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A report published this week by the so-called senior supervisors group of bank regulators says that risk management failures were a common shortcoming of banks that got into trouble in the current financial crisis. In particular, it says that value-at-risk measures and stress-testing did not treat appropriately the basis between cash bonds and credit derivatives. For example, the report notes, some firms that had big problems assumed they could apply the low historical return volatility of corporate credits rated triple A to the senior tranches of CDOs.
It also criticises some banks for expanding their CDO of ABS business rapidly and building up large warehouses of super senior positions in these deals. In particular, it says, some banks did not consider that these positions might be riskier than their credit ratings indicated.
In the leveraged loan business, the report criticises banks for failing to account for the price risk inherent in their pipeline of leveraged lending commitments. "Some firms did not consider the importance of marking pipeline positions to market but treated them more like loans and valued them at or close to par," write the report's authors.
The report summarises its key observations and conclusions by saying that the banks entered the turmoil in relatively sound financial condition and generally with capital well above regulatory requirements, but says that the prolonged disruption in market liquidity stressed most firm's liquidity and capital.


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Unfortunately regulators were proved to be simply commentators in this crisis: While some of their comments are accurate ex-post, their function is to regulate the ongoing functions of banks, not simply comment on their past deeds. They contributed to the crisis like absent parents contribute to their offspring's misbehavior.
With all due respect, the regulators once again are showing how little they understand the business. As the first commentator highlights, regulators are the ones who have put ratings at the top of the regulatory framework (Basle II). Additionally, there is no question that the basis was assumed to mimic the historic low volatility of the past -- as that was the only thing they had to look at (and besides VaR, which relies on historic voaltiliity and price transparency also forces people into this mindset). When will the regulators realize they have much responsibility to bear (along with the bankers)?
while hindsight is 20/20, i think the regulator is right to point out the above failures - banks definitely didnt mark positions to reflect the above risks appropriately. what's worse is that there was a lot of p&l booked which resulted from positions that were not appriopriately reserved against. This p&l resulted in big bonuses and a illusion that certain businesses/trades were profitable when they weren't
You can see that the regulators haven't got a clue why the banking system got into this mess. They are still saying that banks had enough capital going into the crisis (er, no they didn't). So what is their assessment of what went wrong? Banks relied too much on ratings they say. But guess what? The Basel 2 rules that they are now pushing increase that dependence on ratings.