Bank Regulation in the Canadian context - Part 2

To paraphrase from my previous post on the subject (link here), the stock prices of Canadian banks outperformed large American banks during two separate periods through the late 90s and the 2000s. One was a benign period from 1998 to 2005, and the other was the period from 2002 to 2009 (which culminated with the Great Recession), i.e. a combined good and bad period. However, Canada all through this period faced tighter banking regulation than the US banks. What worked in the Canadian example?

Per the FT article, there were three factors involved. And extrapolating from these factors, my belief is that it translated to one important difference in the operating philosophy of Canadian banks vis-a-vis US banks, or for that matter, even the ones in the UK and continental Europe.
- The first factor was a simple regulatory framework. The US famously had an alphabet soup of regulatory agencies that were competing for banks' business. Canada by contrast had a very simple set up. One agency to serve as the central bank - responsible for the stability of the overall system, one as a banking supervisor, one agency for consumer protection and the finance ministry that set the broad rules on ownership of financial institutions and the design of financial products.
- The second factor was a set of really simple and easy-to-follow risk guardrails on individual institutions, having little to no room for flexibility. the first such rule as a requirement of 7% of assets to be maintained as Tangible Common Equity or TCE. Now, 7% is quite a conservative number when compared with the 4.5-6% that US regulators have been comfortable at different points in time. Additionally, the OSFI required that the capital maintained be of the highest quality - shareholder equity. The Canadian regulators require that 75% of TCE should be comprised of shareholder equity. There is no room for quasi-equity products like preferred shares (which, incidentally have not turned out to be very useful from a capital standpoint for US institutions). Finally, the third requirement was a leverage cap of 20:1. Compare this with US banks that have consistently maintained higher leverage ratios in an attempt to expand investments and improve returns to stakeholders in an environment supposedly insulated from risk.
- Finally, a third important factor were the dealings between the Canadian bank regulator and the banks when it came to following rules. The Canadian system was based on principles, rather than narrowly following specific rules. It is about the spirit rather than the letter of the law. The head of the OSFI regularly met with the bank CEOs and was a frequent attendee to board meetings, especially in the ones having the non-executive board members attending. The bank CEOs on their part took interest in maintaining a stable system and paid serious attention to the advisement of the regulators.

Now, I am attempting to fill in the blanks beyond this point. My hypothesis on the operating philosophy of Canadian banks is that these simple and non-negotiable guidelines did not leave too much room for adventures such as optimization around edges, getting into illiquid and structurally untested asset classes (like the synthetic ABSs and MBSs), etc. Canadian banks realized that the one safe and reliable way of making money would be to focus on consumer/ business borrowing needs and meet them with simple lending products. The returns from a plain-vanilla banking business which centered around taking deposits and lending them directly to consumers and businesses, were secure and good enough to generate a healthy return on capital for these banks. Which then got captured in a healthy stock price. The creativity and the management talent of the bankers went towards meeting customer needs, as against getting into even more arcane areas of structured finance.

What does this all mean for risk management and its application? There is a myth out there somewhere that tighter regulations tends to dampen shareholder returns. The high-impact downside resulting from tail-events is prevented, but that is at the cost of profits during more normal times. However, that doesn't seem to have been the case considering the performance of Canadian banks. Canadian banks were more tightly regulated than US banks, i.e. risk management was tighter. But the banks clearly did not suffer as a result. Rather a principles-based risk management practice resulted in greater co-operation between banks and the regulators, allowed the banks to focus on the long-term drivers of value in banking and ultimately returned better returns to shareholders.

Bank Regulation in the Canadian context - Part 1

The fallout of the 2008-09 Great Recession in terms of failed banks, lost jobs, shuttered plants, bankrupt companies, is news to all by now. What started off as a repayment crisis had an amplified impact on the overall economy - driven by reckless risk-taking by big banks, over-leveraging and ultimately pursuing a path that seems to suggest that they believed they were too big to fail. Which turned out to be the case ultimately. Read bailout of AIG, the arranged marriage for Bear, government takeovers of Fannie and Freddie and so on.

The contagion has not been limited to US banks and institutions by any means. European Banks (UBS, Deutsche and Societe Generale), British banks, Irish and Icelandic banks - all showed similar behaviours, similar disdain for any considerations of their long-term health believing themselves to be too big to fail. One glorious exception in all of this has been large Canadian banks. As compared to some of their US and European rivals, these large banks have been the very paragon of well-managed and well-run financial institutions and have hardly suffered a blip to their profitability or needed any government largesse over the Great Recession to survive. In fact, Canada is the only G7 country to survive the financial crisis without a state bail-out for its financial sector.

(The top 5 Canadian banks are Royal Bank of Canada, Scotiabank, Toronto-Dominion Bank, Bank of Montreal and the Canadian Imperial Bank of Commerce. Besides cornering nearly 90% of the Canadian market, these banks are in reality large international banks with operations in 40-50 countries, and stock listings on multiple exchanges. A quick primer on Canadian banks is here.)

What caused the Canadian banks to survive? An immediate reaction (which incidentally would be wrong) is that Canadians are somehow too nice to participate in the kind of no-holds-barred plundering practiced by the American banks. They play a soft form of capitalism, one that protects the downside but also somehow limits the upside. Hmmmm, not entirely true. The net shareholder returns of Canadian banks have exceeded that of UK and US banks in the last 5 years, as evidenced in the graph below.


What about returns over a larger time period? How do the top Canada banks compare to the top US banks in terms of stockprice performance?

Looking at a 7 1/2 year period from mid-2002, the total returns on a basket of large Canadian banks (the ones mentioned above) was 144%. In the same period, US large banks (Citi, Chase, BofA, Wells, Goldman, Morgan Stanley) had a return of a paltry 2%. OK, the US banks returns were decimated because of the recent credit crisis. The market over-reacted maybe. If you look at returns from a period from Jan 1998 to Dec 2005, when we were having a so-called 'Goldilocks' economy, the story isn't too different. US bank stocks rises to a more respectable 69% but the performance of Canadian bank stocks improves even more to 183%.

Table of stock price performance for top Canadian banks - followed by US banks
(Boom and Bust Period)

	June 2002	Feb 2010
RBC	16.06	50.44
TD	23.19	59.56
CIBC	32.85	59.135
BofM	21.86	48.86
Scotia	17.41	42.87

	June 2002	Feb 2010
Chase	22.25	38.39
Wells	25.2	26.71
BofA	35.18	14.47
Citi	28.68	3.18
Goldman	73.35	152.49
MS	35.62	27.13

Table of stock price performance for top Canadian banks - followed by US banks
(Boom Period only)

	Jan 1998	Dec 2005
RBC	12.15	39.27
TD	17.49	52.55
CIBC	24.02	65.8
BofM	20.22	55.94
Scotia	16.6	39.93

	Jan 1998	Dec 2005
Chase	51.29	48.3
Wells	18.22	35.56
BofA	29.94	46.15
Citi	24.78	48.53
Goldman	73.72	133.26
MS	29.19	56.74

(Goldman Sachs and Bank of Montreal did not have full information over these periods. But having them in the numbers - or taking them out - doesn't change the story.)

SO what can explain the better performance of Canadian banks? What allows them the ability to not only perform better through the cycle but also do so with mininal government handouts? The answer is superior risk management and that will form part of the next part on this subject.

Christya Freeland of FT.com has a fascinating article on the subject and the link is here.

Too Big To Fail - contd.

I have commented earlier on the TBTF doctrine.

Recently, I came across a couple of other references on the TBTF situation and what to do about it. The first from the FT has the author Willem Buiter presenting a slew of solutions on what to do about banks becoming TBTF. (Interesting how this abbreviation seems to have taken on a life of its own!) Definitely worth taking a more detailed read as the author goes to a fair degree of detail on what are some of the probable solutions.

The second is a novel way of valuing the benefit that banks get from becoming TBTF. The approach (proposed by a couple of economists Elijah Brewer and Julapa Jagtiani from the Philadelphia Fed) argues that the measure of the benefit that banks expected to get could be ascertained by the acquisition premium paid by these very banks along their journey to becoming TBTF. The estimate of this premium (looking at acquisitions from 1991 to 2004) is about $14 billion. This link references the actual paper written by the economists.

Given my obsession on getting to an optimal risk management framework for financial institutions, I thought I'd share a couple of these links.

Too Big To Fail or Too Scared To Confront?

Back to the blog after a long break. I do need to find a way to become more regular at updating the blog and keeping at expressing my thoughts and ideas.

What spurred this latest post was a decent article I read on the Too-Big-To-Fail (TBTF) doctrine. Of course, one is talking about banks. The article goes into details about the cost of propping up the banks and some of the estimates are truly mind-blogging.

According to the Bank of England, governments and central banks in the US, Britain, and Europe have spent or committed more than $14 trillion—the equivalent to roughly 25 per cent of the world’s economic output—to prop up financial institutions. Combined with a global recession, this bailout has undermined the public finances of the developed world.

Another related set of articles is here from the Free Exchange blog of the Economist. Raghuram Rajan from the University of Chicago School of Business has contributed some good ideas and a robust discussion of the pros and cons of various options have been presented. As always, there is little effort on the part of the various contributors to synthesize a viewpoint. Rather the tendency is to point out why a specific solution presented may not work.

To a large extent, I think these ideas miss an important point. The ideas consistently treat financial institutions as rational entities, which seem to operate largely on principles of rational economics, capital theory and other such textbook ideas. The fact of the matter is that management matters. And management is a function of the human beings that take important decisions within these organizations, their incentive structures and also, more broadly, the set of values and identity that seems to motivate these human players.

And unless we all as stakeholders begin to take notice that the destiny of corporations are driven by the individuals managing those organizations, that the laws of economics are (unlike the laws of nature) created by its human players, we will continue to argue around the margins on window dressing the regulatory system and make no significant progress towards creating a more stable financial system. A stable system by definition is going to provide fewer opportunities to pursue supernormal profits. A stable system needs the suppression of that oldest of human sins, greed. Do have the courage to confront ourselves and seriously consider a slew of workable solutions to fix a broken system? Only time will tell but I am not holding my breath.