Showing posts with label regulations. Show all posts
Showing posts with label regulations. Show all posts

Friday, March 15, 2013

Beginning of the end for big banks?

If the biggest banks are too big to fail, too connected to fail, too important to prosecute, and also too complex to manage, it would seem sensible to scale them down in size, and to reduce their centrality and the complexity of their positions. Simon Johnson has an encouraging article suggesting that at least some of this may actually be about to happen: 
The largest banks in the United States face a serious political problem. There has been an outbreak of clear thinking among officials and politicians who increasingly agree that too-big-to-fail is not a good arrangement for the financial sector.

Six banks face the prospect of meaningful constraints on their size: JPMorgan Chase, Bank of America, Citigroup, Wells Fargo, Goldman Sachs and Morgan Stanley. They are fighting back with lobbying dollars in the usual fashion – but in the last electoral cycle they went heavily for Mitt Romney (not elected) and against Elizabeth Warren and Sherrod Brown for the Senate (both elected), so this element of their strategy is hardly prospering.

What the megabanks really need are some arguments that make sense. There are three positions that attract them: the Old Wall Street View, the New View and the New New View. But none of these holds water; the intellectual case for global megabanks at their current scale is crumbling.
Most encouraging is the emergence of a real discussion over the implicit taxpayer subsidy given to the largest banks. See also this editorial in Bloomberg from a few weeks ago:
On television, in interviews and in meetings with investors, executives of the biggest U.S. banks -- notably JPMorgan Chase & Co. Chief Executive Jamie Dimon -- make the case that size is a competitive advantage. It helps them lower costs and vie for customers on an international scale. Limiting it, they warn, would impair profitability and weaken the country’s position in global finance.

So what if we told you that, by our calculations, the largest U.S. banks aren’t really profitable at all? What if the billions of dollars they allegedly earn for their shareholders were almost entirely a gift from U.S. taxpayers?

... The top five banks -- JPMorgan, Bank of America Corp., Citigroup Inc., Wells Fargo & Co. and Goldman Sachs Group Inc. - - account for $64 billion of the total subsidy, an amount roughly equal to their typical annual profits (see tables for data on individual banks). In other words, the banks occupying the commanding heights of the U.S. financial industry -- with almost $9 trillion in assets, more than half the size of the U.S. economy -- would just about break even in the absence of corporate welfare. In large part, the profits they report are essentially transfers from taxpayers to their shareholders.
So much for the theory that the big banks need to pay big bonuses so they can attract that top financial talent on which their success depends. Their success seems to depend on a much simpler recipe.

This paper also offers some interesting analysis on different practical steps that might be taken to end this ridiculous situation.

Tuesday, March 12, 2013

Strategic recklessness

Some poignant (and infuriating) insight from Chris Arnade on Why it's smart to be reckless on Wall St.:
... asymmetry in pay (money for profits, flat for losses) is the engine behind many of Wall Street’s mistakes. It rewards short-term gains without regard to long-term consequences. The results? The over-reliance on excessive leverage, banks that are loaded with opaque financial products, and trading models that are flawed. ... Regulation is largely toothless if banks and their employees have the financial incentive to be reckless.

Friday, December 14, 2012

For banks, nothing is illegal

This would be literally unbelievable, except that we've all become desensitized to the double standard of our justice system -- enforcement of laws against ordinary people, and systematic collusion with large banks and corporate offenders to keep anyone from going to jail. I think Matt Taibbi offers the most honest take on this shameful decision to slap HSBC with fines only, rather than pursuing what should have been slam-dunk prosecutions for money laundering and drug smuggling on a global scale:
Wow. So the executives who spent a decade laundering billions of dollars will have to partially defer their bonuses during the five-year deferred prosecution agreement? Are you fucking kidding me? That's the punishment? The government's negotiators couldn't hold firm on forcing HSBC officials to completely wait to receive their ill-gotten bonuses? They had to settle on making them "partially" wait? Every honest prosecutor in America has to be puking his guts out at such bargaining tactics. What was the Justice Department's opening offer – asking executives to restrict their Caribbean vacation time to nine weeks a year?

So you might ask, what's the appropriate financial penalty for a bank in HSBC's position? Exactly how much money should one extract from a firm that has been shamelessly profiting from business with criminals for years and years? Remember, we're talking about a company that has admitted to a smorgasbord of serious banking crimes. If you're the prosecutor, you've got this bank by the balls. So how much money should you take?

How about all of it? How about every last dollar the bank has made since it started its illegal activity? How about you dive into every bank account of every single executive involved in this mess and take every last bonus dollar they've ever earned? Then take their houses, their cars, the paintings they bought at Sotheby's auctions, the clothes in their closets, the loose change in the jars on their kitchen counters, every last freaking thing. Take it all and don't think twice. And then throw them in jail.

Sound harsh? It does, doesn't it? The only problem is, that's exactly what the government does just about every day to ordinary people involved in ordinary drug cases.

And people wonder why the US falls year after year a little further down the Corruption Perceptions Index? As of 2012, we're just slightly ahead of Chile, Uruguay and The Bahamas. 

Wednesday, December 12, 2012

Elements of a stable financial system

It's hardly a hell raising demand for revolution, but this speech by Michael Cohrs of the Bank of England is worth a quick read and offers some pretty encouraging signs that authorities -- in the UK, at least -- are moving (slowly) toward financial regulations that seem pretty sensible and might really help avoid future crises or make them less frequent. I read it as a kind of wish list, but of wishes that are fairly realistic.

On a theoretical level, perhaps the most important thing Cohrs calls for is greater awareness of economic and financial history, with the idea that we might prepare our minds better for the natural instabilities that seem to create crises so frequently:
At the heart of much of the current policy debate is how the FPC, PRA and FCA develop better processes for anticipating the next problem – whether the problem is an asset bubble, poor risk mismanagement or a flawed or misunderstood financial product. And these are important steps to take. But it seems to me there is an inherent tendency for policymakers to re-fight the last war. As I said above, I am a believer that understanding the past provides a foundation on which to assess the future. But we shouldn’t pretend we can eliminate financial crises completely. Nor that the next crises will necessarily be a carbon copy of the last one.
My anxiety about getting financial regulation to better mitigate future risks has its roots in the issues one sees in the financial crises of the past couple of hundred years or so. Virtually every type of financial institution has been the cause of a crisis at some point in history – country banks back in 1825, universal banks in 1931, small banks in the 1970s, savings and loan companies in the 1980s, international banks in the 1980s and 1990s (debt crises in Latin America and Asia respectively), and even a hedge fund in 1997.
Pretty much all types of financial institution got involved in the problems of 2007/2008. The roll call included insurance companies (although thankfully not those in the UK) alongside investment banks as well as some more traditional commercial and mortgage banks. I find it hard to see a common thread (other than high leverage ratios) amongst the types of institutions that struggled or the mistakes that they made. It is not clear that the reforms we are putting into place today would have, or could have, averted all the problems faced in these crises. Therefore, experience tells me its origins are unlikely to be in an institution and from a product that is obvious to us now. ... I realize this uncertainty is rather unhelpful.
Actually, I think it is very helpful. Nothing is more dangerous than belief that now , as we know how things can go wrong, we can probably perform a few engineering tricks and hence avoid further problems in the future. This was the facile belief furthered in the decade prior to the past crisis, especially in basic textbooks of economics and finance and research papers furthering belief in the inevitable "spiral to efficiency" of modern markets (infamously described in this rather embarrasing 2005 paper by Robert Merton and Zvi Modie, which was published even as the markets were on the verge of collapse!).

Cohrs goes on to discuss a number of ideas all being pursued with the idea of making finance more "sustainable." These include establishing simple rules by which large institutions can be wound down and let fail safely when they ought to (this might include using penalties or taxes to establish insurance funds beforehand to handle such events), making financial institutions LESS CONNECTED and changing the culture of finance as well so that financial institutions themselves "ensure they can be regulated." Ok, that final one may be a rather huge challenge.

The good thing is that people from the Bank of England are going around saying these things. Let's hope they can manage to put some of these principles in place, especially in some globally consistent way.

Monday, February 13, 2012

Approaching the singularity -- in global finance

In a new paper on trends in high-frequency trading, Neil Johnson  and colleagues note that:
... a new dedicated transatlantic cable is being built just to shave 5 milliseconds off transatlantic communication times between US and UK traders, while a new purpose-built chip iX-eCute is being launched which prepares trades in 740 nanoseconds ...
This just illustrates the technological arms race underway as firms try to out-compete each other to gain an edge through speed. None of the players in this market worries too much about what this arms race might mean for the longer term systemic stability of market; it's just race ahead and hope for the best. I've written before (here and here) about some analyses (notably from Andrew Haldane of the Bank of England) suggesting that this race is generally increasing market volatility and will likely lead to disaster in one form or another. 

We may be getting close. If Johnson and his colleagues are correct, the markets are already showing signs of having already made a transition into a machine-dominated phase in which humans have little control.

Most readers here will probably know about futurist Ray Kurzweil's prediction of the approaching "singularity" -- the idea that as our technology becomes increasingly intelligent it will at some point create self-sustaining positive feedback loops that drive explosively faster science and development leading to a kind of super-intelligence residing in machines. Humans will be out of the loop and left behind. Given that so much of the future vision of computing now centers on bio-inspired computing -- computers that operate more along the lines of living organisms, being able do things like self-repair and adaptation, true reproduction, etc, -- it's easy to imagine this super-intelligence again ultimately being strongly biological in form, while also exploiting technologies that earlier evolution was unable to harness (superconductivity, quantum computing, etc.). In that case -- again, if you believe this conjecture has some merit -- it could turn out ironically that all of our computing technology will act as a kind of mid-wife aiding a transition from Homo sapiens to some future non-human but super-intelligent species.

But forget that. Think singularity, but in the smaller world of the markets. Johnson and his colleagues ask the question of whether today's high-frequency markets are moving toward a boundary of speed where human intervention and control is effectively impossible:
The downside of society’s continuing drive toward larger, faster, and more interconnected socio-technical systems such as global financial markets, is that future catastrophes may be less easy to forsee and manage -- as witnessed by the recent emergence of financial flash-crashes. In traditional human-machine systems, real-time human intervention may be possible if the undesired changes occur within typical human reaction times. However,... in many areas of human activity, the quickest that someone can notice such a cue and physically react, is approximately 1000 milliseconds (1 second)
Obviously, most trading now happens much faster than this. Is this worrying? With the authors, let's look at the data.

In the period from 2006-2011, they found (looking at many stocks on multiple exchanges) that there were about 18,500 specific episodes in which markets, in less than 1.5 seconds, either 1. ticked down at least 10 times in a row, dropping by more than 0.8% or 2. ticked up at least 10 times in a row, rising by more than 0.8%. The figure below shows two typical events, a crash and a spike (upward), both lasting only 25 ms.



Apparently, these very brief and momentary downward crashes or upward spikes -- the authors refer to them as "fractures" or "Black Swan events" -- are about equally likely. And they become more likely as one goes to shorter time intervals:
... our data set shows a far greater tendency for these financial fractures to occur, within a given duration time-window, as we move to smaller timescales, e.g. 100-200ms has approximately ten times more than 900-1000ms.
But they also find something much more significant. They studied the distribution of these events by size, and considered if this distribution changes when looking at events taking place on different timescales. The data suggests that it does. For times above about 0.8 seconds or so, the distribution closely fits a power law, in agreement with countless other studies of market returns on times of one second or longer. For times shorter than about 0.8 seconds, the distribution begins to depart from the power law form. (It's NOT that it becomes more Gaussian, but it does become something else that is not a power law.) The conclusion is that something significant happens in the market when we reach times going below 1 second -- roughly the timescale of human action.

Ok. Now for the punchline -- an effort to understand how this transition might happen. In my last blog post I wrote about the Minority Game -- a simple model of a market in which adaptive agents attempt to profit by using a variety of different strategies. It reproduces the realistic statistics of real markets, despite its simplicity. I expect that some people may wonder if this model can really be useful in exploring real markets. If so, this new work by Johnson and colleagues offers a powerful example of how valuable the minority game can be in action.

Their hypothesis is that the observed transition in market dynamics below one second reflects "a new fundamental transition from a mixed phase of humans and machines, in which humans have time to assess information and act, to an ultrafast all-machine phase in which machines dictate price changes."  They explore this in a model that...
...considers an ecology of N heterogenous agents (machines and/or humans) who repeatedly compete to win in a competition for limited resources. Each agent possesses s > 1 strategies. An agent only participates if it has a strategy that has performed sufficiently well in the recent past. It uses its best strategy at a given timestep. The agents sit watching a common source of information, e.g. recent price movements encoded as a bit-string of length M, and act on potentially profitable patterns they observe.
This is just the minority game as I described it a few days ago. One of the truly significant lessons emerging from its study is that we should expect markets to have two fundamentally distinct phases of dynamics depending on the parameter α=P/N, where P is the number of different past histories the agents can perceive, and N is the number of agents in the game. [P=2M if the agents use bit strings of length M in forming their strategies]. If α is small, then there are lots of players relative to the number of different market histories they can perceive. If α is big, then there are many different possible histories relative to only a few people. These two extremes lead to very different market behaviour.

Johnson and colleagues suggests that the transition between these regimes is just what shows up in the statistics around the one second threshold. They first argue that the regime for large α (many strategies per agent) should be associated with the trading regime above one second, where both people and machines take part. Why? As they suggest,
We associate this regime (see Fig. 3) with a market in which both humans and machines are dictating prices, and hence timescales above the transition (>1s), for these reasons: The presence of humans actively trading -- and hence their ‘free will’ together with the myriad ways in which they can manually override algorithms -- means that the effective number (i.e. α > 1). Moreover α > 1 implies m is large, hence there are more pieces of information available which suggests longer timescales...  in this α > 1 regime, the average number of agents per strategy is less than 1, hence any crowding effects due to agents coincidentally using the same strategy will be small. This lack of crowding leads our model to predict that any large price movements arising for α > 1 will be rare and take place over a longer duration – exactly as observed in our data for timescales above 1000ms. Indeed, our model’s price output (e.g. Fig. 3, right-hand panel) reproduces the stylized facts associated with financial markets over longer timescales, including a power-law distribution.
What they're getting at here is that crowding in the space of strategies, by creating strong correlations in the strategies of different agents, should tend to make large market movements more likely. After all, if lots of agents come to use the very same strategy, they will all trade the same way at the same time. In this regime above one second, with humans and machine, they suggests there shouldn't be much crowding; the dynamics here do give a power law distribution of movements, but it is what is found in all markets in this regime.

In contrast, they suggest that the sub one second regime should be associated the the α < 1 phase of the minority game:
Our association of the α < 1 regime with an all-machine phase is consistent with the fact that trading algorithms in the sub-second regime need to be executable extremely quickly and hence be relatively simple, without calling on much memory concerning past information: α < 1 regime with an all-machine phase is consistent with the fact that trading algorithms in the sub-second regime need to be executable extremely quickly and hence be relatively simple, without calling on much memory concerning past information: Hence M will be small, so the total number of strategies will be small and therefore... α < 1. Our model also predicts that the size distribution for the black swans in this ultrafast regime (α < 1) should not have a power law since changes of all sizes do not appear – this is again consistent with the results in Fig. 2.
And...
Our model undergoes a transition around α = 1 to a regime characterized by significant strategy crowding and hence large fluctuations. The price output for α < 1 (Fig. 3, left-hand panel) shows frequent abrupt changes due to agents moving as unintentional groups into particular strategies. Our model therefore predicts a rapidly increasing number of ultrafast black swan events as we move to smaller α and hence smaller subsecond timescales – as observed in our data.
 The authors go on to quantify this transition in a little more detail. In particular, they calculate in the simple minority game model the standard deviation of the price fluctuations. In the regime α < 1 this turns out to be roughly proportional to the number N of agents in the market. In contrast, it goes in proportion only to the square root of N in the α > 1 regime. Hence, the model predicts a sharp increase in the size of market fluctuations when entering the machine dominated phase below one second.

The paper as a whole takes a bit of time to get your head around, but it is, I think, a beautiful example of how a simple model that explores some of the rich dynamics of how strategies interact in a market can give rise to some deep insights. The analysis suggests, first, that the high frequency markets have moved past "the singularity," their dynamics having become fundamentally different -- uncoupled from the control, or at least strong influence, of human trading. It also suggests, second, that the change in dynamics derives directly from the crowding of strategies that operate on very short timescales, this crowding caused by the need for relative simplicity in these strategies.

This kind of analysis really should have some bearing on the consideration of potential new regulations on HFT. But that's another big topic. Quite aside from practical matters, the paper shows how valuable perspectives and toy models like the minority game might be.