Hollow promises

Frances Coppola regularly offers detailed and useful analysis on exactly what is wrong with some of the claims made by crypto banks. I flagged one of her posts published last November and her latest post “Hollow Promises”continues to offer useful insights into the way traditional banking concepts like deposits, liquidity and solvency get mangled.

Well worth reading.

Tony – From the Outside

“From the Outside” takes stock

This is possibly a bit self indulgent but “From The Outside” is fast approaching the 5th anniversary of its first post so I thought it was time to look back on the ground covered and more importantly what resonated with the people who read what I write.

The blog as originally conceived was intended to explore some big picture questions such as the ways in which banks are different from other companies and the implications this has for thinking about questions like their cost of equity, optimal capital structure, risk appetite, risk culture and the need for prudential regulation. The particular expertise (bias? perspective?) I brought to these questions was that of a bank capital manager, with some experience in the Internal Capital Adequacy Assessment Process (ICAAP) applicable to a large Australian bank and a familiarity with a range of associated issues such as risk measurement (credit, market, operational, interest rate etc), risk appetite, risk culture, funds transfer pricing and economic capital allocation.

Over the close to 5 years that the blog has been operational, something in excess of 200 posts have been published. The readership is pretty limited (196 followers in total) but hopefully that makes you feel special and part of a real in crowd of true believers in the importance of understanding the questions posed above. Page views have continued to grow year on year to reach 9,278 for 2022 with 5,531individual visits.

The most popular post was one titled “Milton Friedman’s doctrine of the social responsibility of business” in which I attempted to summarise Friedman’s famous essay “The Social Responsibility of Business is to Increase its Profits” first published in September 1970. I was of course familiar with Friedman’s doctrine but only second hand via reading what other people said he said and what they thought about their framing of his argument. You can judge for yourself, but my post attempts to simply summarise his doctrine with a minimum of my own commentary. It did not get as much attention but I also did a post flagging what I thought was a reasonably balanced assessment of the pros and cons of Friedman’s argument written by Luigi Zingales.

The second most popular post was one titled “How banks differ from other companies. This post built on an earlier one titled “Are banks a special kind of company …” which attempted to respond to some of the contra arguments made by Anat Admati and Martin Hellwig. Both posts were based around three distinctive features that I argued make banks different and perhaps “special” …

  • The way in which net new lending by banks can create new bank deposits which in turn are treated as a form of money in the financial system (i.e. one of the unique things banks do is create a form of money);
  • The reality that a large bank cannot be allowed to fail in the conventional way (i.e. bankruptcy followed by reorganisation or liquidation) that other companies and even countries can (and frequently do); and
  • The extent to which bank losses seem to follow a power law distribution and what this means for measuring the expected loss of a bank across the credit cycle.

The third most popular post was titled “What does the “economic perspective” add to can ICAAP and this to be frank this was a surprise. I honestly thought no one would read it but what do I know. The post was written in response to a report the European Central Bank (ECB) put out in August 2020 on ICAAP practices it had observed amongst the banks it supervised. What I found surprising in the ECB report was what seemed to me to be an over reliance on what economic capital models could contribute to the ICAAP.

It was not the ECB’s expectation that economic capital should play a role that bothered me but more a seeming lack of awareness of the limitations of these models in providing the kinds of insights the ECB was expecting to see more of and a lack of focus on the broader topic of radical uncertainty and how an ICAAP should respond to a world populated by unknown unknowns. It was pleasing that a related post I did on John Kay and Mervyn King’s book “Radical Uncertainty : Decision Making for an Unknowable Future” also figured highly in reader interest.

Over the past year I have strayed from my area of expertise to explore what is happening in the crypto world. None of my posts have achieved wide readership but that is perfectly OK because I am not a crypto expert. I have been fascinated however by the claims that crypto can and will disrupt the traditional banking model. I have attempted to remain open to the possibility that I am missing something but remain sceptical about the more radical claims the crypto true believers assert. There are a lot of fellow sceptics that I read but if I was going to recommend one article that offers a good overview of the crypto story to date it would be the one by Matt Levine published in the 31 October 2022 edition of Bloomberg Businessweek.

I am hoping to return to my bank capital roots in 2023 to explore the latest instalment of what it means for an Australian bank to be “Unquestionably Strong” but I fear that crypto will continue to feature as well.

Thank you to all who find the blog of interest – as always let me know what I missing.

Tony – From the Outside

After FTX: Explaining the Difference Between Liquidity and Insolvency

Sam Bankman-Fried continues to argue that FTX was solvent. No one is buying this of course but Frances Coppola offers a useful reminder on the difference between illiquidity and insolvency. If you take only one thing away from her article it is to understand the way in which the accounting definition of insolvency can contribute to the confusion.

The confusion between liquidity and solvency is partly caused by the generally accepted definition of “insolvency,” which is “unable to meet obligations as they fall due.” This sounds very much like shortage of cash, i.e., a liquidity crisis. But shortage of cash isn’t necessarily insolvency.

When Frances uses the term “generally accepted) I think she is alluding to Generally Accepted Accounting Principles. I have had the liquidity versus solvency debate more times than I can count and this issue was often the core source of confusion when trying to explain the concepts to people without a Treasury or markets background.

If you want to dig deeper into the solvency versus liquidity question I had a go at the issue here. Matt Levine also had a good column on the topic.

Tony – From the Outside

Impact of oligopoly on bank margins

Intuitively you might expect a more open market to yield lower net interest margins. This post by JP Koning comparing Canada and America suggests that is not always the case.

His post is not long but the short extract below captures the main observation…

It’s true that we have an incredibly concentrated banking sector up here in Canada, with the big 5 controlling an outsized chunk of the market. Paradoxically, this “oligopoly” doesn’t translate into higher net interest margins for Canadian banks. Margins are actually more elevated in the the hotbed of capitalism, the U.S., even though its banks are far more diffused. This margin difference suggests that competition among banks is more strident north of the border than south of it.

Are U.S. banks more competitive than Canadian banks? Moneyness JP Koning, 13 December 2022

Would be interested to read any insights on why this is so. For what it is worth …

  • I wonder how much differences in business mix explain the difference in margin. I am not an expert on Canadian banks but my guess is that they have a lot more housing loan exposure than their American counterparts.
  • It would also be interesting to see how much of the margin difference translated into a higher or lower return on equity.

Tony – From the Outside

A short history of credit card design choices

One for the banking and payment nerds I suspect but I at least found this discussion of some of the design choices associated with our card payment system to be well worth reading for a perspective on how the choices baked into the system were made and how cards adapted to the proliferation of increasingly online business models


Tony – From The Outside

Moneyness: Let’s stop regulating crypto exchanges like Western Union

J.P. Koning offers an interesting contribution to the crypto regulation debate focussing on the problem with using money transmitter licences to manage businesses which are very different to the ones the framework was designed for …

The collapse of cryptocurrency exchange FTX has been gut-wrenching for its customers, not only those who used its flagship offshore exchange in the Bahamas but also U.S. customers of Chicago-based FTX US.

But there is a silver lining to the FTX debacle. It may put an end to the way that cryptocurrency exchanges are regulated – or, more accurately, misregulated – in the U.S.

U.S.-based cryptocurrency exchanges including Coinbase, FTX US, and Bianca.US are overseen on a state-by-state basis as money transmitters.

— Read on jpkoning.blogspot.com/2022/11/lets-stop-regulating-crypto-exchanges.html

Tony – From the Outside

Using the term “deposit” is a red flag

True believers may want to dispute her headline (“The entire crypto ecosystem is a ponzi”) but this post by Frances Coppola I think clearly illustrates the reasons why the term “deposit” should never be applied to anything associated with a crypto application.

Tony – From the Outside

Matt Levine on the FTX balance sheet

There is obviously a lot being written about FTX at the moment but Matt Levine continues to be my favourite source of insight in a very complex and confusing corner of the market.

Matt’s latest Money Stuff column, titled “FTX’s Balance Sheet Was Bad”, is I think worth reading to get an understanding of just how bad it seems to be. The link above might be behind the Bloomberg paywall but you can access Matt’s column by signing up to his daily email. The FTT token has been getting a lot of the press to date but this is first place I have encountered a discussion of the role of Serum in this sorry mess …

And then the basic question is, how bad is the mismatch. Like, $16 billion of dollar liabilities and $16 billion of liquid dollar-denominated assets? Sure, great. $16 billion of dollar liabilities and $16 billion worth of Bitcoin assets? Not ideal, incredibly risky, but in some broad sense understandable. $16 billion of dollar liabilities and assets consisting entirely of some magic beans that you bought in the market for $16 billion? Very bad. $16 billion of dollar liabilities and assets consisting mostly of some magic beans that you invented yourself and acquired for zero dollars? WHAT? Never mind the valuation of the beans; where did the money go? What happened to the $16 billion? Spending $5 billion of customer money on Serum would have been horrible, but FTX didn’t do that, and couldn’t have, because there wasn’t $5 billion of Serum available to buy. FTX shot its customer money into some still-unexplained reaches of the astral plane and was like “well we do have $5 billion of this Serum token we made up, that’s something?” No it isn’t!

Matt also draws on a now-infamous April 2022 episode of Bloomberg’s Odd Lots podcast in which he asked Sam Bankman-Fried a question about yield farming, and in the course of his answer SBF said:

You start with a company that builds a box and in practice this box, they probably dress it up to look like a life-changing, you know, world-altering protocol that’s gonna replace all the big banks in 38 days or whatever. Maybe for now actually ignore what it does or pretend it does literally nothing. It’s just a box. So what this protocol is, it’s called ‘Protocol X,’ it’s a box, and you take a token. …

So you’ve got this box and it’s kind of dumb, but like what’s the end game, right? This box is worth zero obviously. … But on the other hand, if everyone kind of now thinks that this box token is worth about a billion dollar market cap, that’s what people are pricing it at and sort of has that market cap. Everyone’s gonna mark to market. In fact, you can even finance this, right? You put X token in a borrow lending protocol and borrow dollars with it. If you think it’s worth like less than two thirds of that, you could even just like put some in there, take the dollars out. Never, you know, give the dollars back. You just get liquidated eventually. And it is sort of like real monetizable stuff in some senses.

Tony – From the Outside

Bank risk culture

APRA today released the results of a survey of how Australian ADI’s (i.e. “banks” for anyone reading outside Australia) believe they are doing on the question of risk culture.

What I found most interesting was the gap between what the executives believe and what the people on the front line believe as reflected in these two charts

Figure 5. Psychological safety – Management vs Individual Contributors
Figure 8: Decision-making effectiveness – Executives vs Individual Contributors

Creating an environment in which people truely feel safe to speak up is hard but it does appear that there is a lot more work to do. The first book that comes to mind when I read about risk culture is Creativity, Inc which explores (amongst other things) how Pixar institutionalised “Candour” into the business. Michael Mauboussin’s “The Success Equation” and Greg Ip’s “Foolproof” are also useful guides for avoiding hubris and general overconfidence in your risk management process.

I have to say that the challenge of speaking up is one that resonates with me from my time in the front line and it appears that there is still more to do. Personally I quite liked Pixar’s “brains trust” solution.

Tony – From the Outside

Solvency, liquidity and dark magic

The two terms are frequently used interchangeably but I am in the camp that being pedantic is useful in this particular case. In that context hat tip to Matt Levin at Bloomberg for another well worth reading opinion column exploring what is going on with FTX

You can find his column here. There is a Bloomberg paywall but you can also access Matt’s material by signing up to his daily newsletter (highly recommended). The whole piece is worth reading but two short extracts below capture the main points.

First up solvency …

One other point here is that if this is the story, then it is not a liquidity crisis but a solvency one. That is, the problem is not a timing mismatch, in which FTX’s customers asked for their cash back but FTX did not have enough ready cash because it had long-term but money-good loans out. The problem is that FTX took its customers’ money and traded it for a pile of magic beans, and now the beans are worthless and there’s a huge hole in the balance sheet.

And some dark magic …

If you think of the token as “more or less stock,” and you think of a crypto exchange as a securities broker-dealer, this is completely insane. If you go to an investment bank and say “lend me $1 billion, and I will post $2 billion of your stock as collateral,” you are messing with very dark magic and they will say no.[9] The problem with this is that it is wrong-way risk. (It is also, at least sometimes, illegal.) If people start to worry about the investment bank’s financial health, its stock will go down, which means that its collateral will be less valuable, which means that its financial health will get worse, which means that its stock will go down, etc. It is a death spiral. In general it should not be possible to bankrupt an investment bank by shorting its stock. If one of the bank’s main assets is its own stock — is a leveraged bet on its own stock — then it is easy to bankrupt it by shorting its stock.

If you want to dig deeper into the solvency versus liquidity question I had a go at the issue here

Tony – From the Outside