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	<title>Comments on: Concise Explanation with Blame Assigned</title>
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	<description>Believe nothing, no matter where you read it, or who said it, unless it agrees with your own reason and your own common sense.</description>
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		<title>By: Charlie</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-2271</link>
		<dc:creator>Charlie</dc:creator>
		<pubDate>Wed, 18 Mar 2009 14:25:34 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-2271</guid>
		<description><![CDATA[Bill, seriously, I think you should get your own blog.  You&#039;re writing these long comments on a six month old post on an obscure blog I haven&#039;t been able to even update much because of illness.  I&#039;ll be happy to help you find an appropriate set up, but you&#039;re not even having a conversation with &lt;em&gt;me&lt;/em&gt; because the of the same illness.]]></description>
		<content:encoded><![CDATA[<p>Bill, seriously, I think you should get your own blog.  You&#8217;re writing these long comments on a six month old post on an obscure blog I haven&#8217;t been able to even update much because of illness.  I&#8217;ll be happy to help you find an appropriate set up, but you&#8217;re not even having a conversation with <em>me</em> because the of the same illness.</p>
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		<title>By: billshaw</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-2269</link>
		<dc:creator>billshaw</dc:creator>
		<pubDate>Sun, 08 Mar 2009 02:54:59 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-2269</guid>
		<description><![CDATA[The Federal Reserve Board:   Countrywide and others were given an open door to engage in exploitive and deceptive business practices by the conduct – or rather the omissions -- of the Federal Reserve Board.  It is rather as if the Fed was expecting A (highly ethical conduct by a deregulated financial market) while rewarding B (exploitive and deceptive practices).  The Fed kept interest rates at a historically low level and declined, until July, 2008, to exercise its authority to prohibit abusive, unfair, and deceptive practices.  In a world led by an ideology of deregulation, House Banking Committee Chairman Jim Leach (R-Iowa) asked “. . . is the Federal Reserve AWOL?” 
Wall Street:  Investment banks and private equity funds facilitated questionable business practices by exhibiting a thirst for highly rated mortgage-backed obligations (MBOs).   The AAA stamp of approval gave these institutions the opportunity to borrow freely with nominal amounts held in reserve.  A 30 - 1 debt/equity ratio which prevalent during the period 2004-06 gave Wall Street an abundance of cash to purchase more MBOs.  
Triple A ratings, one would think, would be hard to come by.  Instruments of that degree of security require fewer assets to be held in reserve.  As it turns out, the gatekeepers of these ratings – Moody’s, Standard &amp; Poor’s, Fitch were in the pay of Wall Street bankers who thrived on leverage.  If a 30 – 1 ratio was good, wouldn’t 40 – 1 be better?  The fee between the rating agencies and the bankers was held in abeyance until the securities were sold, and the sale of mortgage-backed securities was facilitated by a AAA stamp of approval.  Hence, 80% of the pooled mortgages (the securitized debt obligations) were labeled AAA.
This abundance of Wall Street cash primed the pump for Countrywide, New Century, and Ameriquest.  The loan officers of these firms, and independent loan brokers, received bonuses for inducing borrowers into mortgages that were riskier than they could have qualified for otherwise.  This is called the yield-spread premium (YSP), a practice still unregulated by the Fed.  
Brokers and loan offices could maximize their bonuses by including a pre-payment penalty.  These clauses were typically high enough to discourage or prevent refinancing.  Before the housing bubble burst, however, neither the pre-payment penalty nor increased future payments on adjustable rate mortgages (ARMs) inhibited sub-prime financing.  Borrowers who were concerned with increased payments would be told not to worry, they could always refinance.  Following the downturn, efforts to work out terms amenable to the economic realities of many borrowers did not make a great deal of headway at Countrywide.    However, as recently as March 5, 2009, the House passed a measure that would give bankruptcy judges the power to adjust some mortgages.  It remains to be seen how this measure will fare in the Senate, but, if it becomes law, mortgage-holders (holders of mortgage-backed securities) may be more willing to enter voluntary re-negotiations.  
The Rating Agencies (Fitch, S&amp;P, Moody’s):  It is the role of credit rating agencies to evaluate the market worth of investment instruments, and to do it objectively.  The objectivity of this process has been a matter of contention since the program’s inception.  After all, the ratings are done on a fee basis, so the possibility of pressure being exerted by the client is a matter that calls for transparency.   That issue has, of course, been exacerbated by the onset of the current recession.  
The web sites of each of these firms acknowledge the potential for such conflicts, and link the reader with the firm’s efforts to put the matter to rest.  For example:
&quot;The real question is not whether there are potential conflicts of interest in the &#039;issuer pays&#039; model, but whether they can be effectively managed. Mr. Erik Sirri, director of the SEC’s Division of Market Regulations, last year testified at a congressional hearing that the conflicts raised by this long-standing business model are indeed manageable. Taken together, we believe these measures provide robust safeguards against the potential conflict of interest inherent in the “issuer pays&#039; model.&quot; 
Despite these efforts, some questions regarding the objectivity of these rating have not been laid to rest.  Email exchanges between employees of these rating agencies indicate that some insiders suspected that the standards were too easily gamed, and that this would lead to bigger problems down the line.  A 2006 Standard &amp; Poor’s email raised questions about the impact of its ratings on mortgage-backed securities and credit default swaps:  “Let’s hope we are all wealthy and retired by the time this house of cards falters.” 
American International Group (AIG):  Mortgage-back securities held by troubled banks were given AAA ratings by Moody&#039;s, S&amp;P, and Fitch. The AAA ratings were supported by the additional protection of credit default insurance (credit default swaps).  These were being issued by AIG, the world’s largest insurance company.  Unlike the highly regulated insurance industry which includes AIG’s traditional line of business, the market in swaps is unregulated. Based on the strength of AIG&#039;s AAA rated balance sheet and the AAA rating granted to the bonds by the rating agencies, it was widely believed that there was almost no risk that the AAA rated bonds would default. 
Banks were required to set aside virtually no capital reserves against AAA holdings. Consequently, banks could add assets and leverage to their balance sheets without the burden of committing more regulatory capital. This arrangement was favorable to other regulated entities, including foreign banks, and led to a highly levered, tightly inter-related global financial system. 
The American International Group (AIG) reported 62 billion in losses in 4th quarter, 2008.  That’s largest quarterly loss posted by any firm ever.  Greed, or an abysmal failure of judgment?
“Greed is Good” according to Gordon Gekko, played by Michael Douglas in the 1987 Oscar-winning film “Wall Street.”  But Gekko broke the law and paid a price.  AIG didn’t break the law.  It gamed the system.  Everything it did was legal and in plain sight.  Since it was to-big-to-fail, the essence of a moral hazard, the federal government (proxy for U.S. taxpayers) stepped in and bought approximately 80% of its stock.  The price, or the price so far, is $150 billion, but there is something like another $100 billion in debt in the wings if the housing market doesn’t stabilize.  The AIG stock price, by the way, is 42 cents a share.  
How did this happen under the nose of U.S. regulators?  Simple.  There are no regulations in the game AIG played.  
AIG’s history as an enormously profitable and well-run firm gained it a AAA rating from the most prominent agencies – Fitch, S&amp;P, Moody’s.  Lured by large fees, AIG used its rating to bless securitized debt, i.e., mortgage-backed securities that had been pooled and sold to investment banks and private equity funds.  These firms would in turn use these mortgage-backed securities to borrow still more money to invest in . . . mortgage-backed securities.  
The strategy was fool-proof, but only if the housing market continued strong and on the up-turn.  That didn’t happen of course.  The reason the market crashed was the weigh of billions of dollars in “toxic” mortgages.  These mortgages stemmed from Countrywide-like firms that “forced” sub-prime mortgages on borrowers who were by no means able to make the scheduled repayments.  Since housing prices were assumed to be on a strong upward surge, borrowers were told that if they defaulted, then the mortgage could simply be re-negotiated.  After all, with housing prices on the upswing, the appreciation in home values would easily underwrite the debt.  
Securitized debt instruments were created by dividing the pooled mortgages into tiers, or stanches.   Actually, these are “mixed bags.”  The strongest tiers carrying the fewest toxic instruments, the second tier with more, and the bottom tier loaded with toxic, sub-prime mortgages.    The demand for these securitized debt instruments was so high that Countrywide and other mortgage brokers went scurrying to create more and paid handsome bonuses to employees and associates for brokering more deals.  
AIG enters the picture, not by issuing securitized debt, but by selling derivatives called credit default swaps (CDS).  These derivatives (CDS) lent AIG’s AAA rating to instruments that were built on a house of cards, that is, built in large part on toxic mortgages.  Derivatives are instruments that bring in fees -- high fees -- and will be paid off if such conditions are met.  In this case, the conditions provided for AIG to pay its customer if the securitized debt instruments that were being “insured” went below a cretain point.    
Insured is not quite the right word because state regulated insurance law requires a certain amount in reserves be set aside in the event the terms of a policy are triggered – fire, flood, accident, death.  Credit default swaps, however, are not regulated.  That meant AIG was not required to set aside any amount to support its obligations in the event of a housing down turn.  But for an additional fee, AIG would agree to put up collateral if it, or if the securitized debt it was backing up, received a rating down grade.]]></description>
		<content:encoded><![CDATA[<p>The Federal Reserve Board:   Countrywide and others were given an open door to engage in exploitive and deceptive business practices by the conduct – or rather the omissions &#8212; of the Federal Reserve Board.  It is rather as if the Fed was expecting A (highly ethical conduct by a deregulated financial market) while rewarding B (exploitive and deceptive practices).  The Fed kept interest rates at a historically low level and declined, until July, 2008, to exercise its authority to prohibit abusive, unfair, and deceptive practices.  In a world led by an ideology of deregulation, House Banking Committee Chairman Jim Leach (R-Iowa) asked “. . . is the Federal Reserve AWOL?”<br />
Wall Street:  Investment banks and private equity funds facilitated questionable business practices by exhibiting a thirst for highly rated mortgage-backed obligations (MBOs).   The AAA stamp of approval gave these institutions the opportunity to borrow freely with nominal amounts held in reserve.  A 30 &#8211; 1 debt/equity ratio which prevalent during the period 2004-06 gave Wall Street an abundance of cash to purchase more MBOs.<br />
Triple A ratings, one would think, would be hard to come by.  Instruments of that degree of security require fewer assets to be held in reserve.  As it turns out, the gatekeepers of these ratings – Moody’s, Standard &amp; Poor’s, Fitch were in the pay of Wall Street bankers who thrived on leverage.  If a 30 – 1 ratio was good, wouldn’t 40 – 1 be better?  The fee between the rating agencies and the bankers was held in abeyance until the securities were sold, and the sale of mortgage-backed securities was facilitated by a AAA stamp of approval.  Hence, 80% of the pooled mortgages (the securitized debt obligations) were labeled AAA.<br />
This abundance of Wall Street cash primed the pump for Countrywide, New Century, and Ameriquest.  The loan officers of these firms, and independent loan brokers, received bonuses for inducing borrowers into mortgages that were riskier than they could have qualified for otherwise.  This is called the yield-spread premium (YSP), a practice still unregulated by the Fed.<br />
Brokers and loan offices could maximize their bonuses by including a pre-payment penalty.  These clauses were typically high enough to discourage or prevent refinancing.  Before the housing bubble burst, however, neither the pre-payment penalty nor increased future payments on adjustable rate mortgages (ARMs) inhibited sub-prime financing.  Borrowers who were concerned with increased payments would be told not to worry, they could always refinance.  Following the downturn, efforts to work out terms amenable to the economic realities of many borrowers did not make a great deal of headway at Countrywide.    However, as recently as March 5, 2009, the House passed a measure that would give bankruptcy judges the power to adjust some mortgages.  It remains to be seen how this measure will fare in the Senate, but, if it becomes law, mortgage-holders (holders of mortgage-backed securities) may be more willing to enter voluntary re-negotiations.<br />
The Rating Agencies (Fitch, S&amp;P, Moody’s):  It is the role of credit rating agencies to evaluate the market worth of investment instruments, and to do it objectively.  The objectivity of this process has been a matter of contention since the program’s inception.  After all, the ratings are done on a fee basis, so the possibility of pressure being exerted by the client is a matter that calls for transparency.   That issue has, of course, been exacerbated by the onset of the current recession.<br />
The web sites of each of these firms acknowledge the potential for such conflicts, and link the reader with the firm’s efforts to put the matter to rest.  For example:<br />
&#8220;The real question is not whether there are potential conflicts of interest in the &#8216;issuer pays&#8217; model, but whether they can be effectively managed. Mr. Erik Sirri, director of the SEC’s Division of Market Regulations, last year testified at a congressional hearing that the conflicts raised by this long-standing business model are indeed manageable. Taken together, we believe these measures provide robust safeguards against the potential conflict of interest inherent in the “issuer pays&#8217; model.&#8221;<br />
Despite these efforts, some questions regarding the objectivity of these rating have not been laid to rest.  Email exchanges between employees of these rating agencies indicate that some insiders suspected that the standards were too easily gamed, and that this would lead to bigger problems down the line.  A 2006 Standard &amp; Poor’s email raised questions about the impact of its ratings on mortgage-backed securities and credit default swaps:  “Let’s hope we are all wealthy and retired by the time this house of cards falters.”<br />
American International Group (AIG):  Mortgage-back securities held by troubled banks were given AAA ratings by Moody&#8217;s, S&amp;P, and Fitch. The AAA ratings were supported by the additional protection of credit default insurance (credit default swaps).  These were being issued by AIG, the world’s largest insurance company.  Unlike the highly regulated insurance industry which includes AIG’s traditional line of business, the market in swaps is unregulated. Based on the strength of AIG&#8217;s AAA rated balance sheet and the AAA rating granted to the bonds by the rating agencies, it was widely believed that there was almost no risk that the AAA rated bonds would default.<br />
Banks were required to set aside virtually no capital reserves against AAA holdings. Consequently, banks could add assets and leverage to their balance sheets without the burden of committing more regulatory capital. This arrangement was favorable to other regulated entities, including foreign banks, and led to a highly levered, tightly inter-related global financial system.<br />
The American International Group (AIG) reported 62 billion in losses in 4th quarter, 2008.  That’s largest quarterly loss posted by any firm ever.  Greed, or an abysmal failure of judgment?<br />
“Greed is Good” according to Gordon Gekko, played by Michael Douglas in the 1987 Oscar-winning film “Wall Street.”  But Gekko broke the law and paid a price.  AIG didn’t break the law.  It gamed the system.  Everything it did was legal and in plain sight.  Since it was to-big-to-fail, the essence of a moral hazard, the federal government (proxy for U.S. taxpayers) stepped in and bought approximately 80% of its stock.  The price, or the price so far, is $150 billion, but there is something like another $100 billion in debt in the wings if the housing market doesn’t stabilize.  The AIG stock price, by the way, is 42 cents a share.<br />
How did this happen under the nose of U.S. regulators?  Simple.  There are no regulations in the game AIG played.<br />
AIG’s history as an enormously profitable and well-run firm gained it a AAA rating from the most prominent agencies – Fitch, S&amp;P, Moody’s.  Lured by large fees, AIG used its rating to bless securitized debt, i.e., mortgage-backed securities that had been pooled and sold to investment banks and private equity funds.  These firms would in turn use these mortgage-backed securities to borrow still more money to invest in . . . mortgage-backed securities.<br />
The strategy was fool-proof, but only if the housing market continued strong and on the up-turn.  That didn’t happen of course.  The reason the market crashed was the weigh of billions of dollars in “toxic” mortgages.  These mortgages stemmed from Countrywide-like firms that “forced” sub-prime mortgages on borrowers who were by no means able to make the scheduled repayments.  Since housing prices were assumed to be on a strong upward surge, borrowers were told that if they defaulted, then the mortgage could simply be re-negotiated.  After all, with housing prices on the upswing, the appreciation in home values would easily underwrite the debt.<br />
Securitized debt instruments were created by dividing the pooled mortgages into tiers, or stanches.   Actually, these are “mixed bags.”  The strongest tiers carrying the fewest toxic instruments, the second tier with more, and the bottom tier loaded with toxic, sub-prime mortgages.    The demand for these securitized debt instruments was so high that Countrywide and other mortgage brokers went scurrying to create more and paid handsome bonuses to employees and associates for brokering more deals.<br />
AIG enters the picture, not by issuing securitized debt, but by selling derivatives called credit default swaps (CDS).  These derivatives (CDS) lent AIG’s AAA rating to instruments that were built on a house of cards, that is, built in large part on toxic mortgages.  Derivatives are instruments that bring in fees &#8212; high fees &#8212; and will be paid off if such conditions are met.  In this case, the conditions provided for AIG to pay its customer if the securitized debt instruments that were being “insured” went below a cretain point.<br />
Insured is not quite the right word because state regulated insurance law requires a certain amount in reserves be set aside in the event the terms of a policy are triggered – fire, flood, accident, death.  Credit default swaps, however, are not regulated.  That meant AIG was not required to set aside any amount to support its obligations in the event of a housing down turn.  But for an additional fee, AIG would agree to put up collateral if it, or if the securitized debt it was backing up, received a rating down grade.</p>
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		<title>By: billshaw</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-2268</link>
		<dc:creator>billshaw</dc:creator>
		<pubDate>Wed, 04 Mar 2009 15:36:18 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-2268</guid>
		<description><![CDATA[Quite frequently, pundits will find the origin of the problem as far back as the Carter administration that advanced the Community Redevelopment Act (CRA), and that banks were pressured into making sub-prime loans.  The principal focus of the Act, however,  was to eliminate “red-lining,” the practice of many lending institutions of refusing to finance businesses and housing in certain urban areas.  These were typically minority and impoverished areas.  

Were banks pressured into making sub-prime loans?  The pressure banks have been subjected to evidently stems from the long-standing principle that insured depository institutions must serve “the convenience and needs” of the communities in which they are chartered to do business.  This includes meeting the credit needs of that community.   The Bank Holding Company Act (1956) required the FRB, when reaching decisions on proposed acquisitions by banks or bank holding companies, to evaluate how well they were involved in meeting community needs, consistent with the requirements of safety and soundness.   This is the basis for the arguments of some critics that the CRA obligation is the quid pro quo for privileged access to federal deposit insurance and access to the Fed’s discount window.]]></description>
		<content:encoded><![CDATA[<p>Quite frequently, pundits will find the origin of the problem as far back as the Carter administration that advanced the Community Redevelopment Act (CRA), and that banks were pressured into making sub-prime loans.  The principal focus of the Act, however,  was to eliminate “red-lining,” the practice of many lending institutions of refusing to finance businesses and housing in certain urban areas.  These were typically minority and impoverished areas.  </p>
<p>Were banks pressured into making sub-prime loans?  The pressure banks have been subjected to evidently stems from the long-standing principle that insured depository institutions must serve “the convenience and needs” of the communities in which they are chartered to do business.  This includes meeting the credit needs of that community.   The Bank Holding Company Act (1956) required the FRB, when reaching decisions on proposed acquisitions by banks or bank holding companies, to evaluate how well they were involved in meeting community needs, consistent with the requirements of safety and soundness.   This is the basis for the arguments of some critics that the CRA obligation is the quid pro quo for privileged access to federal deposit insurance and access to the Fed’s discount window.</p>
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		<title>By: Charlie</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-2267</link>
		<dc:creator>Charlie</dc:creator>
		<pubDate>Mon, 02 Mar 2009 01:34:43 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-2267</guid>
		<description><![CDATA[Good lord, Bill, it&#039;s been six months since this was posted.  how&#039;d you even happen upon it?

Re the 1977 CRA: doesn&#039;t matter.  The effect was to increase the risk while forbidding banks to modify interest rates.

Re the 1995 amendments: I don&#039;t recall noticing that there was a constitutional amendment allowing the Congress to pass things over Clinton&#039;s objections.  In any case, check the legislative history: it was proposed by Clinton.

Re cronies: there is plenty of other information on this if you care to look around.  Some names you might start with are Gorelick, Raines, Emanuel, Rubin -- the people who got rich in the private sector having left the Clinton administration.

Re lobbying: nope, but it&#039;s well documented who received by far the *most* lobbying money on banking issues: Schumer, Kerry, Clinton, and Obama are four of the top five.

On mark to market: the &quot;true net worth&quot; issue is the problem.  In the middle of a panic, when some companies have been forced to sell at fire sale prices, FAS 157 fores their on-paper net worth down, very probably artificially.  Why is that more the true net worth than any other?

If I sounded protective of the rating agencies, it wasn&#039;t my intention: they clearly didn&#039;t do a good job either of understanding the securitized stuff or of evaluating the risk.

As far as the losses that killed AIG, nope, wasn&#039;t the taxpayers fault at all.  But one of the things I learned in first aid class was they you stop the bleeding first, and then inquire into the cause of the accident.

If you want to convince me that Phil Gramm had much to do with it, you&#039;re going to need to tell me what regulation was removed; it&#039;s unclear Glass-Steagall changes had much to do with it.

On Cox, look at the date again; in September it wasn&#039;t much less clear what happened and how much the SEC had to do with it.

And on the eighteen times issue, the names you&#039;re looking for are &quot;Barney Frank&quot; and &quot;Chris Dodd.&quot;  Contrary to what a lot of people apparently think, having a small majority in Congress doesn&#039;t lead to the ability to force Congress to pass anything you want.  Hell, as Obama is finding out, even a &lt;i&gt;large&lt;/i&gt; majority doesn&#039;t always mean you get what you want.]]></description>
		<content:encoded><![CDATA[<p>Good lord, Bill, it&#8217;s been six months since this was posted.  how&#8217;d you even happen upon it?</p>
<p>Re the 1977 CRA: doesn&#8217;t matter.  The effect was to increase the risk while forbidding banks to modify interest rates.</p>
<p>Re the 1995 amendments: I don&#8217;t recall noticing that there was a constitutional amendment allowing the Congress to pass things over Clinton&#8217;s objections.  In any case, check the legislative history: it was proposed by Clinton.</p>
<p>Re cronies: there is plenty of other information on this if you care to look around.  Some names you might start with are Gorelick, Raines, Emanuel, Rubin &#8212; the people who got rich in the private sector having left the Clinton administration.</p>
<p>Re lobbying: nope, but it&#8217;s well documented who received by far the *most* lobbying money on banking issues: Schumer, Kerry, Clinton, and Obama are four of the top five.</p>
<p>On mark to market: the &#8220;true net worth&#8221; issue is the problem.  In the middle of a panic, when some companies have been forced to sell at fire sale prices, FAS 157 fores their on-paper net worth down, very probably artificially.  Why is that more the true net worth than any other?</p>
<p>If I sounded protective of the rating agencies, it wasn&#8217;t my intention: they clearly didn&#8217;t do a good job either of understanding the securitized stuff or of evaluating the risk.</p>
<p>As far as the losses that killed AIG, nope, wasn&#8217;t the taxpayers fault at all.  But one of the things I learned in first aid class was they you stop the bleeding first, and then inquire into the cause of the accident.</p>
<p>If you want to convince me that Phil Gramm had much to do with it, you&#8217;re going to need to tell me what regulation was removed; it&#8217;s unclear Glass-Steagall changes had much to do with it.</p>
<p>On Cox, look at the date again; in September it wasn&#8217;t much less clear what happened and how much the SEC had to do with it.</p>
<p>And on the eighteen times issue, the names you&#8217;re looking for are &#8220;Barney Frank&#8221; and &#8220;Chris Dodd.&#8221;  Contrary to what a lot of people apparently think, having a small majority in Congress doesn&#8217;t lead to the ability to force Congress to pass anything you want.  Hell, as Obama is finding out, even a <i>large</i> majority doesn&#8217;t always mean you get what you want.</p>
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		<title>By: billshaw</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-2266</link>
		<dc:creator>billshaw</dc:creator>
		<pubDate>Mon, 02 Mar 2009 01:06:56 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-2266</guid>
		<description><![CDATA[Concise Explanation with Blame Assigned.  
There&#039;s a great deal of bias in the attempt above to explain the financial meltdown.  It has been repeated mindlessly that banks were &quot;forced&quot; into making subprime loans.  No one, however, speaks with any knowledge of these forced loans, or cites statutes/bank regs, or any other authority.  Where are the details?  Someone is trying to make us believe that a bank charter will be revoked unless the institution makes a certain percentage of sub-prime loans.  That&#039;s lazy talk and just plain wrong.  

The 1977 CRA was designed to prevent financial institutions from totally ignoring applicants from certain &quot;red lined&quot; areas.  It was an effort to eliminate blanket racial discrimination.  

The 1995 amendments to CRA were passed after the Newt Gingrich take-over of Congress and after the Republican Congress shut the government down.  The writer of the &quot;Concise Explanatsion&quot;  comment may have misplaced that bit of information.  

Political cronies footnote -- Who are those people?  Are we supposed to guess?

Lobbying -- Are we to believe that only Democrats received lobby money.  Ever heard of Abramoff?  Randy Cunningham?  What about Bob Ney, Republican-Ohio doing 30 month prison time for Abramoff.  What about Tom Delay&#039;s forced resignation for ethics violations.  Ted Stevens, Republican-Alaska.  Heard of him? 

Mark-to-Market accounting only requires securities to be recorded at their current value.  A lot of people think that assets should maintain their &quot;book&quot; values until the market comes back in a few years, but any professional financial examiner could see through that.  Example:  If your house has lost $50,000 in value, but you keep your job and  hold on, it will probably come back and maybe exceed that.  But financial institutions are not like that.  They have to meet their reserve requirements, and their portfolio of securities as simply marked to their market value.  Otherwise their true net worth would be misstated.  

Don&#039;t be protective of credit rating agencies -- Fitch, S&amp;P, Moody&#039;s.  First of all, they decline to answer my inquiries regarding their connection to investment firms .  They are, after all, compensated by Wall Street for their servicies.  Their is some possibility they were pressured into giving AAA ratings to securitized debt obligations when they knew the risk was much higher.

Sure, very many firms found themselves strapped when they became liable on the derivatives (credit default swaps).  AIG, the big insurer, certainly ought to have known better.  All of them were greedily raking in the profits before the bubble went pop.   Whoes fault was that?  Not the taxpayers?

Some people like to say that even the higher-ups in investment banking and hedge firms didn&#039;t really understand the complexities of these newly invented financial instruments.  Heck with that.  They&#039;re the ones who invented those things.  They were making money, and either assumed the bubble would never bust, or that they would get out with their fortune/reputation before the disaster.  

The writer of &quot;Concise Explanation&quot; obviously has an ax to grind with nothing but hot air to back up his arguments.  If you are looking to place the blame, you have to mention Robert Rubin, Clinton&#039;s Secretary of Treasury, Clinton, George W.  If W warned of the problem 18 times as &quot;C.Ex&quot; claims, why didn&#039;t he do something?  He had a Republican Congress for 6 years that ate out of his hand.    You can also put former Senator Phil Gramm (Mr. Deregulation), Alan Greenspan, and Christopher Cox (Bush&#039;s SEC chief) on the blame list.]]></description>
		<content:encoded><![CDATA[<p>Concise Explanation with Blame Assigned.<br />
There&#8217;s a great deal of bias in the attempt above to explain the financial meltdown.  It has been repeated mindlessly that banks were &#8220;forced&#8221; into making subprime loans.  No one, however, speaks with any knowledge of these forced loans, or cites statutes/bank regs, or any other authority.  Where are the details?  Someone is trying to make us believe that a bank charter will be revoked unless the institution makes a certain percentage of sub-prime loans.  That&#8217;s lazy talk and just plain wrong.  </p>
<p>The 1977 CRA was designed to prevent financial institutions from totally ignoring applicants from certain &#8220;red lined&#8221; areas.  It was an effort to eliminate blanket racial discrimination.  </p>
<p>The 1995 amendments to CRA were passed after the Newt Gingrich take-over of Congress and after the Republican Congress shut the government down.  The writer of the &#8220;Concise Explanatsion&#8221;  comment may have misplaced that bit of information.  </p>
<p>Political cronies footnote &#8212; Who are those people?  Are we supposed to guess?</p>
<p>Lobbying &#8212; Are we to believe that only Democrats received lobby money.  Ever heard of Abramoff?  Randy Cunningham?  What about Bob Ney, Republican-Ohio doing 30 month prison time for Abramoff.  What about Tom Delay&#8217;s forced resignation for ethics violations.  Ted Stevens, Republican-Alaska.  Heard of him? </p>
<p>Mark-to-Market accounting only requires securities to be recorded at their current value.  A lot of people think that assets should maintain their &#8220;book&#8221; values until the market comes back in a few years, but any professional financial examiner could see through that.  Example:  If your house has lost $50,000 in value, but you keep your job and  hold on, it will probably come back and maybe exceed that.  But financial institutions are not like that.  They have to meet their reserve requirements, and their portfolio of securities as simply marked to their market value.  Otherwise their true net worth would be misstated.  </p>
<p>Don&#8217;t be protective of credit rating agencies &#8212; Fitch, S&amp;P, Moody&#8217;s.  First of all, they decline to answer my inquiries regarding their connection to investment firms .  They are, after all, compensated by Wall Street for their servicies.  Their is some possibility they were pressured into giving AAA ratings to securitized debt obligations when they knew the risk was much higher.</p>
<p>Sure, very many firms found themselves strapped when they became liable on the derivatives (credit default swaps).  AIG, the big insurer, certainly ought to have known better.  All of them were greedily raking in the profits before the bubble went pop.   Whoes fault was that?  Not the taxpayers?</p>
<p>Some people like to say that even the higher-ups in investment banking and hedge firms didn&#8217;t really understand the complexities of these newly invented financial instruments.  Heck with that.  They&#8217;re the ones who invented those things.  They were making money, and either assumed the bubble would never bust, or that they would get out with their fortune/reputation before the disaster.  </p>
<p>The writer of &#8220;Concise Explanation&#8221; obviously has an ax to grind with nothing but hot air to back up his arguments.  If you are looking to place the blame, you have to mention Robert Rubin, Clinton&#8217;s Secretary of Treasury, Clinton, George W.  If W warned of the problem 18 times as &#8220;C.Ex&#8221; claims, why didn&#8217;t he do something?  He had a Republican Congress for 6 years that ate out of his hand.    You can also put former Senator Phil Gramm (Mr. Deregulation), Alan Greenspan, and Christopher Cox (Bush&#8217;s SEC chief) on the blame list.</p>
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		<title>By: Help with developing my thesis - AFboard</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-1701</link>
		<dc:creator>Help with developing my thesis - AFboard</dc:creator>
		<pubDate>Sun, 12 Oct 2008 18:34:26 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-1701</guid>
		<description><![CDATA[[...] Little tidbit showing how Credit Swaps do not tell which entities may be insolvent. This may in turn cause Moody or other agencies to erroneously upgrade or not lowering its creditworthiness.     Concise Explanation with Blame Assigned &#124; Explorations [...]]]></description>
		<content:encoded><![CDATA[<p>[...] Little tidbit showing how Credit Swaps do not tell which entities may be insolvent. This may in turn cause Moody or other agencies to erroneously upgrade or not lowering its creditworthiness.     Concise Explanation with Blame Assigned | Explorations [...]</p>
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		<title>By: NTW</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-1574</link>
		<dc:creator>NTW</dc:creator>
		<pubDate>Thu, 02 Oct 2008 12:06:25 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-1574</guid>
		<description><![CDATA[Shellbell, I should say that Charlie&#039;s narrative of events makes a lot of sense to me. Mostly, I see some question marks about the right counterfactuals (always a problem in assessing causality without a true experiment) and about some specific numbers--how mortgages break between GSE-guaranteed ones and purely private ones.

Here&#039;s another interesting article this morning:

http://online.wsj.com/article/SB122291076983796813.html#

Hubbard and Mayer have actual research credentials in academic economics. This is the first extensive proposal for stabilizing the housing market that I&#039;ve seen offered by such people.

It also has some numbers. They claim that the Feds now control 90% of the mortgage market. Does that mean that the GSEs were holding 90% of U.S. mortgage paper when they went into conservatorship? Or that they back 90% of all outstanding mortgages?

I&#039;m just asking. I would really like to know what the relevant numbers are. Without that, it is hard to know how to assign responsibility between the private and public sectors here.]]></description>
		<content:encoded><![CDATA[<p>Shellbell, I should say that Charlie&#8217;s narrative of events makes a lot of sense to me. Mostly, I see some question marks about the right counterfactuals (always a problem in assessing causality without a true experiment) and about some specific numbers&#8211;how mortgages break between GSE-guaranteed ones and purely private ones.</p>
<p>Here&#8217;s another interesting article this morning:</p>
<p><a href="http://online.wsj.com/article/SB122291076983796813.html#" rel="nofollow">http://online.wsj.com/article/SB122291076983796813.html#</a></p>
<p>Hubbard and Mayer have actual research credentials in academic economics. This is the first extensive proposal for stabilizing the housing market that I&#8217;ve seen offered by such people.</p>
<p>It also has some numbers. They claim that the Feds now control 90% of the mortgage market. Does that mean that the GSEs were holding 90% of U.S. mortgage paper when they went into conservatorship? Or that they back 90% of all outstanding mortgages?</p>
<p>I&#8217;m just asking. I would really like to know what the relevant numbers are. Without that, it is hard to know how to assign responsibility between the private and public sectors here.</p>
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		<title>By: Charlie</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-1573</link>
		<dc:creator>Charlie</dc:creator>
		<pubDate>Thu, 02 Oct 2008 03:39:43 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-1573</guid>
		<description><![CDATA[&lt;em&gt;The Act was passed in 1977, are you telling me the subprime lending wave that hit from 2004-2007 was because of a 1977 law? That doesn’t mathmatically nor logically make since.&lt;/em&gt;

True, but then I didn&#039;t say that, either.  You really need to be careful with those straw men.  What I said was that, starting with the CRA in 1977, we started to force banks to make higher risk loans at the same interest rates as lower-risk loans.  As NTW points out, changes in 1995 increased the problem; some, um, &lt;em&gt;aggressive&lt;/em&gt; accounting at Fannie and Freddie, plus political pressure to increase the number and proportion of those loans, increased it even more.

&lt;i&gt;...blame of the recession on the CRA&lt;/i&gt;

Sheli, if you think I&#039;m blaming a recession on the CRA, you&#039;ve misread.  But this more limited notion --- that the CRA and other market distortions led to the issue of higher risk mortgages --- isn&#039;t even controversial.  In fact that was a stated purpose of the law: to ensure that people who were a greater credit risk, didn&#039;t have a large downpayment, or were buying in high risk areas got loans anyway.  These are, almost by definition, higher risk loans.

The structure of things built up to share the risk of these higher risk mortgages, along with the fairly draconian mark-to-market instantly rules from FAS 157, together set up the dominoes for this current issue, which may lead to a recession.

NTW, there&#039;s nothing magic about 20 percent down.  It does mean that someone has more skin in the game and more to lose in a default.  But the trade of risk and cost doesn&#039;t have some magic special value at 20 percent down; &lt;i&gt;if&lt;/i&gt; a zero-down loan is at an appropriate interest rate, and it fits your level of risk tolerance, there&#039;s no reason not to write one.]]></description>
		<content:encoded><![CDATA[<p><em>The Act was passed in 1977, are you telling me the subprime lending wave that hit from 2004-2007 was because of a 1977 law? That doesn’t mathmatically nor logically make since.</em></p>
<p>True, but then I didn&#8217;t say that, either.  You really need to be careful with those straw men.  What I said was that, starting with the CRA in 1977, we started to force banks to make higher risk loans at the same interest rates as lower-risk loans.  As NTW points out, changes in 1995 increased the problem; some, um, <em>aggressive</em> accounting at Fannie and Freddie, plus political pressure to increase the number and proportion of those loans, increased it even more.</p>
<p><i>&#8230;blame of the recession on the CRA</i></p>
<p>Sheli, if you think I&#8217;m blaming a recession on the CRA, you&#8217;ve misread.  But this more limited notion &#8212; that the CRA and other market distortions led to the issue of higher risk mortgages &#8212; isn&#8217;t even controversial.  In fact that was a stated purpose of the law: to ensure that people who were a greater credit risk, didn&#8217;t have a large downpayment, or were buying in high risk areas got loans anyway.  These are, almost by definition, higher risk loans.</p>
<p>The structure of things built up to share the risk of these higher risk mortgages, along with the fairly draconian mark-to-market instantly rules from FAS 157, together set up the dominoes for this current issue, which may lead to a recession.</p>
<p>NTW, there&#8217;s nothing magic about 20 percent down.  It does mean that someone has more skin in the game and more to lose in a default.  But the trade of risk and cost doesn&#8217;t have some magic special value at 20 percent down; <i>if</i> a zero-down loan is at an appropriate interest rate, and it fits your level of risk tolerance, there&#8217;s no reason not to write one.</p>
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		<title>By: NTW</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-1572</link>
		<dc:creator>NTW</dc:creator>
		<pubDate>Thu, 02 Oct 2008 00:00:14 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-1572</guid>
		<description><![CDATA[I would add: Is &quot;20% down or no loan&quot; one of Kipling&#039;s Copybook Headings? ;)]]></description>
		<content:encoded><![CDATA[<p>I would add: Is &#8220;20% down or no loan&#8221; one of Kipling&#8217;s Copybook Headings? ;)</p>
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		<title>By: NTW</title>
		<link>http://explorations.chasrmartin.com/2008/09/30/concise-explanation-with-blame-assigned/comment-page-1/#comment-1571</link>
		<dc:creator>NTW</dc:creator>
		<pubDate>Wed, 01 Oct 2008 23:56:11 +0000</pubDate>
		<guid isPermaLink="false">http://explorations.chasrmartin.com/?p=979#comment-1571</guid>
		<description><![CDATA[Here&#039;s a somewhat different angle on the &quot;bad social learning&quot; idea by Malanga over at Real Clear Markets. I don&#039;t necessarily agree with his punchline, but I wasn&#039;t aware of the effort (through the Boston Fed) to convince banks that the received customs and wisdom about credit worthiness were wrong. Interesting.

http://www.realclearmarkets.com/articles/2008/10/the_long_road_to_slack_lending.html]]></description>
		<content:encoded><![CDATA[<p>Here&#8217;s a somewhat different angle on the &#8220;bad social learning&#8221; idea by Malanga over at Real Clear Markets. I don&#8217;t necessarily agree with his punchline, but I wasn&#8217;t aware of the effort (through the Boston Fed) to convince banks that the received customs and wisdom about credit worthiness were wrong. Interesting.</p>
<p><a href="http://www.realclearmarkets.com/articles/2008/10/the_long_road_to_slack_lending.html" rel="nofollow">http://www.realclearmarkets.com/articles/2008/10/the_long_road_to_slack_lending.html</a></p>
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