or a disagreement about a risk limit, the risk manager’s view should always prevail.

Understandably, compensation continues to generate a lot of anger and controversy.  We recognise that having troubled asset relief programme money creates an important context for compensation.  That is why, in part, our executive management team elected not to receive a bonus in 2008, even though the firm produced a profit.

More generally, we should apply basic standards to how we compensate people in our industry.  The percentage of the discretionary bonus awarded in equity should increase significantly as an employee’s total compensation increases.  An individual’s performance should be evaluated over time so as to avoid excessive risk-taking.  To ensure this, all equity awards need to be subject to future delivery and/or deferred exercise.  Senior executive officers should be required to retain most of the equity they receive at least until they retire, while equity delivery schedules should continue to apply after the individual has left the firm.

For policymakers and regulators, it should be clear that self-regulation has its limits.  We rationalised and justified the downward pricing of risk on the grounds that it was different.  We did so because our self-interest in preserving and expanding our market share, as competitors, sometimes blinds us – especially when exuberance is at its peak.  At the very least, fixing a system-wide problem, elevating standards or driving the industry to a collective response requires effective central regulation and the convening power of regulators.

Capital, credit and underwriting standards should be subject to more “dynamic regulation”.  Regulators should consider the regulatory inputs and outputs needed to ensure a regime that is nimble and strong enough to identify and appropriately constrain market excesses, particularly in a sustained period of economic growth.  Just as the Federal Reserve adjusts interest rates up to curb economic frenzy, various benchmarks and ratios could be appropriately calibrated.  To increase overall transparency and help ensure that book value really means book value, regulators should require that all assets across financial institutions be similarly valued.  Fair value accounting gives investors more clarity with respect to balance sheet risk.

The level of global supervisory co-ordination and communication should reflect the global inter-connectedness of markets.  Regulators should implement more robust information sharing and harmonised disclosure, coupled with a more systemic, effective reporting regime for institutions and main market participants.  Without this, regulators will lack essential tools to help them understand levels of systemic vulnerability in the banking sector and in financial markets more broadly.

In this vein, all pools of capital that depend on the smooth functioning of the financial system and are large enough to be a burden on it in a crisis should be subject to some degree of regulation.

After the shocks of recent months (of late 2008) and the associated economic pain, there is a natural and appropriate desire for wholesale reform of our regulatory regime.  We should resist a response, however, that is solely designed around protecting us from the 100-year storm.  Taking risk completely out of the system will be at the cost of economic growth.  Similarly, if we abandon, as opposed to regulate, market mechanisms created decades ago, such as securitisation and derivatives, we may end up constraining access to capital and the efficient hedging and distribution of risk, when we ultimately do come through this crisis.

Most of the past century was defined by markets and instruments that fund innovation, reward entrepreneurial risk-taking and act as an important catalyst for economic growth.  History has shown that a vibrant, dynamic financial system is at the heart of a vibrant, dynamic economy.

We collectively have a lot to do to regain the public’s trust and help mend our financial system to restore stability and vitality. Goldman Sachs is committed to doing so.”