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1 Comments on Pasani-Ferry and Sapir Banking crisis management in the EU: An interim assessment September 10, 2009 Thomas Glaessner MD Global Policy Strategy [email protected] 212-723-1410 EU actions taken in Europe exceeded the market’s expectations in some respects Slides 1-16 provide an assessment of the drawbacks inherent in the institutional arrangements for coordination in Europe with which I largely concur – Market integration went forth as large European banks diversified geographically inside Europe (Pan European) and beyond – Importantly institutional arrangements for crisis management lagged in six essential areas per slide 15. All six of the points noted are important in my view Information asymmetries—remains an issue in the US as well Disparate national deposit insurance regimes Unspecified LOLR role of ECB Potential disparity in liquidity provision across currency areas Clashes between state support and competition No common war chest for recapitalization operations of pan-European FIs – I would add no over-arching prompt corrective action (PCA) framework providing extra-judicial authority for resolution of systemic FIs. 3 Key Conclusions and Take Aways EU crisis management outperformed market expectations in several areas: – Liquidity provision and dollar lines and arrangements with other Central banks including the FED eventually were worked out—future arrangements? – Treatment of blanket debt guarantees and lack of coordination was overcome fairly rapidly after a shaky start—and coordination in pricing—but how will exit work? – Recapitalization operations of specific banks in countries and in cases of Pan European banks and subsidiaries were adequately coordinated despite national responsibilities for financial stability—subs helpful—how sustainable? – Flexibility in the application of state aid rules – Principles for treatment of impaired assets useful Were the responses truly fast enough in a global financial system—what are changes that can be institutionalized in future? Many of us warned that coordination abilities in the case of systemically important FIs would be tested? 4 The Road Ahead Remaining Issues the Authors raise – Information Asymmetries was a serious unsolved problem throughout the crisis—will stress tests European style mitigate this risk and if so how? – Is the division of responsibilities truly adequate for the next crisis—especially regarding financial stability and differing fiscal situations and regimes? – Is the risk of zombies real and is the ECB trapped in cheap liquidity support—have European banks taken adequate write downs? – Supervision of Pan European banks? 5 Where are European and US Banks: A Snapshot Global Leverage 7 Delinquency rates for 100 US banks still rising at increasing rates Source:Citi, IMF, FED Futures markets are pointing to substantial further declines in home prices and even FHFA expect a further decline of 10% in home prices into next year. In the United States, delinquency and foreclosure rates have continued to rise on both prime and nonprime loans and foreclosure moratoriums and other work-out efforts have only just started to reverse the deterioration (mainly for poorest credits by FICOs). In some cases, public interventions, including large-scale purchases of mortgage-backed securities (MBS), have helped reduce primary and secondary mortgage rates and contain or narrow spreads. Bank de-leveraging still has a long way to go. Commercial real estate and property based lending is another lingering issue and not only among smaller US banks 8 Charge-Offs and Write-downs by Region—US more Aggressive Charge-Off Rates Write Downs By Region Percent of Loans 1.8 100% 1.6 90% US Europe 1.4 Other 80% 1.2 1.0 70% Trading / securities / derivatives 60% Monolines 50% 0.8 40% 0.6 30% 0.4 20% 0.2 10% Unsecuritized mortgages & loans SIVs and conduits 0% 0.0 1985 1990 Source: Bloomberg, Citi. 1995 2000 US 2005 Europe Asia ABS & CDOs of ABS Source: Federal Reserve, Company data, Citi Investment Research. Loan losses to become much, much worse. Bank de-leveraging still has a long way to go. 9 Bank Capital Requirements The IMF expects lower operating earnings going forward will reduce the cushion against further credit write-downs on capital. Under the stylized scenario, banks’pre-provision earnings are forecast to drop by between a third and a half. This is less than the 50 percent drop experienced by U.S. banks during the Great Depression, but in line with the experience of Japanese banks during the 1990s. Charge-offs are forecast to peak at 4.2 percent in the United States, 3.4 percent in the United Kingdom, and 2.8 percent in the Euro area. In each case, these are levels that are well above those experienced during the 1991–92 recession, though below those estimated to have been experienced in the United States during the Great Depression. Source:Citi, IMF 10 Write Downs and Capital Needs of Emerging Market Banks Write downs in emerging market banking systems (including subsidiaries of foreign parent banks ) could reach US 800 billion or 7 percent of assets In CEEMEA alone US 140 billion in fresh capital could be needed as shown in the table above of which 102 billion would be needed in Eastern Europe including the CIS and Russia. Will official financing along with fiscal resources from specific EM governments and IMF be enough? Can foreign banks adequately make up the capital shortfalls of their subsidiaries. This is an ongoing concern of local EM supervisors. 11 Leverage Ratios Have Improved from 2008 Levels CT1 / RWA T1 / RWA T1 / TA TCE / TA 2009 Capital Ratios USA Europe UK/Intl UK Switzerland Sweden Spain Poland Italy Hungary Greece Germany France Denmark Czech Cyprus Benelux Austria 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% CT1 / RWA T1 / RWA T1 / TA TCE / TA Change in Ratios from 2008 5.0% 4.0% 3.0% 2.0% 1.0% Source: Bloomberg, Citi 12 USA Europe UK/Intl UK Switzerland Sweden Spain Poland Italy Hungary Greece Germany France Denmark Czech Cyprus Benelux -1.0% Austria 0.0% US Bank CDS Have Come to Parity with European Banks especially in the aftermath of the stress tests Average Bank 5Y CDS Bear Stearns Rescue FED QE Announced Lehman Bankuptcy Stress Test Results TARP Passed 600 500 400 300 200 100 0 Apr-07 Source: Bloomberg, Citi US Banks European Banks Aug-07 Nov-07 Feb-08 Jun-08 13 Sep-08 Dec-08 Mar-09 Jul-09 Bank Debt in the US Has Traded Better Since the Release of the Stress Tests 3000 C Sen CDS 2500 C Sub CDS 2500 MS Sen CDS C 6.875% 38s 2000 C 6.125% 36s 2000 MS 6.625% 18s C 8.30% 37s 1500 Stress Test Results 1500 MS Sub CDS MS 4.75% 14s Stress Test Results 1000 1000 500 500 0 Oct-06 Apr-07 Nov-07 Jun-08 Dec-08 Jul-09 Jan-10 Jul-09 Jan-10 1600 1400 1200 1000 800 BAC Sen CDS BAC Sub CDS BAC 5.65% 18s BAC 5.42% 17s BAC 6.625% 36s Stress Test Results 600 400 200 0 Oct-06 Apr-07 Source: Bloomberg, Citi Nov-07 Jun-08 Dec-08 14 0 Oct-06 Apr-07 Nov-07 Jun-08 Dec-08 Jul-09 Jan-10 Some Thoughts on Issues Ahead Seven issues that may deserve analysis and attention but not treated in this paper 1. Sequencing of exit across multiple areas of intervention when not all exit is automatic—CB policies and micro—interventions relating to bank liabilities or deposit insurance— 2. Markets have a sense that European authorities are “papering over the cracks” (information asymmetry) and that relative write downs and impacts on access to credit will act as a drag for a longer time in Europe despite ECB exceptional support 3. Regulatory interventions that impact rights of claimants within the capital structure for FIs getting “meaningful state aid” (e.g. RBS) and actions taken in support of “burden sharing” and “competition policy” (interference with loan pricing) can have un-intended impacts 4. Re-defining capital, leverage, and liquidity buffers and timing of implementation across Europe given that some forms of capital disappear in a crisis—”quality of capital” 5. Fiscal transfer arrangements to allow for cross border resolutions and the need for PCA 6. Treatment of derivative operations for European banks and interconnectedness 7. How to make the market discipline pillar vibrant in Europe via quality of information improvements and greater attention to governance beyond executive compensation 16 FED BOE and ECB Balance Sheet Expansion—Liquidity and Special Facilities Bank of England Consolidated balance Sheet (billions of £) 350 Federal Reserve Balance Sheet 300 250 2400 200 Short term Lending to Financials 2000 150 Rescue Operations 100 Broader Credit Conditions 1600 50 800 Other assets Longer-term reverse repos Short-term market operations 400 Ways and Means advances to HM Government Bonds and other securities acquired via market transactions 7/3/2009 5/3/2009 3/3/2009 1/3/2009 11/3/200 9/3/2008 7/3/2008 5/3/2008 3/3/2008 1/3/2008 11/3/200 9/3/2007 7/3/2007 5/3/2007 1200 3/3/2007 0 1/3/2007 $ Billion Treasury Portfolio 0 Jan-07 Apr-07 Jul-07 Oct-07 Jan-08 Apr-08 Jul-08 Oct-08 Jan-09 Apr-09 Jul-09 ECB Open Market Operations, (Euros, bn) So far the Fed has purchased: – $268/300 bn of Treasuries – $117/200 bn of Agency Debt – $767/1250 bn of Agency MBS 17 Source: ECB, Citi Economic Research Fed Activity in Agency MBS CurrentCoupon Purch Program focus has been historically in near-par priced MBS Fed CC Purchasesasa % ofTotalPurchases This has shifted over recent weeks WA new Prod Cpn 60% Daily Fed demand roughly $500MM to $1B more than origination 4.75 50% 40% 30% 4.50 20% 10% 0% 4.25 Total30YR Purchases Fed Owned MBS ($B) 400 Week5 Fed Ownership % ofSettled MBS Week9 84% 300 72% 250 60% 200 48% 150 36% 100 24% 50 12% 0% 3.5s 4.0s 4.5s 5.0s 5.5s 6.0s Source: Federal Reserve, Fannie Mae, Freddie Mac, Ginnie Mae, and CIRA. 6.5s 18 Week17 Week21 Week25 Week29 Week33 96% 350 0 Week13 Fed Ownership of MBS (%) Week1 Fed ownership of low coupons extremely high relative to available float Lack of clarity on program termination could be contributing to recent move away from near par-priced MBS Coupon (%) Fed’s Balance Sheet Roll-Off Growth in Fed balance sheet is mostly a result of QE programs Prepayments on the Fed MBS portfolio are likely to be fairly slow with the majority of the portfolio consisting of 30yr 4.0s and 4.5s 3,000 MBS QE Actual Debt + Tsy QE Other Special Lending Facilities (Non-QE) Forecast 2,500 2,000 1,500 1,000 500 0 Jun 08 Jun 09 Jun 10 Jun 11 Jun 12 Jun 13 19 Source: Federal Reserve, and CIRA. Jun 14 Jun 15 Jun 16 Jun 17 Jun 18 Rethinking the Market Discipline Framework Block 1: Information and Dislcosure Block 4: Internal Governance Accounting and financial reporting External auditors Prudential disclosures Credit rating agencies Valuation providers Risk Governance Executive Compensation Board of Directors (Independence and qualifications) Influence Monitoring Block 2: Stakeholders Block 3: Discipline Mechanisms Market participants (Counterparties, depositors, shareholders, debt investors, etc.) Media and research analysts Source: Rethinking Market Discipline, Constantino Stephanou, World bank 20 Quantity/price adjustments in bank instruments (equity, debt, deposits, hybrids, derivatives etc.) Market for corporate control Legal redress (investor protection rules, court system) Supervisory actions Bank Capital Framework 21 Bank Capital Framework 22 Disclaimer This communication is issued by a member of the sales and trading department of Citigroup Global Markets Inc. or one of its affiliates (collectively, “Citi”). 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