Post mortem overload
Reading, digesting and implementing the many suggestions, guidelines and rules in the wake of the credit crisis is becoming a full-time job. To name the sources of just a few: the President's Working Group on Financial Markets, the US Treasury, the International Organisation of Securities Commissions, the Financial Stability Forum, the Senior Supervisors Group, the Institute of International Finance and, most recently, the Counterparty Risk Management Policy Group.
The recommendations within these reports are many and wide-ranging, from the valuation of structured credit products and rating agency practices, to liquidity risk management, derivatives infrastructure and regulatory capital charges. Many of the recommendations overlap - begging the question why there couldn't have been slightly more co-ordination in regulatory responses.
But one of the interesting themes to emerge from the various reports is the role of the risk management function within banks, how it liaises with senior management, and how models and quantitative analysis are used. Some banks, it emerges, put too much onus on key risk management metrics, not asking basic questions about gross exposures or challenging assumptions. The idea of banks' boards of directors, in some cases with little capital markets experience, leafing through value-at-risk reports - and potentially making business decisions off the back of these numbers - is, frankly, alarming.
Others didn't pay enough attention to internal pricing models, putting too much reliance on ratings, dealer quotes and pricing services to value structured credit holdings. As a result, a number of banks built up sizeable super-senior collateralised debt obligation warehouses without having a clear idea of the risks involved, or the tools at their disposal to manage this risk.
Some, meanwhile, did have the right models and processes in place, but either didn't believe the results or blatantly ignored them. Anecdotal stories are circulating about risk managers approaching senior managers in 2006 with the results of stress tests based on a hefty drop in the US housing market, and being laughed out of the room.
Clearly, there's no single failure or weakness that can be identified. There were lots of moving parts to this crisis, with seemingly unconnected factors combining to create the mother of all market dislocations - hence, presumably, the sheer volume of reports into the causes of the crisis. The benefit of the recent soul-searching is that risk management will have more clout and resources, while senior management will be more questioning of valuations and risk management figures. But it still would have been nice if regulators could have got together, trawled through the causes, and outlined their recommendations in a manageable number of documents.
Nick Sawyer, Editor.
Only users who have a paid subscription or are part of a corporate subscription are able to print or copy content.
To access these options, along with all other subscription benefits, please contact info@risk.net or view our subscription options here: http://subscriptions.risk.net/subscribe
You are currently unable to print this content. Please contact info@risk.net to find out more.
You are currently unable to copy this content. Please contact info@risk.net to find out more.
Copyright Infopro Digital Limited. All rights reserved.
As outlined in our terms and conditions, https://www.infopro-digital.com/terms-and-conditions/subscriptions/ (point 2.4), printing is limited to a single copy.
If you would like to purchase additional rights please email info@risk.net
Copyright Infopro Digital Limited. All rights reserved.
You may share this content using our article tools. As outlined in our terms and conditions, https://www.infopro-digital.com/terms-and-conditions/subscriptions/ (clause 2.4), an Authorised User may only make one copy of the materials for their own personal use. You must also comply with the restrictions in clause 2.5.
If you would like to purchase additional rights please email info@risk.net
More on Regulation
FRTB revamp won’t restore models to past glory, risk managers say
US-inspired reform only expected to lead to small boost in adoption, with limited desks on IMA
Regulators must think bigger to tackle tech risks, says Hong Kong SFC
Leung warns AI adoption and recent cyber scares show new threats require global co-operation
Time to let some air out of the banking system?
Watchdogs worry about lowering standards, but policy-makers eye growth – they face a difficult dilemma
Competitiveness mandate for Esma faces uphill battle
European Parliament offers last chance to force Esma to take more nuanced approach
Europe expects FRTB to bite on XVA hedges
Risk Benchmarking: One-third of European dealers fear new market risk rules will have major effect on hedges
Burning ambition: will Europe join the US in setting fire to the rules?
As the US dismantles post-crisis regulations, some think Europe will follow in a bid to boost economic growth
Can US perpetual futures solve their identity crisis?
Market could fall under four different regulatory categories, with sharply diverging outcomes
Banks want AML data upgrade to complement US regulatory reform
FinCEN’s proposed overhaul sparks debate on whether it will lead to smarter or weaker supervision