By: Sunil Datt, MS, MBA, MA, CGFM, PMP
Sunil Datt, MS, MBA, MA, CGFM, PMP, is Senior Managing
Consultant, IBM Global Business Services.
When acronyms begin to appear, you know a debate has gone on
for too long. So when I saw TBTF (Too Big To Fail) in an article, I knew the
time for discussion was over, and it was time to act. Of course, in spite of my
advice to the contrary, Mervyn King took the hatchet and sliced up a couple of
banks in the U.K. Never mind, he took action! At least he got the banks scared
for some time. But here, back home, the debate is festering, and some smart
cookies have already proposed Jamie Dimon (CEO of JP Morgan Chase) as the next
Treasury Secretary.
Jamie, of course, is quick to act. He already wrote in the
Washington Post of Nov. 13, 2009, that the term TBTF should be banished
from our vocabulary. Instead, he proposes an orderly winding down of an
institution, no matter how large. Easier said than done. Remember, Lehman’s demise
was catastrophic not because of its size, but because of the number of
counterparties it put at risk globally. And the systemic risk arises not just
from actual losses, but from the vaporization of confidence in even the largest
or most respected players in the system. Markets seize up, and that starts the domino effect.
Anyway, the issue is why are we thinking like undertakers,
and not like preventive care physicians? As I wrote in my previous weblog,
“The real issue is the interconnectedness and the tight integration of global
financial markets in today’s world. The dominos don’t stand individually and
get knocked down one by one. They hold hands and dance together. And they
infect each other virally. From that perspective, ‘smart’ regulation lies in a
combination of better reporting requirements from all major financial players,
highly automated processing of submitted data, and sharp quick analysis to
detect seeds of systemic risk. Stress testing all new financial instruments
would be part of such a regime.”
So the question arises, is this possible? Is it humanly possible to collect such
vast amounts of data and process it meaningfully, and point out incipient
symptoms of sickness? The answer is yes, because we have the technology. We
have the Web for filing of information, we have super computers like IBM’s Blue
Gene for processing at super speeds, and we have tons of software for storing,
aggregating and analyzing data. In fact, it is possible to collect risk parameterized
data from every financial institution in the nation, and process and analyze it
in pretty short time frames. But that will not be necessary. Collecting data
from all financial entities that have assets of say, over a billion, should
serve the purpose.
As a matter of fact, on a smaller scale the Federal Deposit Insurance Corporation (FDIC) has been
doing this for the Federal Financial Institutions Examination Council (FFIEC),
that consists of FDIC, the Federal Reserve and the Office of the Controller of
the Currency, since 2006. Using the XBRL (Extensible Business Reporting
Language) standard, FDIC collects quarterly call report data from 8,200 banks in
a highly automated environment, and then shares it with the other members of
the FFIEC. As compared to earlier methods, this automated environment has
resulted in the following improvements:
- Cleaner
data—95 percent compliant with definitions as compared to 66 percent previously.
- More
accurate data—100 percent mathematical requirements met as against 70 percent prior.
- Faster
data inflow—Data received within one day of quarter close as against
weeks in the previous system.
- Increased
productivity—Each analyst could now handle up to 600 banks as against
450 banks previously.
- Faster
analysis—Analyst workload completed 15 percent faster.
Now, the Securities and Exchange Commission (SEC) has mandated a phased program of filing annual
and quarterly reports in XBRL by reporting firms, starting June 2009, and then
of risk-return statements by mutual funds. The data will be available not just
to analysts but to the public in general.
The FDIC and SEC are, however, still collecting data in the
traditional formats for the traditional regulatory functions viz. capital
requirements. As the Basel II type requirements have been proven to be
insufficient for containing systemic risk, the parameters for risk measurement
have to be revised. In any case, the massive disintermediation away from banks
requires fresh thinking in this area, clearly requiring regulation of large
non-banks. It is instructive that between 1977 and 2007, the assets of all
depository institutions plunged from 56.3 percent to 23.7 percent of total
financial sector assets. Meanwhile, the assets of pension funds and mutual
funds rose from 21.0 percent to 37.8 percent, as these institutional investment
pools came to provide the dominant channels for household saving and investment
flows. At year end 2007, the financial assets of pension funds and mutual funds
totaled $21.9 trillion, as compared to $13.7 trillion for banks. Talking of
TBTF!