Showing posts with label mark to market. Show all posts
Showing posts with label mark to market. Show all posts

Thursday, September 1, 2011

Just How Bad Off Are the Banks?


Here we are, how many years after the start of the financial crisis, and we still have questions about the status of individual banks and the banking system…in both the United States and Europe.

European banks have gone through two “stress” tests.  The United States banks have gone through their own “stress” tests.  And, still, there are questions about the solvency of individual banks and the banking system. 

Christine Lagarde, Managing Director of the International Monetary Fund, received all sorts of criticism from the remarks she made last Saturday concerning the status of the European banks and the fact that they “need urgent recapitalization.” 

Early this week we read about how various European banks are writing down the values of the distressed Greek government debt they hold.  Some banks are taking have taken a 50 percent write down while others have taken haircuts of slightly more than 20 percent.  There are no standards for taking such write downs leaving each bank to follow its own path. (http://professional.wsj.com/article/SB10001424053111904199404576540291609289616.html?mod=ITP_moneyandinvesting_2&mg=reno-secaucus-wsj)

American banks are not coming off much better.  One looks at the discounts being assessed against US banks in the stock market and the legal efforts that they face and one wonders what is real.   Are these banks really solvent?

Bank of America has become the poster-child of the mismanaged large banks in the United States.  Warren Buffett brought it some relief with his “pussy-cat” deal.  Yes, Mr. Buffett can say that he (and other wealthy people) should pay more taxes as he cuts such sweet deals with such nice tax benefits for himself.  Yet, some are taking the Buffet bailout of Bank of America as a signal that maybe a closer look needs to be given the position of Bank of America. (http://dealbook.nytimes.com/2011/08/31/buffett-investment-could-erode-confidence-in-wall-st/)

Just look at some of the numbers.  Bank of America has  stated that slightly less than 20 percent of its residential mortgage loans as either delinquent or nonperforming, a rate that is similar to that of Wells Fargo.  JPMorgan Chase has about 24 percent falling in this class while the fourth of the big four, Citigroup, has less than 14 percent. 

And, “Not only does the bank still face billions in legal settlement costs from Countrywide Financial deals, but it also has to buy back billions in faulty mortgages.  Bank of America’s questionable foreclosure practices continue to drag it down, and, in addition, it faces Securities and Exchange Commission investigations into the actions of its subsidiary, Merrill Lynch, in the lead-up to the financial crisis.”

In addition, bank profits are falling (http://www.nytimes.com/2011/08/29/business/top-banks-confront-leaner-future-by-cutting-jobs.html?_r=1&scp=1&sq=profits%20falling,%20banks%20confront%20a%20leaner%20future&st=cse) and with the Fed promise that it will keep interest rates low for the next two years, bank interest rate margins and, hence, bank profits can be expected to remain squeezed for the near term. 

And, why is the Federal Reserve keeping interest rates so low for the next twenty-four months?

One reason for keeping interest rates so low is that the Fed will continue to provide the banking system with substantial liquidity so that banks can work themselves out of their bad loan situation and that failing banks can be removed from the banking system with the least disruption possible.

Furthermore, commercial banks in both Europe and the United States are cutting back on their employment by not just thousands of people, but tens of thousands of people when all the layoffs are added together.   

We look at all this information and we wonder, “Just how bad off are the banks?”  The regulators have been working on this situation for at least three years.  And, we still have all these questions?

The only conclusion one can draw from this is that the regulators and the people “in the know” did not want us to know how bad things were.  And, they still are reluctant to let any of this information out.  Notice how upset people got when Ms. Lagarde let the “cat-out-of-the-bag” on Saturday.

So much of this dilemma goes back to the discussion about the need for financial institutions to mark their assets to market.

I know how hard this is to do in the case of some assets without active markets.  And, I know how painful this is to do “after-the-fact”, that is, after the asset values drop underwater.

But, this is a lame excuse that has been allowed to go on for too long!

If banks take risky bets on interest rate movements, they should only do so with the knowledge that if the markets move against them they will have to pay a price by marking the assets to market.  I also don’t buy the argument that they will hold the assets to maturity.  If the banks “place the bet” they must pay the consequences.

Same thing with risky assets: as banks take on more and more risky loans in an effort to “beef-up” their return on capital they are overtly exposing the bank.  Again, when the assets go south the banks need to own up to the bets they placed. 

And, if these mark-to-market efforts are done on a more timely basis then the banks will have to move to correct their asset problems earlier and they will not get into the deep “doo-doo” they now find themselves in.

Sooner or later these bank problems are going to have to be taken care of.  Stringing things out as the regulators and politicians have done only postpones the day we can move off into the future.  It is a prerequisite for finally achieving more robust economic growth. 

The fact that the problems we continue to read about still exist three years after the financial collapse took place only raises further questions and continues to add uncertainty to the economic climate.  No wonder that people are so risk averse today and only want to buy US Treasury securities or gold. (http://seekingalpha.com/article/290934-struggling-with-a-great-contraction)   

Saturday, August 13, 2011

Response to "The Future of Banking" Comments


In response to two comments on my recent “Future of Banking” post (http://seekingalpha.com/article/287037-the-future-of-banking-looks-grim-again) I would like to make the following additions.

First, in terms of the number of employees in banks, I truly believe that the existing model of commercial banking is “legacy” and is in the process of changing.  The comment was made, for example, that “Until customers don't want to come into bank branches anymore, you will have to retain that model.”

In the past five years, I don’t believe that I have been in a bank branch in which there were more than three customers (including myself) at any one time.  And the branches are of similar size to the ones in which I was a teller back in the 1960s. 

I remember those days.  On a Saturday morning when the branch opened at 9:00 AM we would have eight tellers working eight tellers windows and lines of 10 to 15 people at each window constantly until 1:00 PM when the branch closed.  The weekdays were not so busy, but there was always a constant flow of customers through the banks.

I do not know exactly what the future of banking is going to be, but I am working on it as I write.  I have studied, written about, helped start up companies and worked with early stage companies in the area of information technology.  I am on the board of a newly formed bank and am in the process of starting up a credit union.  The use of information technology is constantly on my mind with respect to its application to the finance area. 

Everything I know and have experienced indicates that banking and finance is going through a quantum leap and, over the next ten years, will evolve into something we may not recognize as banking and finance, given the models we work with today.

In teaching classes in information science, I suggested two places for the students to look for ideas about what the future would be like.  First, I said, look at what the military is doing.  They must be ahead of everyone else in their ability to keep secrets and to fight wars (kill people).  They must have the most advanced technology.  Second, I said, look at what the young people are doing the kids in the 8 to 14 age bracket.  What is ubiquitous to them will be “standard” in five to eight years. 

If your business does not take these two things into account in your operations then you will probably not be around to enjoy this future.

I know young people that have not been inside a bank or the branch of a bank for at least five years.  I seriously doubt that my grandchildren will see the inside of a bank or the branch of a bank more that just a few times in their life. 

Finance is information…and nothing more.  Hence, how information is stored, processed, and used will dominate the practice of finance. 

I hope I find out what the future of banking is going to be before others do. 

Whatever it will be, it will not be as people intensive as it is now.

The second comment had to do with “mark to market” accounting.  The comment correctly indicates that many bank assets are probably over valued and this fact will come to light in the future indicating that many banks are in worse shape in terms of capital than we presented think they are.

The comment concludes: “I have seen very few people focus on this in what I have read over the past 3 years, yet I think what I have spelled out here is a potentially looming 'largely unrecognized' further problem. “

I agree with this analysis but would add that over the past three years I have constantly argued in my posts  (you can look them up on Seeking Alpha) that the commercial banking industry needs to go to a accounting system that does a better job of “marking “ assets to market.  This, to me, is essential for the finance industry to be “open” and “transparent”.

In terms of my recent post, I just did not have time to get into this issue.  Of course, adding this issues to the other two does not make the future of banking look any rosier.

Thursday, August 20, 2009

Bank Asset Values are a Lingering Problem

Is the recession over? Has the economic recovery begun? Will there be a double-dip recession?
The picture is fuzzy and one reason the picture is fuzzy is because so many banks and other financial institutions, investors, and regulators either don’t seem to have a good grasp of the value of many of the assets on the balance sheets of these banks and other financial institutions or because they are unwilling to confess what the asset values are.

Look at some of the recent articles that have been in the news this week. “Insurers’ Biggest Writedowns May be yet to Come” by Jonathan Weil, http://www.bloomberg.com/apps/news?pid=20601039&sid=a8itsmbfm9qc. “Disclose the Fair Value of Complex Securities” by Robert Kaplan, Robert Merton and Scott Richard, http://www.ft.com/cms/s/0/7eb082d6-8b8e-11de-9f50-00144feabdc0.html. “Citigroup’s Asset Guarantees to be Audited by TARP” by Bradley Keoun and Mark Pittman, http://www.bloomberg.com/apps/news?pid=newsarchive&sid=aiWZXE5RKSCc. “We Need Daily Data to Get Credit Markets Working Again” by Richard Field, http://www.ft.com/cms/s/0/8a9f2906-8d20-11de-a540-00144feabdc0.html.

All of these articles have to do with financial institutions knowing and reporting, as well as possible and as often as possible, the current value of their assets. The managements of financial institutions claim that this will inhibit their actions and force them into decisions that are not in the best interest of their institutions or the financial markets. These managements are wrong!

We are hung up right now because we don’t know the value of those assets either because the banks don’t know what the value of those assets are or the banks are not revealing what the value of those assets are.

I believe that we would face less uncertainty now and may have even avoided a good deal of the financial collapse of the last two years if these financial institutions would have been required to regularly report the fair value of their assets and responded more rapidly to changing market conditions.

Even better, it would have been a sign of outstanding management and real leadership if the banks themselves had been more open and transparent with the financial community, rather than require regulation to force them to release this information.

Alas, this didn’t happen.

This whole dilemma, to me, comes under the “No Free Lunch” argument.

Bankers mismatch the maturities of their assets and liabilities and take advantage of the positive slope to the yield curve. But, in doing so they take on more interest rate risk. Financial markets move against them and the price of the longer term assets decline. Whoops! The benefit the bank got by taking on the extra interest rate risk has backfired. Well, nothing comes for free!

Bankers add riskier loans to their loan portfolio or buy riskier securities to increase their yield. But, in so doing they take on more credit risk. The economy slows down and now these loans or securities face a larger default rate than the bankers had anticipated. Whoops! The benefit the bank got by taking on the extra credit risk has backfired. Well, nothing comes for free!

Financial institutions leverage up their balance sheets in order to squeeze out additional return on their equity position. But, in so doing they take on more financial risk. As assets prices go down the increased leverage backfires and their solvency comes into question. Whoops!

Bankers can’t get something for nothing. And, they can’t hide behind accounting rules in an effort to wait things out until times get better. As Kaplan, Merton, and Richard argue, banks typically fail to act when markets move against the risky positions they have taken and chalk the situation up to “unusual market conditions” or to “just a bump in the road”. And, if economic declines are relatively short and relatively shallow maybe they can get away with waiting the problem assets out. But, in deeper and longer periods of economic and financial dislocation they get trapped in their own failure to act. The asset values do not return to previous levels and the longer they wait to act on the existing problems the worse the situation on their balance sheet becomes.

Richard Field argues, in the article cited above, that banking and credit markets are having problems, not because the loans and securities on the books of the financial institutions are complex, but because they are opaque. This lack of clarity has helped to get us into the current crises and will continue to plague the recovery if it is not corrected. This lack of clarity allows bankers to continue to postpone action, it prevents investors from knowing the value of their investments, and it hinders regulators from in their efforts to understand the true condition of the financial institutions they are regulating.

As I have mentioned in previous posts, I have been involved in several successful bank turnarounds. One of the first things you have to do in turning around a bank is determine the value of your assets and you have to be brutally honest about what the values are. And, in going through this process, in every turnaround I was involved in, it becomes clear that the previous management failed to accept the fact that the value of their assets had declined, they continued to hope that the “unusual market conditions” would pass, and, consequently, by failing to act, the condition of the assets got worse and worse.

Good managements are not afraid of the truth and they are not afraid of releasing that information to the public!

Unfortunately, it is likely that the opaqueness with regard to the value of bank assets will continue.

Thursday, August 6, 2009

Bank of America and the Appointment of Sallie Krawcheck

This continues to be a trying time for the finance industry. Articles like the one that appeared this morning in the Wall Street Journal just do no good for the stature of those who admit to working in finance in one way or another. The article I am referring to is “Behind BofA’s Silence on Merrill,” http://online.wsj.com/article/SB124952686109510009.html.

The problem is one similar to that described by John Plender, the Chairman of Quintain PLC, in the Financial Times yesterday, “Ditch Theory and Take Away the Punchbowl,” http://www.ft.com/cms/s/0/e8b88624-8107-11de-92e7-00144feabdc0.html. Plender presents the folksy strategy for central banking ascribed to William McChesney Martin, former Chairman of the Board of Governors of the Federal Reserve System. Martin is reported to have said that the task of a central banker was to take away the punchbowl before the party got out of hand.

To me, the role a financial officer, especially a Chief Financial Officer, is similar. A financial officer ultimately must be the naysayer in an organization. If the financial officer does not act out this role in an organization then the Chief Executive Officer is not going to be well served by the finance function and the organization is going to be exposed as it grows and considers alternative business options!

No one else in the organization performs this function. A “good” Chief Executive Officer wants a strong person in this position because without someone there to say “no” from time-to-time, the CEO will be like the emperor that is wearing no clothes. A “good” CEO knows this. One thing I look for in evaluating a management team is the strength of the people a CEO surrounds him- or herself with, especially the strength of the CFO.

A strong Chief Financial Officer knows that there is no such thing as a free lunch. That is, when it comes to finance, you never get something for nothing. If you want a greater return on your assets, you can take on riskier assets, or you can increase you financial leverage which, of course, increases risk, or you can mismatch the maturities of your assets and liabilities which, of course, increases risk. Of course, we can extend the idea of “no free lunch” to proposals coming from marketing, or information processing, or purchasing as well, but I am sticking with financial issues because that is where the concern is today.

In the euphoria of the credit bubbles that took place in the 1990s and the 2000s, CFOs and other finance people that believed that there was “no fee lunch” and acted upon this belief seem to have fallen out of favor with CEOs seeking to make bundles of money in the bubbles. Of course, not everyone acted in this way but a significant number did and we are all paying the price for this today.

When one sees articles like the one in the Wall Street Journal mentioned above, you can understand why people on Main Street and why Senators and Representatives in Congress can pick on bankers and others who are in the finance profession. It certainly seems as if a trust was broken and greed ruled the kingdom.

The hiring of Sallie Krawcheck by BofA is, therefore, a hint that maybe BofA understands that it needs to build up its credibility. Krawcheck has a reputation for openness and integrity that has stayed with her throughout her career. The argument is that this trait got her in trouble with the CEO of Citigroup, Vikram Pandit, and cost her the position of CFO which she held at Citi. Taking over responsibility for BofAs global wealth and investment management business in not the same as becoming CFO of the institution, but it indicates that BofA is pulling in someone that is not only talented and capable in finance, but also will add some credibility to the organization in terms of honesty and transparency.

One can learn a lot about leaders and the organizations they lead by observing how they respond to people that possess these qualities, especially in times of trouble. Citigroup seems to have a history of releasing top people that question how financial affairs are being handled. Richard Bookstaber comments on how Citi operated in the area of risk management in his book “A Demon of Our Own Design”. We also see that Jamie Dimon was asked to leave Citi when he began to clash with the leadership of that organization on issues of risk and management. (See my review of a book about Dimon: http://seekingalpha.com/article/148179-book-review-the-house-of-dimon-by-patricia-crisafulli.) It seems as if Citigroup worked hard and long to get itself into the position it is now in.

Of course, BOA and Citi are not isolated cases. One can name any number of organizations from Bear Sterns to Lehman Brothers to AIG to Wachovia to Countrywide to so and so and on and on. The depth and breadth of the problem just indicates how far the finance profession has lost credibility.

That is why I would advise at this time that investors look even more closely at the people, especially the finance people, that the leadership of an organization brings on board. Strong financial leadership is needed within an organization, leadership that stresses telling the truth, reporting asset values at realistic levels, and leadership that rejects accounting rules that only muddle if not mislead investors and regulators.

In this regard I would argue that we have to get back to mark-to-market accounting. To me, people only kid themselves when they finance long term assets with short term liabilities in order to capture additional return and cry and whine when they have to mark down the values of their longer term assets if the market goes against them. They are brave enough to gamble on this mismatch of maturities. They also need to be brave enough to accept the consequences of their actions. There is no free lunch!

In my experience there is one thing that financial integrity does: it causes people to act earlier than they would otherwise. The situation I saw over and over again in doing bank turnarounds was that people postponed doing anything about a bad position because they were not forced to recognize a problem early on. As a consequence they put off doing something about the bad situation and put it off until the problem grew into a much larger problem where they could not postpone action any longer. Good management recognizes problems and deals with them early on.

Hopefully, the hiring of Sallie Krawcheck is a sign that organizations are recognizing the need for strong financial leadership. Then, in hiring more people like her, maybe emperors won’t have to go out into crowds to discover that they don’t have any clothes on. The absence of clothes will have been discovered long before then and the situation will have been corrected.

Sunday, March 1, 2009

Uncertain Asset Values and the Stock Market

“Value investors prefer to estimate the intrinsic value of a company by looking first at the assets and then at the current earnings power of a company.” This comes from the book “Value Investing: From Graham to Buffett and Beyond” by Greenwald, Kahn, Sonkin, and van Biema.

In value investing, the value of the assets is the first thing you should look at. Value, however, is uncertain and decisions about value are risky…that is, placing a bet on the value of an asset is a risky decision…and this throws us into a probabilistic world.

But uncertainty comes in different flavors. For example, in some situations we have a relatively good idea about what the underlying outcome distribution looks like. Games of chance like roulette or blackjack have uncertain outcomes but the probability distribution of possible outcomes is well known. On the other hand, the possible outcomes of a war are uncertain and we generally have very little knowledge of the probability distribution of possible outcomes. So at one end of the spectrum of uncertain situations we can say that our estimated probability is objectively determined, while at the other end we have to admit that our estimated probability distribution is entirely subjective.

The United States is at war right now…at war against an economic and financial crises. And, investors, as well as everyone else, have no idea what the probability distribution of possible outcomes looks like. We can’t even approximate such a distribution from historical statistics because there is insufficient information to produce any kind of a result that would be relevant in the current situation. The information that we are getting seems to be getting worse and worse.

This, to me, is why financial markets are performing as they are at the present time. No one can state with any certainty the values relating to the vast majority of assets in the United States.

Until people can gain some confidence that they know…even approximately…what is the value of assets relevant to them…they will not be willing to place substantial “bets” with much confidence. And, this will mean that financial markets will continue to meander lower.

One effort to get a handle on asset values is the “stress test” exercise of the Federal Government on large commercial banks. The effort is, of course, to see whether or not the asset values of these banks will hold up in a relatively severe economic downturn. The outcome of these stress tests will determine, to a large degree, the amount of financial help these institutions will get from the Treasury Department.

The problem is that the whole economy needs to face a stress test. It is not altogether clear that even the people running a large part of this economy have any idea about the value of their own assets. This is scary!

We have heard over and over again in the past year that one factor that has “caused” or at least “exacerbated” the current crisis is accounting rules such as the “mark to market” requirement faced by many institutions. I think that this is nonsense!

The problem, to me, is that there has been too little information forthcoming from the businesses and financial institutions in this country. I contend that the only reason the “mark to market” requirement might have caused organizations any trouble is that the managements of these companies believed that they would never be held to live up to this standard.

The “mark to market” requirement is meant to warn managements that their decisions with respect to asset choices will have consequences on their balance sheets and this will be revealed to the investment community in real time. Therefore, Mr. Management, if you want to invest in riskier assets or mis-match the maturities of your assets and liabilities in order to increase your return on equity, you will have to account for them “up front” if your decisions sour.

Knowing this to be the case, why would these managements go ahead and assume riskier positions unless they believed that the accounting rules would not be enforced?

Another bad argument to me is the one used by Long Term Capital Management in terms of the portfolio positions they took…”We can’t release information on our positions because of the fact that if we did our competitors would know what we are doing and copy us.”

Well, guess what? Their competitors knew what positions they were taking and copied them. And, the spreads Long Term Capital Management worked with got narrower and narrower…and so LTCM needed to use more and more leverage to get the returns they were shooting for…and trouble developed…and who knew about it? Not their banks…not their investors…not the regulators…no one but them. And, we ended up with another crisis.

And, this goes back even further. I am reading a book about Goldman Sachs. One situation stands out…the financial crisis created by the Penn Central bankruptcy in the early 1970s. The Penn Central hid information about its financial problems from Goldman Sachs, as well as others in the financial community, which resulted in a collapse of the commercial paper market leading to a Federal Reserve rescue and millions and millions of dollars in losses as well as an enormous amount of time in law suits and other regulatory assessments.

In doing bank turnarounds I found out very quickly in each bank I was involved in that the first thing an organization does when their decisions start going south is that they attempt to “cover up” results. One of the first things needed in any turnaround situation is to open up the books and let the fresh air in. It always seemed to me that greater openness and transparency of reporting results would have reduced the number of bank problems and bank failures that took place in this country.

Many argue that if people knew the trouble that banks had gotten themselves into there would be more “runs” on banks and the system would be less stable. This is an argument “after the fact” much as is the argument about “marking to market.” If the information were available earlier to the public and the investment community, there would be pressure on managements to respond quicker to bad decisions and resolve them before they got out-of-hand. Allowing the managements to delay action on these issues only exacerbates the problem, for it does not force the managements to solve them.

If there are to be any regulatory changes…and I am afraid that there will be way too many of them in our future…I would argue that the most important one would be related to the reporting requirements of all businesses in the United States. The records of American businesses…non-financial as well as financial…need to be more timely and more open and transparent to the world.

The investment community and the regulatory community should never be in a position where there is such uncertainty about asset values as there is at this time! We have the computer systems to accommodate a requirement to be more open and transparent…there is no reason why more information should not be forthcoming on a real time basis.

The stock market…as well as other financial markets…will continue to move lower as long as the uncertainty exists about asset values. A government “recovery program,” a plan to ease the burden of foreclosures, and even a bank bailout plan, will not stimulate bank lending and move the economy out of recession until we get a handle on asset values…throughout the whole economy. Valuing assets will take time…and even more time will be required to work out the associated solvency issues. But, even now, greater openness and transparency would help speed this process along. And, maybe give investors enough confidence to start buying again

Sunday, February 15, 2009

Stree Testing the Banks, Bank Regulation, and Bank Failures

It is obvious from my recent posts that the amount of debt in the economy is my biggest concern right now. Of course, the focus of current concern is the banking industry. Bankers got caught up in the euphoria of the stock market bubble of the 1990s and the credit market (housing) bubble of the 2000s and showed the way to others about how to take on riskier and riskier assets and finance these assets with more and more debt. Off-balance sheet financing and virtual deals added to the fragile structure of the banking system as innovation built upon innovation.

I will not place all the responsibility for not catching everything that was going on, on the shoulders of the regulators because one of the things that a market system is very good at is finding ways to get around regulations and regulators. This is one of the reasons why regulation will always fail in the end…it just cannot keep up with what private institutions can find to do…and so regulation is always lagging behind in its ability to know what is going on in financial institutions and financial markets.

Let me just say that I have served in the Federal Reserve System and I have been the CEO of two publically traded financial institutions and CFO of a third, and, although the banks I worked with did not have the resources to be innovative in this way…my knowledge of the banking industry leads me to applaud the ingenuity and creativity of bankers to come up with new instruments, new markets, and new ways to do things. Innovative behavior is the pride of a market economy.

The law of economics in irrefutable…if incentives exist within a given market situation…economic units will make an effort to take advantage of them. Thus, if rules and regulations are placed on a market or on institutions and incentives exist to get around these rules and regulations…people will get around them!

The effort is not to break laws…but rules and regulations are never complete in and of themselves…hence there will always be wiggle room for an organization to maneuver and take advantage of the incentives available to them. This is why regulation will never…read me again…never…be able to gain complete control. The only way to gain complete control over institutions and markets is…to totally take over and own the institutions and markets, themselves.

We must remember this as people in Washington, D. C. attempt to build up the new regulatory system.

That said…I think a lot of responsibility does fall on the shoulders of the regulators for falling so far behind the banking system in their examination and oversight of individual banks. There is a need for rules and regulations to be imposed on the banking system because of the problem…not of one or two banks failing…but the fear that there could be a contagion within the banking system that could severely damage the financial and economic system…either in terms of a liquidity crisis…which took place in December 2007…or a solvency crisis which we are going through right now.

A liquidity crisis and a solvency crisis are not the same and should not be compared with one another. A liquidity crisis the Federal Reserve System can do something about. A solvency crisis is beyond the ability of the Fed to resolve. However, the Federal Reserve and other regulatory bodies, through their responsibility for the examination and oversight of the banking system, can help to prevent a liquidity crisis by doing a deep and thorough review of the books of financial institutions and hold these financial institutions to the standards of “good” banking practice. This effort is a first line defense against a failure of banks that could lead to a contagion amongst financial institutions.

Now, Tim Geithner, Secretary of the Treasury, has informed us that a “stress test” will be performed upon banks to determine whether or not specific banks will be eligible for financial aid from the United States government. The “stress test” is to be broad enough and deep enough to discern if a bank is still breathing or not…and if it is breathing…it can be eligible to receive capital from the government in order to help it work out its asset problems.

My question is…shouldn’t the government already know this? Wasn’t this their job!

If we have to go through an additional examination process on a large number of banks to find out whether or not they are solvent…what have we been paying for over the past 20 years or so?

And, I hear the cry for “regulatory forbearance”…that the regulators should ease up on the bad assets of the banks…and give the banks a chance to “work things out over time.” I think this is crap!

I like “mark to market”! If banks know that they are going to be responsible for marking their assets to market then one should not feel sorry for them when they have underwater assets…and want “regulatory forbearance”. To me this situation has arisen because bankers never felt that regulators were going to hold them responsible for this procedure and so they went along believing full well that they would never have to mark their assts to market. Now, they are ticked off! Now, they believe that the regulators have double-crossed them! I say…too bad!

Finally, let me say that I believe that banks that are insolvent should be allowed to fail. The stock holders have lost everything. Others may have lost large chunks of wealth…but, the banks have been badly mismanaged. The banks took on too much risk and they assumed too much leverage. The executive at the larger ones took it for granted that they would be considered to be too big to fail…and their jobs would be safe.

I know that I have not run a bank with a trillion dollars or more in assets…or even hundreds of billions. Yet, in those I did run, I never wanted to have the regulators or central bankers or Treasury officials tell me what to do. My rule of thumb was to always maintain operating procedures that were more conservative than those that the regulators required. I wanted to be in control of the bank…I did not want someone else imposing their standards on me!

When you push yourself right up to the edge…and even over the edge…with financial innovations and creative accounting…you run the risk of losing control of your organization. If this is the way you want to lead and manage your organization…then you are exposing yourself to the possibility that you will lose control of the future of your organization. Don’t cry when the government comes and takes away your goodies. It was a choice that you made.

There are going to be more bank failures. We have only had 13 failures so far this year…possibility 18 or so by the end of this month. At this rate we would have about 110 failures during the year. Most of these will be small ones, although the probability of two or three or more large failures taking place is increasing every day. However, this is far below the 200 or so bank failures that took place during the S & L crises.

In the present case, there is a good chance that several banks will be “nationalized” in some form or another. In my mind, the worst thing that Secretary Geithner can do is to try and soften the situation. Debt is our problem right now…see my blog “The Three Problems We Face: Debt, Debt, and Debt” posted on February 11, 2009, http://maseportfolio.blogspot.com/ …and debt is going to be our problem for some time into the future. We need to be honest about the problem, transparent about what is being done about the problem, and we must be courageous in addressing the problem. To me this is the only hope we have in shortening the present downturn.