Irm Risk and The Financial Crisis Summer 2009
Irm Risk and The Financial Crisis Summer 2009
Irm Risk and The Financial Crisis Summer 2009
Pauline Bird
Summer 2009
IRM FOCUS – Papers on Risk The City of London is the greatest employer of science
and maths graduates in the country. How could it be that a 1
disaster with such far reaching impacts was not spotted and
Risk and the dealt with before it brought the global economy to its knees?
Financial Crisis Let’s examine the root of the problem. In order to expand their
businesses the lending institutions needed to find new markets
for mortgage lending. Two of those markets were buy-to-let
owners (a new animal) and people whose credit history was
As risk’s management leading international suspect or who were unable to share the lender’s risk in the
education and training body, the Institute of mortgage lending by putting down a deposit. In a market where
lenders became ever keener, it was possible to obtain what
Risk Management (IRM) asked its members
was (in effect) a loan of 125% of the purchase price, allowing
for their views on the causes of the current borrowers to buy a run down property and renovate it. The
financial crisis and lessons for the future. IRM second category was ‘sub-prime’ loans, a term which recognised
the more risky nature of the lending.
is delighted to publish the following four essays.
Each approaches the subject from a slightly The lenders recognised the risk in this lending, and removed the
risk from their balance sheets by bundling up the sub-prime and
different angle, but all of them shed light on how other high risk loans and selling them to a company created for
we got here and some ways forward. the purpose, the special investment vehicle or SIV. The shares
in that company were sold to investors, who received the right to
the income from the loans. This had the effect of removing the
risk in the loans from the lender’s balance sheet, and, even better,
Contents allowing the lender to take the full value of the loans over their
lifetime of several years in one financial year, which improved the
The Root of the Problem lender’s financial results.
Pauline Bird, BDO Stoy Hayward..................................p.1 So far, so good. But what then possessed the lenders to buy
other people’s risk? The lender creating a SIV would discount the
value of the loans for (in effect) early payment. So long as the
loans continued to perform, the buyer would be getting a greater
CAMPARI on the Rocks return on the loan than they had paid for it. These deals would
Andrew Chapman, Anglia Ruskin University. ........p.3 also appear on the investor’s balance sheet as an investment,
and could appear in the accounts as a transaction ‘marked to
market’ – that is the entire profit from the lifetime of the contract
could be recognised in one financial year, which again would
The Naughty Years improve the apparent results for the investor in that year.
Gerard Joyce, LinkResQ........................................................p.4
These techniques are based on a number of critical assumptions,
the first being that borrowers with an impaired credit history
would continue to repay their loans, and the second, that the
Three Opportunities for property market would only increase in value. It is now clear that
these assumptions were wholly or partially invalid.
Risk Management
Clive Thompson, Willis UK and Ireland....................p.6 The value of the deals depended partly on the strength of the
underlying asset – either the repayment of the debt as expected
or the rising value of properties that could be repossessed and
sold to cover any default. Where the borrower was unable to
service the debt, or where there was a shortfall between the
forced sale value of the property and the lending, the investor in
the SIV was left with a loss.
The Institute of Risk Management The organisations that have exposures to sub-prime debt
www.theirm.org have been very coy about revealing the extent to which they
[email protected] are exposed, although all of them understand the accounting
+44 (0) 20 7709 9808 techniques that have been used to generate results in the past.
None of them can trust that the others’ declared exposures are an
The Institute of Risk Management is risk management’s leading
international professional education and training body. The Institute accurate reflection of the true risk exposure, and therefore none of
provides high quality education, training and professional development in
risk management at a range of levels, from introductory to expert.
The Institute of Risk Management
them can risk lending to the others, which has resulted full value of a transaction that will produce results over
2 in a sudden drought in available credit with catastrophic
effects on business. Lenders whose business model
several years is fully accounted for in the first year and
there is considerable uncertainty about the actual (as
depended on the availability of cheap short-term finance opposed to the projected) outcome, reported results can
and the assumption that this would continue indefinitely be unduly flattering.
were in a very precarious position almost overnight.
What we can learn
Why did it happen? Before the current troubles, it was unthinkable that
Individuals are often driven more by their own interests old and respected City giants could fail, despite the
in a given situation than by the collective good of the collapse of Barings Bank in 1995. There has been
whole. The way that the City rewards its employees some suggestion that an answer to the current crisis
enforces this tendency, as a typical City reward system is to form a bank that is ‘too big to fail’. The collapse of
is based on a modest annual salary and an annual such giants as energy trader Enron and Barings should
bonus that may be a multiple of the salary depending on have weaned us off the idea that size is any predictor of
the organisation’s results. safety. If any organisation makes a sufficient number of
wrong calls it will collapse. The concept of ‘unthinkable’
It was in everybody’s interest in these organisations
is a very dangerous one.
that the annual results, as agreed by the auditors,
were as impressive as possible, hence the attraction The way that an organisation rewards its employees
of taking profits from loans in one financial year rather may have unintended consequences. If it is in the
than over the lifetime of the loan and making provision interest of individuals to find ways of portraying the
over time for defaults, which was possibly a more organisation’s results in a flattering light, they may do
prudent treatment. In fact, shortly after Swiss bank so if the personal rewards are great enough. Similarly,
UBS disclosed that it had some exposure to sub-prime it is important to understand what policies have been
lending in summer 2008, a commentator noted that applied in producing accounts, the implications of the
where the employees of an investment bank knew that policies and the potential distortions they introduce. A
a type of transaction would result in fat bonuses for four set of audited accounts is the product of some raw data
years and a crash in the fifth, the employees would take filtered through the organisation’s accounting policies
the fat bonuses – the crash would not be their problem. and subject to a number of opinions. It may appear that
everything in the garden is lovely, but some of the plants
The City is extremely aware of some risks, but possibly
may hide a snake.
insufficiently aware of others. For example, the
investment banks have extremely sophisticated software Risk culture is a very important safeguard against
for modelling market risk, but from the results that we collapse. This will be an interesting and on-going
now see, it appears that those who ultimately sanctioned challenge for the City. Is it acceptable to have an
the investment in the SIVs gave insufficient consideration approach to risk that gives great results for some years,
to the risk in the underlying asset. There has been some but puts the world economy to the sword as a result? Or
press commentary suggesting that risk management will it grasp the nettle and take a more holistic approach
departments were unhappy with the sub-prime deals, but to risk management? Probably, once the dust settles,
that the traders applied pressure to be allowed to make there will be calls for far stronger regulation. It is by no
markets in these products, and the traders won. means easy to see how regulation can be strengthened
effectively while still encouraging an appropriate level of
It is not an uncommon experience for risk managers
risk taking. The seeds of the next collapse are probably
to be over-ruled where it appears that there is a large
being sown in the technical department of a financial
profit to be made. If everything appears to be going
institution somewhere in the world at this very moment.
very well and large profits are being made, what
The problem is how to identify it?
could possibly go wrong? In these circumstances, risk
managers are regarded as party poopers, who would None of this is rocket science. Companies collapse
hamstring the organisation in its efforts to make money. for very prosaic reasons, and the reasons are often
The City is often seen as a young man’s environment very similar, irrespective of size. Some of the causes
– risk accepting and intolerant of nannying. Observers of failure of financial institutions are, in general terms,
have also noted a herd mentality – ‘everyone else eerily similar to that of Enron before them. It remains
is making money from this, why not us?’ The culture to be seen whether we will learn the lessons, or will we
prevalent in the City does not tend to encourage allow history to repeat itself?
excessive prudence.
The Financial Services Authority (FSA) is reported to be Pauline Bird MIRM is Senior Manager Business
unhappy about the way that mark to market accounting Restructuring Technical and Risk Management for
has been applied, and it is easy to see why. Where the accountants BDO Stoy Hayward.
It is difficult to comment on the current credit needed, although I knew some lenders were prepared
crisis and the risk issues that surround it without to lend up to 125% of the property value for a whole
variety of purposes.
3
appearing to be political, but I will try.
Amount – Many might recall that mortgage lenders
The first 26 years of my working life were spent in used to work on simple multipliers as a guide to the
banking. I worked in many different roles, but for many maximum they would lend. These used to be set at
of those years I was a lending manager. I will admit around three times sole income, or 2.5 times joint,
there were occasions when I got it wrong, but on the but over recent years these multipliers have become
whole I would like to think I got it right and helped many somewhat less restrictive. To borrow almost five times
businesses and individuals succeed. their income (much of which was indeterminable and
During most of that time, lending decisions were based unreliable) and almost the total value of the inflated
on a simple mnemonic, CAMPARI – character, ability, price of the house would seem to be bordering on
margin, purpose, amount, repayment and insurance, reckless. I again wondered to what extent this was
the latter referring to insurance in the broadest sense, influenced by the housing market boom.
as will be clearer later. These were described as the Repayment – This relied in the short term on a
canons of good lending. They provided the banker with government grant, earnings from part time employment
a tried and tested model for credit risk analysis, and and bonuses. In the longer term, it depended on my
helped ensure the correct risk/reward ratio. daughter securing full time employment on leaving
Over time analysts realised that many of the factors that university. Fortunately, the gamble paid off, but if it had
underpinned CAMPARI could in effect be scored, and not, I can only assume that the lender would have taken
so this model was gradually translated into what we comfort from the steadily increasing value of the property,
now call credit scoring. So how is it that what appears to once again relying heavily on the housing boom.
be a fairly robust model leads to irresponsible lending? Insurance – This really means security, and in this case
Good question, and one I have often asked myself. meant the house. If the borrower fails to pay, then the
In 2007, my daughter wanted a mortgage. Her fiancé lender seeks recourse to the security. Again, enormous
had had a job for a year or so, but she was still at emphasis was placed on the rising value of the asset,
university. To get the property they wanted, they needed so much so that, as you have probably guessed, the
to borrow almost five times their joint income, which mortgage was agreed on the spot, without a guarantee.
included her fiancé’s bonuses, her part-time income and
Poor pawn brokers
a government grant she received. My expectation was
that they would need dad’s guarantee to provide the How on earth did we get to this irresponsible
‘insurance’, as from my experience their request would credit culture? I feel certain that others would have
otherwise fail the CAMPARI test: been equally keen to lend to my daughter. Clearly
complacency set in, driven by greed, because of the
Character – They had no real track record, neither buoyant housing market. House prices were based on
of them had a credit card nor, indeed, any real credit demand fuelled by access to almost limitless credit. The
history. Also, the lender they had approached was high proportion of lending to value was not seen as a
neither my daughter’s nor her fiancé’s account holder. problem; indeed we know that 125% mortgages were
Ability – Quite correctly the mortgage adviser not at all unusual.
requested a detailed budget planner so that they could If you multiply my daughter’s experience many million
demonstrate that they could afford the repayments, times, you end up with a totally distorted market, where
but given the reliance on grants, part time work and profligate lending is the norm, which potentially has the
bonuses, affordability was at best questionable, even in makings of a global crisis.
the short term.
What does this say about how lending decisions in
Margin – This is very much about the risk/reward ratio. banking have changed and why they have been allowed
The actual reward was very modest since the mortgage to develop in this way? The fact is that the regulator,
products on offer were very competitive and therefore the Financial Services Authority (FSA), knew about the
had very fine interest margins, but on paper the risks problem even before taking responsibility for regulating
were massive. However, at this point the housing mortgage lending!
market factor seems to have started to cloud any
rational thinking. Addressing mortgage lenders in 2003, Philip Robinson,
a Director at the FSA1, used the CAMPARI model
Purpose – Mortgage lending for a house purchase to emphasise his misgivings about the state of the
would seem appropriate, a long term loan, for a long mortgage market. He expressed real concerns about
term purchase, and my daughter had no desire to sub-prime mortgages, the rate of growth in mortgage
borrow for any other purpose, or any more than was credit and too much emphasis on the current and future
The first decade of the 21st century is not over capacity to repay in anything but a growing market. We
yet, but already the noughty years have become chose to forget the truism – Values can go down as well
‘the naughty years’, which sums up what can only as up. Has the constant repetition of this message at
be described (in risk management terms) as the the end of advertisements for financial products made
us oblivious to its significance?
tolerate years.
In my father’s time, you could only get a mortgage or a
Despite the warning signs of the Enron, Arthur Andersen loan if you could produce 20% of the money required to
and Tyco scandals and the dot.com bust, the nonsense purchase the asset. This was a good control. It meant
continued. Even the mighty US Sarbanes-Oxley served that the borrower had a history of saving and if the
only to fuel the compliance industry while being regarded borrower defaulted, the lender had a claim on an asset
as a spoil sport by some in the financial services sector. that was highly likely to cover the debt. These were
comfortable safety margins engineered in the same
With all the attention given to risk management since
way you would design safety into a machine that could
September 2001, one would think that this would have
physically hurt someone. And in a similar way, people
been a decade of risk management prowess. As a
forgot the reasons for the controls or believed them to
result of the introduction of risk management standards
be too restrictive and relaxed them... until something
and frameworks, such as A/NZ 4360, COSO, Basel II,
broke. The financial system that world economies are
etc, we had better tools to manage the risks. Financial
built on just broke!
regulators in the developed world were to be the
watchdogs and ensure that the financial community Risk management’s role in all of this
stayed within the boundaries.
Did risk managers tell their boards that they were sailing
So where did it all go so horribly wrong? Was it really into stormy waters? Are there many like Paul Moore,
the sub-prime market in the United States? That former Head of Group Regulatory Risk at HBOS, who feel
was certainly part of it, but not all of it. Allowing the that they were in a rowing boat trying to stop the tanker,
investment banks to leverage up to ratios of 30 or 40:1 when they really should have been the pilot employed to
is closer to the truth. And individuals are not totally steer the boat through a challenging course?
blameless; many borrowed sums that were beyond their
How on earth did it happen: a house is Some banks correctly assessed the risks to their
repossessed in West Virginia and the global own portfolios, but they had insufficient information to
financial system falls down! identify the tsunami effect on the system which would
strike from September 2008.
• Was it a weakness in risk management? Some banks tried to take action to mitigate their
• Can we make sure it never happens again? exposure, but they could not transfer the impact of the
• Are there any opportunities for risk management system crashing. In effect, banks which took action
to grasp? were playing pass the parcel without leaving the room
In this paper I intend to argue the answers to those when the final unwrapping revealed an exploding bomb!
questions are No, No and Yes, this crisis will reveal Those banks which were observed in March 2008
opportunities for risk management. They will flow demonstrated the following:
from the need to increase transparency for external
investors, to support governance structures better
Best Practices Poor Practices
and to provide proof of professional risk management
application through academic qualification – the IRM Sharing information Business areas making
International Diploma. freely and proactively decisions in isolation,
But first, it is important to knock down any arguments that across businesses with failing to see the full picture
risk management got us into this mess, why it couldn’t be procedures for senior level (incomplete information)
avoided and why it will inevitably happen again. challenge/action
Institute of Risk Management Networking opportunities for those with a risk-related qualification, up
• Membership of any of the special interest to full Member and ultimately Fellow. Simply
Membership provides you with information, groups you want to join complete and return the application form from
our website (www.theirm.org) or phone us on
networking opportunities and recognition. • Membership of your local regional group +44 (0)20 7709 9808 to join.
Become a member and you get all the • Free annual lecture and other events focussing
following included in your subscription: on the topical issues in risk management The Institute provides a broad range of
courses to help you build your knowledge
• Discounted entry to the Risk Forum, the and skills. The International Certificate in Risk
Information Institute’s annual conference and dinner Management is an introductory qualification,
• The Institute’s magazine with a weekly with no entry requirement, which is studied
e-supplement containing news, articles and Recognition through distance learning.
job vacancies • The opportunity to study for an internationally
recognised risk qualification The International Diploma in Risk Management
• Free subscriptions to risk-related magazines is the postgraduate qualification for the risk
• Discounts on relevant activities such as • Designatory letters according to your management professional. It is designed
conferences and events from third parties membership grade to equip today’s practitioners to become
There are various grades of membership the risk managers of tomorrow, through the
• Unlimited access to the Institute’s online
starting with Affiliate, which has no entry development of a solid, progressive and
Risk Library
requirements and is open to everyone with an practical set of skills which in turn enhance
interest in risk management, through Specialist, career portability, personal status and reward.
Disclaimer: the opinions expressed in this publication do not necessarily reflect those of the IRM