Studying for the Test

Instead of studying the material. In a Monday Wall Street Journal op-ed, Michael Faulkender and Tyler Goodspeed, University of Maryland Finance Professor and Fellow at Stanford University’s Hoover Institution, respectively, wrote about bank stress tests and their resulting uniformity of banks’ risk management techniques. Citing a Boston Federal Reserve study, they noted that

banks that performed poorly on the mandated Dodd-Frank stress tests subsequently adjusted their portfolios such that they more closely resembled the portfolios of banks that performed well. The average institution’s portfolio is more diversified, but the system is more uniform. By requiring all of the biggest financial institutions to adhere to the same measures, pass the same tests, and follow the same practices, America has lost diversification in the entire banking sector.

Dodd-Frank, in essence, required individual banks to do better at diversifying their individual portfolios. But that business of all of them having to pass the same test means that all the banks have much the same portfolios, diversified over much the same instruments.

This is the complement of teaching the test rather than teaching the material and then testing that knowledge. Banks are (regulatorily pushed into) learning the test rather than learning the material and then acing the test.

Uniformity is dangerous for species in a biological ecology, and uniformity is dangerous for categories of businesses in an economical ecology.

Mistake

Treasury Secretary Janet Yellen wants to extend the Federal government’s intrusion into our banking system.

Our intervention was necessary to protect the broader US banking system. And similar actions could be warranted if smaller institutions suffer deposit runs that pose the risk of contagion[.]

No, it wasn’t. No, it would not be.

Businesses thrive or fail on their managers’—individual Americans acting in concert with other individual Americans—performance or failure to perform. We individual Americans thrive, or not, on our own decisions, made out of our own obligations and determination to get ahead.

It isn’t government’s job to inure us individual Americans or our businesses from the vagaries of the marketplace or—especially—from our own poor decision-making. It’s government’s job to create and enforce a framework within which our free market can operate freely, and within which personal responsibility, whether as individuals or as business managers, can operate freely.

If our decisions are without consequence, we are neither operating freely nor in accordance the requirements of our personal responsibility.

Wrong Answer

The Biden/Regan Environmental Protection Agency has decided to get into individual municipalities’ business.

For the first time in 26 years, the US Environmental Protection Agency has issued new guidelines for drinking water safety. Municipal utilities will be required to install expensive filtration systems to lower the amount of PFAS in water supplies.

The cost of such “guidelines” will run to billions of dollars just for Illinois’ cities, towns, and villages. Multiply that by all the cities, towns, and villages across the US and our territories—the reach of the EPA—and we get a ton of costs.

PFAS (Per- and polyfluoroalkyl substance) and the related PFOS (perfluorooctanesulfonic acid) are chemicals that don’t appear to break down in anything approaching a useful time frame, and they are associated with a variety of cancers. That makes it useful to avoid ingesting them or inflicting them on our environment.

However.

While removal of these chemicals is a good idea, doing that alone and at the end of the production-use-disposal chain will cost the relevant jurisdictions vast sums in perpetuity. Too, after the chemicals are removed from our water supplies—what then? What will we do with those now concentrated perpetual chemicals? Nuclear waste at least breaks down after some, often extended, period of time.

Focusing on developing other materials that don’t require these chemicals, at the beginning of the production-use-disposal chain would be initially expensive and long-term far cheaper. But that wouldn’t maintain EPA power.

“The Fed Got Us Into the SVB Mess”

That’s the headline on The Wall Street Journal‘s Sunday Letters section. There’s also this from a letter by Desmond Lachman of the American Enterprise Institute:

The real lesson from SVB’s failure is that things break when the Fed is forced to raise interest rates at an unusually rapid rate to regain inflation control.

And this, from another Letter-writer in that section:

…the Fed sowed the seeds of the current crisis as SVB stretched for yield in a zero-interest-rate environment and then failed to manage its duration risk. The Fed’s efforts to micromanage the economy creates unforeseen problems that continue to erupt.

No, and no.

There is much to criticize regarding the Fed’s interest rate moves, but they’re irrelevant to SVB’s and Signature Bank’s failures.

The Fed’s interest rate increases may have been done at an unusually rapid rate, but they still occurred over a period of months—12 of them in fact: the first increase in the current series was way back in March 2022. The Fed’s moves were part of the environment in which these two failed banks operated, nothing more. It was the management teams of two failed banks who failed to deal with the environment in which they operated.

The idea that the Fed’s moves—micromanaging our economy or other moves—created unforeseen problems is risible on its face. Any pupil in a high school economics class knows that bond (and other debt instrument) prices move in the opposite direction from interest rates: as rates rise, existing bond prices fall. SVB’s and Signature’s managers surely are high school graduates; they knew full well that their reserve holdings, held almost entirely in long-term Treasuries and mortgage-backed debt instruments, were falling in value for the entire year that the Fed had been raising interest rates. The failure of these two banks to pay attention to their reserves is entirely and solely the fault of those two banks’ management teams.

Whitewash

It seems the Federal Reserve knew of the risks stemming from SVB management moves as long ago as 2019 [emphasis added].

In January 2019, the Fed issued a warning to SVB over its risk-management systems, according to a presentation circulated last year to employees of SVB’s venture-capital arm….
The Fed issued what it calls a Matter Requiring Attention, a type of citation that is less severe than an enforcement action. Regulators are supposed to make sure the problem is addressed, but it couldn’t be learned if the Fed held SVB to that standard in 2019.

Following the 2019 warning, the Fed informed SVB in 2020 that its system to control risk didn’t meet the expectations for a large financial institution, or a bank holding company with more than $100 billion in assets, the presentation to employees at SVB’s venture-capital arm said.

And:

Over time, the central bank issued numerous warnings to SVB, suggesting the bank’s problems were on the radar of the Fed, the bank’s primary federal regulator.

So, what was done by the Fed’s regulators in response to this string of noncompliances?

A central-bank review of its oversight of SVB is due by May.

Will those prior whitewashes be followed up with an official whitewash?

I’m not holding my breath over a favorable outcome, which IMNSHO would include, at the very least, the public firing for cause of the Fed regulator(s) directly responsible for SVB oversight and that individual’s/team’s supervisor. Pour l’encouragement des autres régulateurs.