Streetwise Professor

June 15, 2015

Always Follow the Price Signals. I Did on Brent-WTI.

Filed under: Commodities,Derivatives,Economics,Energy,Politics,Regulation — The Professor @ 8:18 pm

As a blogger, I am long the option to point out when I call one right. Of course, I am short the option for you all to point out when I call one wrong, but I can’t help it if that option is usually so far out of the money (or if you don’t exercise it when it is in) 😉

I will exercise my option today, after reading this article by Greg Meyer in the FT:

West Texas Intermediate crude, once derided as a broken oil benchmark, is enjoying a comeback.

Volumes of futures tracking the yardstick have averaged 1m contracts a day this year through May, up more than 45 per cent from the same period of 2014, exchange data show. WTI has also sped ahead of volumes in rival Brent crude, less than two years after Brent unseated WTI as the most heavily traded oil futures market.

. . . .

WTI has also regained a more stable connection with global oil prices after suffering glaring discounts because of transport constraints at its delivery point of Cushing, Oklahoma. The gap led some to question WTI as a useful gauge of oil prices.

“I guess the death of the WTI contract was greatly exaggerated,” said Andy Lipow of consultancy Lipow Oil Associates.

But in the past two years, new pipeline capacity of more than 1m barrels a day has relinked Cushing to the US Gulf of Mexico coast, narrowing the discount between Brent and WTI to less than $4 a barrel.

Mark Vonderheide, managing partner of Geneva Energy Markets, a New York trading firm, said: “With WTI once again well connected to the global market, there is renewed interest from hedgers outside the US to trade it. When the spread between WTI and Brent was more than $20 and moving fast, WTI was much more difficult to trade.”

Things have played out exactly as I forecast in August, 2011:

One of the leading crude oil futures contracts–CME Group’s WTI–has been the subject of a drumbeat of criticism for months due to the divergence of WTI prices in Cushing from prices at the Gulf, and from the price of the other main oil benchmark–Brent.  But whereas WTI’s problem is one of logistics that is in the process of being addressed, Brent’s issues are more fundamental ones related to adequate supply, and less amenable to correction.

Indeed, WTI’s “problem” is actually the kind an exchange would like to have.  The divergence between WTI prices in the Midcontinent and waterborne crude prices reflects a surge of production in Canada and North Dakota.  Pipelines are currently lacking to ship this crude to the Gulf of Mexico, and Midcon refineries are running close to full capacity, meaning that the additional supply is backing up in Cushing and depressing prices.

But the yawning gap between the Cushing price at prices at the Gulf is sending a signal that more transportation capacity is needed, and the market is responding with alacrity.  If only the regulators were similarly speedy.

. . . .

Which means that those who are crowing about Brent today, and heaping scorn on WTI, will be begging for WTI’s problems in a few years.  For by then, WTI’s issues will be fixed, and it will be sitting astride a robust flow of oil tightly interconnected with the nexus of world oil trading.  But the Brent contract will be an inverted paper pyramid, resting on a thinner and thinner point of crude production.  There will be gains from trade–large ones–from redesigning the contract, but the difficulties of negotiating an agreement among numerous big players will prove nigh on to impossible to surmount.  Moreover, there will be no single regulator in a single jurisdiction that can bang heads together (for yes, that is needed sometimes) and cajole the parties toward agreement.

So Brent boosters, enjoy your laugh while it lasts.  It won’t last long, and remember, he who laughs last laughs best.

This really wasn’t that hard a call to make. The price signals were obvious, and its always safe to bet on market participants responding to price signals. That’s exactly what happened. The only surprising thing is that so few publicly employed this logic to predict that the disconnection between WTI and ocean borne crude prices would be self-correcting.

Speaking of not enjoying the laugh, the exchange where Brent is traded-ICE-issued a rather churlish statement:

Atlanta-based ICE blamed the shift on “increased volatility in WTI crude oil prices relative to Brent crude oil prices, which drove more trading by non-commercial firms in WTI, as well as increased financial incentive schemes offered by competitors”.

The first part of this statement is rather incomprehensible. Re-linking WTI improved the contract’s effectiveness as a hedge for crude outside the Mid-continent (PADD 2), which allowed hedgers to take advantage of the WTI liquidity pool, which in turn attracted more speculative interest.

Right now the only potential source of disconnect is the export ban. That is, markets corrected the infrastructure bottleneck, but politics has failed to correct the regulatory bottleneck. When that will happen, I am not so foolish to predict.

 

 

 

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June 13, 2015

Definitive Proof That The New York Times’ David Kocieniewski Is A Total Moron*

Filed under: Commodities,Derivatives,Economics,Energy,Politics,Regulation — The Professor @ 6:06 pm

Not that further proof is needed, but still.

You may recall that NYT “reporter” (and by “reporter,” I mean “hack”) David Kocieniewski slimed me on the front page of the NYT on 31 December, 2013. In a nutshell, Kocieniewski accused me of being in the pocket of oil traders, and that this had led me to skew my research and policy positions. Specifically, he insinuated that I opposed position limits and defended speculation in energy markets because I had been suborned by oil traders who profited from high prices, like those that occurred in 2008 (before the crash). Kocieniewski’s main piece of “evidence” was that I had written a white paper sponsored by Trafigura. According to Kocieniewski, as an oil trader, Trafigura benefited from high prices.

At the time I pointed out that this demonstrates Kocieniewski’s appalling ignorance, as Trafigura is not a speculator, and is typically short futures (and other derivatives) to hedge its inventories of oil (and other commodities). Companies like Trafigura have no real interest in the direction of oil prices directly. They make money on margins and volumes. The relationship between these variables and the level of flat prices depends on what makes flat prices high or low.  I further said that if anything, commodity traders are likely to prefer a low price environment because (1) low prices reduce working capital needs, which can be punishing when prices are high, and (2) low price environments often create trading opportunities, in particular storage/contango plays that can be very profitable for those with access to storage assets.

Well, imagine my surprise (not!) when I saw this headline and article:

Crude slide bolsters Trafigura’s profits and trading margins

Trafigura has posted record half-year profits and a doubling of trading margins, illustrating how one of the world’s largest commodity trading houses has been a big beneficiary of the collapse in oil prices.

Profits at the group rose almost 40 per cent in the six months to 31 March, reaching $654m, while margins hit 3.1 per cent, as the Switzerland-based company used its global network of traders and storage facilities to buy cheap crude and take advantage of dislocations in the oil market.

. . . .
It was not the only company to benefit. Other trading groups including Vitol, the largest independent oil trader, and Gunvor have posted strong results for this period. Even Shell, BP and Total managed better-than-expected first quarter results thanks to the performance of muscular trading operations.

Wow. In Kocieniewskiworld, “Crude slide bolsters Trafigura’s profits” would be a metaphysical impossibility. Here on earth, that’s an eminently predictable event. Which I predicted. Not that that makes me a genius, just more knowledgeable about commodity markets than David Kocieniewski (which is a very low bar).

Not that there was ever anything to it in the first place, but this pretty much blows to hell the entire premise of Dim Dave’s story. Proof yet again that if you read the NYT for economics stories, you’ll wind up dumber after reading than before.

* As well as an unethical slug who blatantly violated the NYT’s ethics guidelines. Not that his editor gave a damn, making him as much of an unethical slug as Kocieniewski.

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June 11, 2015

The Ethanol Mandate is Enough to Drive Me to Drink

Filed under: Climate Change,Commodities,Economics,Energy,Politics,Regulation — The Professor @ 6:13 pm

About 19 months ago I wrote about RINsanity, i.e., the United States’ nutty ethanol (and other biofuel) program. RINsanity has long outlived the phenomenon (Lin-sanity) that inspired the neologism. A couple of weeks ago, the EPA announced the ethanol and biodiesel quotas . . . for 2014. Who said time travel is impossible? That Einstein. What an idiot!  (The EPA also announced quotas for 2015 and 2016.)

In a nutshell, despite protestations to the contrary, the EPA largely conceded to the reality of the E10 “blend wall” (the fact that the vast bulk of auto engines are incapable of burning fuel with more than 10 percent ethanol), and announced quotas that were (a) smaller than the market expected, and (b) smaller than the statutory amounts that Congress specified in its farseeing omniscience 10 years ago. At the same time, the EPA decreed larger quotas for biodiesel.

As a result, the market did the splits. The price of ethanol RIN credits that count towards the ethanol quota plunged, while the price of biodiesel RIN credits that count towards the biodiesel quota rose. Scott Irwin and Darrell Good have all the gory details here. (Those are the guys to follow on this issue, folks. I’m just kibitzing.)

As a result, pretty much everyone is upset. The nauseating biofuel lobby is screaming bloody murder because the ethanol quota is too small, and is threatening to go to court. Those holding ethanol credits are fuming due to the forty plus percent price decline.

This all points out the dysfunctional nature of environmental markets in which the supply is set by some opaque politicized bureaucratic process unhinged from economic reality. (The European CO2 credit market is another classic example.) The Congressional mandate set quotas (supplies) years in advance based on forecasts of future fuel demand that turned out to be wildly incorrect. So the EPA played Mr. Fixit, and through some unknown process, divined what Congress meant to do-really!-and announced some surprising numbers that caused prices to plummet.

The EPA’s reaction? It is shocked! Shocked! to find gambling going on at Rick’s (ethanol served here!):

The EPA didn’t intend for the program to create a speculative market, and an agency spokesperson declined to comment on RIN price movement.

“RINs are used to demonstrate compliance under the Renewable Fuel Standard program,” the EPA said. The agency manages an electronic system that tracks the RINs, but not their prices on the open market.

Earth to EPA! Earth to EPA! (And hey-aren’t you supposed to be earth’s stewards? So what are you doing orbiting Pluto?): if you create a scarce resource (ethanol credits) a market-and yes, one with speculation!-will appear. This is inevitable as the sun rising in the east. Another unintended but metaphysically certain event.

Indeed, the kind of speculation that these markets foster is particularly bizarre, because of the necessity of speculating on the feedback between the market and the EPA’s decisions on the amount of the scarce resource it creates. A big part of the RIN prices is market participants’ expectations about what the EPA will decide. If the EPA’s decision takes the market price into account, in some unknown (and almost certainly unarticulated) way, the reasoning chain becomes mind-numbingly complex very quickly. Mr. Market guesses what the EPA will do. That affects prices. The EPA takes the price, and guesses what this says about what the market knows about fundamentals . . . and what the market thinks about what the EPA is going to do. It adjusts its decision accordingly. Market participants have to make judgments about the feedback between the price and the EPA’s decision, which can affect the EPA’s decision, and on and on, ad infinitum. (This is analogous to Keynes’s beauty contest metaphor, and Soros’s theory of market “reflexivity.” Sign of the apocalypse alert: I gave Keynes and Soros a favorable mention in a single blog post.)

That’s no way to run a market, but the alternatives are  likely worse. One alternative would be to set quotas for years far into the future, and then not adjust them based on the evolution of other fundamentals that cannot be foreseen when the quotas are set.

It’s pretty clear that events like have just rocked the biofuel world are an inherent part of the system. Somewhat arbitrary, inherently difficult to predict (in part because they are politicized), and “reflexive” decisions are a major determinant of supply. These decisions are made at discrete times. It is extremely likely that there will be disconnections between the quantity the market thinks the EPA will select and what the EPA actually chooses. Given the inelasticity of demand for energy products, these supply surprises lead to big price impacts.

All of which goes to show that a better use of ethanol is imbibing it to cope with the craziness of a faux market.

Of course it’s not just that the market is crazy: it’s crazy that there is a market. Ethanol is an economic and environmental and humanitarian monstrosity. Yes, ethanol would play a role without subsidies or mandates. But a much smaller role. Forcing and inducing its use is costly, not environmentally beneficial, and raises the price of food, which hits the poorest the hardest. So this crazy market shouldn’t exist in the first place. I think I need another drink.

 

 

 

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June 2, 2015

Hey Elon-Put *OUR* Money Where Your Big Fat Mouth Is

Filed under: Climate Change,Economics,Politics,Regulation — The Professor @ 7:12 pm

In one of my periodic Quixotic moments, I tilted at the Cult of Elon Musk. First, I argued that he or someone manipulated the prices of Tesla and Solar City stocks: I stand by that analysis. Second, I argued that the supposed visionary’s true genius was for feeding lustily at the taxpayer teat.

It is a testament to my great influence that the Cult of Musk has grown only larger in the two years since I made a run at him. But maybe the spell is breaking. For the LA Times just ran a long article detailing just how much his fortune was picked from our pockets. According to the LAT, Musk companies have raked in $4.9 billion in various subsidies and tax breaks, give or take.

That’s 10 figures, people.

That’s bad enough. What’s worse is Musk’s “defense.” It is a farrago of intellectual dishonesty, logical fallacies, condescension, and arrogance.

Musk only replied to the LAT after repeated inquiries, but it is good that the paper persisted. Musk’s rationalizations have to be seen to be believed.

For one thing, he says he doesn’t really need the subsidies:

“If I cared about subsidies, I would have entered the oil and gas industry,” said Musk.

. . . .

“Tesla could be profitable right now if we went into low-growth mode and we just served premium buyers,” he said. “The reason we are not profitable is because we are making massive investments to create an affordable long-range electric car.”

We are making massive investments? What do you mean by “we”, paleface?

So fine. You don’t care about subsidies. You don’t need them.

Then put your money-excuse me, our money-where your big fat mouth is and don’t cash the checks.

The rest of Musk’s defense consists of various incarnations of N wrongs make a right (or, put differently, other people suck at the government teat, why shouldn’t I?):

Musk said the subsidies for Tesla and SolarCity are “a pittance” compared with government support of the oil and gas industry.

“What is remarkable about my companies is that they have been successful despite having such a tiny incentive from the government relative to our competitors,” Musk told The Times.

. . . .

Tesla, Musk said, competes with a mature auto industry that has seen massive federal bailouts for General Motors and Chrysler.

“Tesla and Ford are the only American auto companies not to have gone bankrupt,” Musk said.

SolarCity, he said, is in a nascent industry that must fight entrenched oil and gas interests that have myriad subsidies.

Throwing good money after bad is not good public policy.

Musk cites numerous junk studies to support his case. Some of these are studies of the alleged economic benefits arising from investments in his battery plants, etc. I guarantee, all such studies are garbage based on mythical multipliers and crypto-Keynesian mumbo jumbo. Others are studies of the alleged subsidies of other industries, notably the energy industry. Even taking the numbers at face value, the subsidies of fossil fuels are a pittance on a per BTU or megawatt basis compared to those for renewables. Further, fossil fuels are also heavily taxed directly and indirectly, including by substantial geopolitical and expropriation risks. The study that cites the environmental costs of fossil fuels is particularly susceptible to abuse. And to quote Sonicharm, of the blog Rhymes With Cars and Girls-also not a Musk fan!-all large calculations are wrong.

Elon Musk is a rent seeker masquerading as a visionary. If he is one-tenth the innovator and genius his fawning fans believe him to be he wouldn’t need any subsidies. We should give him the chance to prove it.

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May 15, 2015

No. Trains Are Not Public Goods and Don’t Exploit Tragedy To Claim They Are

Filed under: Economics,Politics,Regulation — The Professor @ 9:39 pm

One of the least savory aspects of human behavior is the tendency to exploit tragedy for personal or political ends. This low tendency was on display in spades in the aftermath of the Amtrak derailment in Philadelphia. Before the bodies of the dead were even cold, pundits and politicians were out in force moaning that the tragedy proved the lamentable decay of American infrastructure, and the lack of government spending on it. Remarkably (or maybe not), the lamentations have continued even after it was revealed that the train had been going more than twice the speed limit, thereby making it highly unlikely that shoddy track or a poorly maintained train was to blame. No tragedy should go to waste, apparently, and the facts shouldn’t get in the way of a politically useful narrative.

There are many examples of the mo’ guvmint types exploiting the deaths of 8 people in Philly, but for 99.9 percent pure, unadulterated stupidity, you have to read this screed by Adam Gopnik* in The New Yorker. Where to begin?

To leverage the Philadelphia tragedy into a justification for more government spending, Gopnik has to claim that railroads, and passenger railroads in particular, are public goods:

And everyone knows that American infrastructure—what used to be called our public works, or just our bridges and railways, once the envy of the world—has now been stripped bare, and is being stripped ever barer.

. . . .

This week’s tragedy also, perhaps, put a stop for a moment to the license for mocking those who use the train—mocking Amtrak’s northeast “corridor” was a standard subject not just for satire, which everyone deserves, but also for sneering, which no one does. For the prejudice against trains is not a prejudice against an élite but against a commonality. The late Tony Judt, who was hardly anyone’s idea of a leftist softy, devoted much of his last, heroic work, written in conditions of near-impossible personal suffering, to the subject of … trains: trains as symbols of the public good, trains as a triumph of the liberal imagination, trains as the “symbol and symptom of modernity,” and modernity at its best. “The railways were the necessary and natural accompaniment to the emergence of civil society,” he wrote. “They are a collective project for individual benefit … something that the market cannot accomplish, except, on its own account of itself, by happy inadvertence. … If we lose the railways we shall not just have lost a valuable practical asset. We shall have acknowledged that we have forgotten how to live collectively.”

Trains take us places together. (You can read good books on them, too.) Every time you ride one, you look outside, and you look inside, and you can’t help but think about the private and the public in a new way.

In point of fact, railroads are not public goods, as defined by economists. Not even close. I get no benefit whatsoever from your trip on a train, or a train that ships a good to you. The benefits of rail travel and rail transport are internalized by the traveler and the consumer of the transported good.

Further, what characterizes public goods is non-exclusivity. If you produce it, I get to consume it too, and you can’t exclude me from doing so. Not true of railroads. You have to buy a ticket to ride.

Meaning that if the value of the service exceeds the cost of providing it, market forces will lead to its provision, in approximately the efficient quantity. Yes, indivisibility and market power issues may lead to some distortions, but the gross under provision that Gopnik and Judt fear will not happen. Period.

Yes, trains take us places together-but they also take us places alone. And we internalize the benefits of the company-or the solitude. You internalize the benefit of the book you read or the view you see: it affects me not one whit.

Given these facts, there is no case here whatsoever for public provision of this service. If Gopnik or Judt get psychic benefits out of other people riding on trains, let them buy them tickets: why enlist the coercive powers of the state to subsidize what they value?

Perhaps-perhaps-there was justification for subsidizing transcontinental rail in the mid-19th century, but even that is doubtful: the success of the James J. Hill’s Great Northern, which received no government land grants,  is a great counterexample. Privately funded rail investment boomed starting in the 1850s, and soon roads criss-crossed the northeast and midwest. Indeed, it is arguable that there was over investment.

Gopnik has a theory why there is not more investment in railroads (underinvestment in his view, in fact). Anti-government libertarian fanatics. (Shhh. No one tell him that the protagonist of Atlas Shrugged runs a railroad.)

The reason we don’t have beautiful new airports and efficient bullet trains is not that we have inadvertently stumbled upon stumbling blocks; it’s that there are considerable numbers of Americans for whom these things are simply symbols of a feared central government, and who would, when they travel, rather sweat in squalor than surrender the money to build a better terminal.

No, actually. It is the fact that the high speed rail projects that so enamor leftists like Gopnik-and Jerry Brown and Obama-are colossal boondoggles that pass no cost benefit test whatsoever, even if you make dreamy assumptions about ridership or the value of carbon allegedly saved.

Consider the California high speed rail project, much beloved by Brown. For $6 billion, the first phase will connect . . . wait for it . . . Merced and Bakersfield.  North Nowhere to South Nowhere. Buck Owens would have been so proud. But it will be a white elephant that California cannot afford, and ironically, will divert resources from other infrastructure that California could definitely use.

If you want to find an era in which investment in rail was truly throttled, go back to the halcyon days of the 60s and 70s, when nearly a century of rate regulation, combined with the rise of air transport and the (government funded) creation of the interstate highway system brought the entire industry into severe financial distress, and drove many famous rail companies to bankruptcy. (It’s an irony, no, that government infrastructure spending undercut the left’s beloved railroads?) Investment in track and rolling stock plummeted, and the industry was truly decrepit. And that was almost completely the result of archaic and inefficient regulation. Government almost killed rail.

The freight industry was reborn starting in 1980, with the passage of the Staggers Act, which deregulated rates. As surely as day follows night, the freight rail industry was revitalized. The profit motive worked wonders. Economic forces were permitted to work, and routes were rationalized, resulting in the closure of uneconomic routes that the government had forced roads to retain. Economically viable routes were expanded.  Innovation, in particular the development of intermodal systems, led to dramatic improvements in efficiency and incredible integration between ocean, rail, and road freight.  The private enterprise that Gopnik and Judt believe cannot possibly lead to good except by accident (“inadvertence”) revived what their beloved government had almost strangled.

Passenger rail did not experience a similar revival, but that too was driven by economics. Rail cannot compete with air on long distance travel, especially when the value of time is considered. For shorter trips, the point-to-point convenience and flexibility that cars offer means that driving typically dominates rail.

Gopnik claims “We all should know that it is bad to have our trains crowded and wildly inefficient—as Michael Tomasky points out, fifty years ago, the train from New York to Washington was much faster than it is now.” We know no such thing. Indeed, the massive subsidies necessary to keep passenger rail operating in the US tell us the exact opposite: that it is economically unviable.

It is beyond funny that liberals consider passenger rail a “symbol and symptom of modernity.” In 1880, maybe. In 2015? Seriously? Now it is an anachronism.

In brief, there is no “plot against trains.” If anything conspires against passenger trains, it is economic reality, and they have survived only by coercing you and me to pay for it. Economic reality is quite congenial to freight rail, and it has thrived as a result, without us being compelled to subsidize it.

Gopnik’s economic illiteracy is annoying, but his supercilious tone and East Coast superiority makes his ignorance almost unbearable: he fits in perfectly at the New Yorker, and personifies the famous cover depicting the view of the US from 9th Avenue. A condescending ignoramus. Not an appealing combination.

In sum, it’s appalling enough that Gopnik, like others, leaped to use the Philadelphia tragedy to advance his pet political cause.  It’s even worse that this pet political cause is economically retarded.

*Gopnik’s name cracks me up, because in Russia the term “gopnik” (гО́пник) refers to lower class street punks known for their drinking, loutish behavior, petty criminality, and stylish dress, usually consisting of Adidas track suits and dress shoes. In other words, гО́пники are pretty much the antithesis of Manhattan prog Adam Gopnik, and no doubt the typical гО́пник would take great pleasure in beating the snot out of the likes of Adam Gopnik.

 

 

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May 5, 2015

Blaming SRO Lapses on For-Profit Status: A Straw Man Dining on Red Herring

Filed under: Commodities,Derivatives,Economics,Regulation — The Professor @ 8:28 pm

The frenzy over the Sarao spoofing indictment has led to the CME Group receiving considerable criticism about the adequacy of its oversight of its markets and trading system. One argument that has been advanced is that the CME’s for-profit status (and the for-profit status of other exchanges) is incompatible with its role as a self-regulatory organization. A piece by Brooke Masters titled “Exchanges Need to Balance Policing and Profitability” in the FT a few days ago puts it this way:

The Sarao case highlights the potential problems with the current US system of relying on “self-regulatory organisations”, including the exchanges, to do much of the frontline policing of markets. They are supposed to make sure traders abide by the rules and refer serious misbehaviour on to government regulators.

This system may have worked when exchanges were owned by their members, but now that they have to generate profits for shareholders, conflicts have emerged. A market that cracks down too hard or too quickly could drive away paying customers. The CME controls the futures market allegedly used by Mr Sarao, but the temptation to go soft could be far greater in areas where trading venues compete.

This is a straw man dining on red herring. The for-profit status of exchanges has little, if anything, to do with the incentives of an exchange to self-regulate. Indeed, for some types of conduct, investor ownership and for-profit status likely improves exchange policing efforts substantially.

I addressed these issues 21 years ago, and then again 15 years ago, in articles published in the Journal of Law and Economics, and 22 years ago in a piece in the Journal of Legal Studies. In the older JLE article, titled “The Self-Regulation of Commodity Exchanges: The Case of Market Manipulation,” I demonstrated incentives are crucial, and for some types of conduct the incentives to police were weak even for non-profit exchanges.

Exchanges (which were organized as non-profits) historically made little effort to combat corners, despite their manifest distorting effects, because the biggest costs of manipulation fell on inframarginal demanders of exchange services (namely, hedgers) or third parties (people who do not trade rely on exchange prices when making decisions), but exchange volume and member profitability depended on the marginal demanders (e.g., speculators) who were little affected. Therefore, exchanges didn’t internalize the cost of corners, so didn’t try very hard to stop them. For-profit exchanges would have faced the same problem.

In other cases, exchanges-be they for profit or non-profit-face strong incentives to police harmful conduct. For instance, securities exchanges have an incentive to reduce insider trading that reduces liquidity and hence raises trading costs leading to lower trading volume. Again, this incentive is largely independent of whether the exchange is for-profit or not-for-profit.

Exchange incentives to police a particular type of deleterious conduct depend crucially on how the costs of that conduct are distributed, and how it affects trading volume and trading costs. The effect on volume and trading costs determines whether and by how much the exchange’s owners (be they shareholders or members) internalize the cost of this conduct. This internalization depends primarily on the type of conduct, not on how the exchange is organized or who owns it or whether the exchange can pay its owners dividends.

In fact, for-profit exchanges have stronger incentives to adopt efficient rules relating to certain kinds of conduct than member-owned, not-for-profit ones. In particular, the members of mutual exchanges were intermediaries; brokers and market makers mainly. The intermediaries’  interests often conflicted with those of exchange users. In particular, self-regulation on member-owned exchanges often took the form of adopting rules and polices that were explicitly intended to benefit their members by restricting competition between them, thereby hurting exchange customers. For instance, member owned exchanges operated commissions cartels for decades: Only forty years ago last Friday (“May Day”) was the NYSE commission cartel that dated from its earliest days dismantled by the SEC. Even after the commission cartels were eliminated, member-owned exchanges adopted other anti-competitive rules that benefited members. Self-regulation was in large part an exercise in cartel management.

Further, powerful members, be they big individual traders or important firms, could often intimidate exchange managers and enforcement personnel. In addition, daily interaction between members contributed to a culture in which screwing a buddy was beyond the pale, but in which many a blind eye was turned when a customer got screwed. Not all the time, but enough, as the FBI sting in ’88-’89 and its aftermath made clear.

So no, there was no Eden of mutual, non-profit exchanges that rigorously enforced rules against abusive trading that was despoiled by the intrusion of the profit-seeking snake. The profit motive was there all along: exchange members were obviously highly profit-driven. It just was manifested in different ways, and not necessarily better ways, than in the current for-profit world.

This also raise the question: just who would own, control, and manage a neo-mutual, non-profit exchange? Big banks, either directly or through their brokerage units? Does anyone think that would solve more problems than it would create? Does anyone honestly believe that there would be fewer conflicts of interest and less potential for abuse in such a setup?

This all gets back to the issue of why exchanges demutualized in the first place. It had zero, zip, nada to do with self-regulation and rule enforcement. It was driven by a seismic technological change. I showed in my 2000 JLE article that non-profit form and mutual ownership economized on transactions costs on floor based exchanges, but were unnecessary in an electronic marketplace. I therefore predicted that exchanges would demutualize and become investor-owned as they shifted from open outcry to electronic trading. That’s exactly what happened over the next several years.

In sum, exchange ownership and organizational form are not the primary or even major determinants of the adequacy of exchange self-policing efforts. The incentives to self-regulate are driven more by economic factors common to both for-profit and not-for-profit exchanges, and the choice of organizational form is driven by transactions cost economizing (including the mitigation of rent seeking) rather than by self-regulatory considerations.  The tension between policing and profit existed even in non-profit exchanges. So those who fret about the adequacy of self-regulation need to get over the idea that going back to the future by re-mutualizing would make a damn bit of difference. If only it were that easy.

 

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April 24, 2015

A Matter of Magnitudes: Making Matterhorn Out of a Molehill

Filed under: Derivatives,Economics,HFT,Politics,Regulation — The Professor @ 10:47 am

The CFTC released its civil complaint in the Sarao case yesterday, along with the affidavit of Cal-Berkeley’s Terrence Hendershott. Hendershott’s report makes for startling reading. Rather than supporting the lurid claims that Sarao’s actions had a large impact on E Mini prices, and indeed contributed to the Flash Crash, the very small price impacts that Hendershott quantifies undermine these claims.

In one analysis, Hendershott calculates the average return in a five second interval following the observation of an order book imbalance. (I have problems with this analysis because it aggregates all orders up to 10 price levels on each side of the book, rather than focusing on away-from-the market orders, but leave that aside for a moment.) For the biggest order imbalances-over 3000 contracts on the sell side, over 5000 on the buy side-the return impact is on the order of .06 basis points. Point zero six basis points. A basis point is one-one-hundredth of a percent, so we are talking about 6 ten-thousandths of one percent. On the day of the Flash Crash, the E Mini was trading around 1165. A .06 basis point return impact therefore translates into a price impact of .007, which is one-thirty-fifth of a tick. And that’s the biggest impact, mind you.

To put the comparison another way, during the Flash Crash, prices plunged about 9 percent, that is, 900 basis points. Hendershott’s biggest measured impact is therefore 4 orders of magnitude smaller than the size of the Crash.

This analysis does not take into account the overall cumulative impact of the entry of an away-from-the market order, nor does it account for the fact that orders can affect prices, prices can affect orders, and orders can affect orders. To address these issues, Hendershott carried out a vector autoregression (VAR) analysis. He estimates the cumulative impact of an order at levels 4-7 of the book, accounting for direct and indirect impacts, through an examination of the impulse response function (IRF) generated by the estimated VAR.* He estimates that the entry of a limit order to sell 1000 contracts at levels 4-7 “has a price impact of roughly .3 basis points.”

Point 3 basis points. Three one-thousandths of one percent. Given a price of 1165, this is a price impact of .035, or about one-seventh of a tick.

Note further that the DOJ, the CFTC, and Hendershott all state that Sarao see-sawed back and forth, turning the algorithm on and off, and that turning off the algorithm caused prices to rebound by approximately the same amount as turning it on caused prices to fall. So, as I conjectured originally, his activity-even based on the government’s theory and evidence-did not bias prices upwards or downwards systematically.

This is directly contrary to the consistent insinuation throughout the criminal and civil complaints that Sarao was driving down prices. For example, the criminal complaint states that during the period of time that Sarao was using the algorithm “the E-Mini price fell by 361 [price] basis points” (which corresponds to a negative return of about 31 basis points). This is two orders of magnitude bigger than the impact calculated based on Hendershott’s .3 return basis point estimate even assuming that the algorithm was working only one way during this interval.

Further, Sarao was buying and selling in about equal quantities. So based on the theory and evidence advanced by the government, Sarao was causing oscillations in the price of a magnitude of a fraction of a tick, even though the complaints repeatedly suggest his algorithm depressed prices. To the extent he made money, he was making it by trading large volumes and earning a small profit on each trade that he might have enhanced slightly by layering, not by having a big unidirectional impact on prices as the government alleges.

The small magnitudes are a big deal, given the way the complaints are written, in particular the insinuations that Sarao helped cause the Flash Crash. The magnitudes of market price movements dwarf the impacts that the CFTC’s own outside expert calculates. And the small magnitudes raise serious questions about the propriety of bringing such serious charges.

Hendershott repeatedly says his results are “statistically significant.” Maybe he should read Deirdre McCloskey’s evisceration of the Cult of Statistical Significance. It’s economic significance that matters, and his results are economically miniscule, compared to the impact alleged. Hendershott has a huge sample size, which can make even trivial economic impacts statistically significant. But it is the economic significance that is relevant. On this, Hendershott is completely silent.

The CFTC complaint has a section labeled “Example of the Layering Algorithm Causing an Artificial Price.” I read with interest, looking for, you know, actual evidence and stuff. There was none. Zero. Zip. There is no analysis of the market price at all. None! This is a piece of the other assertions of price artificiality, including most notably the effect of the activity on the Flash Crash: a series of conclusory statements either backed by no evidence, or evidence (in the form of the Hendershott affidavit) that demonstrates how laughable the assertions are.

CFTC enforcement routinely whines at the burdens it faces proving artificiality, causation and intent in a manipulation case. Here they have taken on a huge burden and are running a serious risk of getting hammered in court. I’ve already addressed the artificiality issue, so consider causation for a moment. If CFTC dares to try to prove that Sarao caused-or even contributed to-the Crash, it will face huge obstacles. Yes, as Chris Clearfield and James Weatherall rightly point out, financial markets are emergent, highly interconnected and tightly coupled. This creates non-linearities: small changes in initial conditions can lead to huge changes in the state of the system. A butterfly flapping its wings in the Amazon can cause a hurricane in the Gulf of Mexico: but tell me, exactly, which of the billions of butterflies in the Amazon caused a particular storm? And note, that it is the nature of these systems that changing the butterfly’s position slightly (or changing the position of other butterflies) can result in a completely different outcome (because such systems are highly sensitive to initial conditions). There were many actors in the markets on 6 May, 2010. Attributing the huge change in the system to the behavior of any one individual is clearly impossible. As a matter of theory, yes, it is possible that given the state of the system on 6 May that activity that Sarao undertook with no adverse consequences on myriad other days caused the market to crash on that particular day when it didn’t on other days: it is metaphysically impossible to prove it. The very nature of emergent orders makes it impossible to reverse engineer the cause out of the effect.

A few additional points.

I continue to be deeply disturbed by the “sample days” concept employed in the complaints and in Hendershott’s analysis. This smacks of cherry picking. Even if one uses a sample, it should be a random one. And yeah, right, it just so happened that the Flash Crash day and the two preceding days turned up in a random sample. Pure chance! This further feeds suspicions of cherry picking, and opportunistic and sensationalist cherry picking at that.

Further, Hendershott (in paragraph 22 of his affidavit) asserts that there was a statistically significant price decline after Sarao turned on the algorithm, and a statistically significant price increase when he turned it off. But he presents no numbers, whereas he does report impacts of non-Sarao-specific activity elsewhere in the affidavit. This is highly suspicious. Is he too embarrassed to report the magnitude? This is a major omission, because it is the impact of Sarao’s activity, not offering away from the market generally, that is at issue here.

Relatedly, why not run a VAR (and the associated IRF) using Sarao’s orders as one of the variables? After all, this is the variable of interest: what we want to know is how Sarao’s orders affected prices. Hendershott is implicitly imposing a restriction, namely, that Sarao’s orders have the same impact as other orders at the same level of the book. But that is testable.

Moreover, Hendershott’s concluding paragraph (paragraph 23) is incredibly weak, and smacks of post hoc, ergo propter hoc reasoning. He insinuates that Sarao contributed to the Crash, but oddly distances himself from responsibility for the claim, throwing it on regulators instead: “The layering algorithm contributed to the overall Order Book imbalances and market conditions that the regulators say led to the liquidity deterioration prior to the Flash Crash.” Uhm, Terrence, you are the expert here: it is incumbent on you to demonstrate that connection, using rigorous empirical methods.

In sum, the criminal and civil complaints make a Matterhorn out of a molehill, and a small molehill at that. And don’t take my word for it: take the “[declaration] under penalty of perjury” of the CFTC’s expert. This is a matter of magnitudes, and magnitudes matter. The CFTC’s own expert estimates very small impacts, and impacts that oscillate up and down with the activation and de-activation of the algorithm.

Yes, Sarao’s conduct was dodgy, clearly, and there is a colorable case that he did engage in spoofing and layering. But the disparity between the impact of his conduct as estimated by the government’s own expert and the legal consequences that could arise from his prosecution is so huge as to be outrageous.

Particularly so since over the years CFTC has responded to acts that have caused huge price distortions, and inflicted losses in nine and ten figures, with all of the situational awareness of Helen Keller. It is as if the enforcers see the world through a fun house mirror that grotesquely magnifies some things, and microscopically shrinks others.

In proceeding as they have, DOJ and the CFTC have set off a feeding frenzy that could have huge regulatory and political impacts that affect the exchanges, the markets, and all market participants. CFTC’s new anti-manipulation authority permits it to sanction reckless conduct. If it was held to that standard, the Sarao prosecution would earn it a long stretch of hard time.

*Hendershott’s affidavit says that Exhibit 4 reports the IRF analysis, but it does not.

 

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April 22, 2015

Spoofing: Scalping Steroids?

Filed under: Derivatives,Economics,Exchanges,HFT,Regulation — The Professor @ 5:35 pm

The complaint against Sarao contains some interesting details. In particular, it reports his profits and quantities traded for nine days.

First, quantities bought and sold are almost always equal. That is characteristic of a scalper.

Second, for six of the days, he earned an average of .63 ticks per round turn. That is about profit that you’d expect a scalper to realize. Due to adverse selection, a market maker typically doesn’t earn the full quoted spread.  On only one of these days is the average profit per round turn more than a tick, and then just barely.

Third, there is one day (4 August, 2011) where he earned a whopping 19.6 ticks per round trip ($4 million profit on 16695 buy/sells). I find that hard to believe.

Fourth, there are two days that the government reports the profit but not the volume. One of these days is 6 May, 2010, the Flash Crash day. I find that omission highly suspicious, given that this is the most important day.

Fifth, I again find it odd, and potentially problematic for the government, that it charges him with fraud, manipulation, and spoofing on only 9 days when he allegedly used the layering strategy on about 250 days. How did the government establish that trading on some days was illegal, and on other days it wasn’t?

The most logical explanation of all this is that Sarao was basically scalping-market making-and if he spoofed, he did so to enhance the profitability of this activity, either by scaring off competition at the inside market, or inducing a greater flow of market orders, or both.

One implication of this is that scalping does not tend to cause prices to move one direction or the other. It is passive, and balances buys and sells. This will present great difficulties in pursuing the manipulation charges, though not the spoofing charges and perhaps not the fraud charges.

 

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Did Spoofing Cause the Flash Crash? Not So Fast!

Filed under: Derivatives,Economics,HFT,Regulation — The Professor @ 12:41 pm

The United States has filed criminal charges against on Navinder Sarao, of London, for manipulation via “spoofing” (in the form of “layering”) and “flashing.” The most attention-grabbing aspect of the complaint is that Sarao engaged in this activity on 6 May, 2010-the day of the Flash Crash. Journalists have run wild with this allegation, concluding that he caused the Crash.

Sarao’s layering strategy involved placement of sell orders at various levels more than two ticks away from the best offer. At his request, “Trading Software Company #1″ (I am dying to know who that would be) created an algorithm implemented in a spreadsheet that would cancel these orders if the inside market got close to these resting offers, and replace them with new orders multiple levels away from the new inside market. The algorithm would also cancel orders if the depth in the book at better prices fell below a certain level. Similarly, if the market moved away from his resting orders, those orders would be cancelled and reenetered at the designated distances from the new inside market level.

The complaint is mystifying on the issue of how Sarao made money (allegedly $40 million dollars between 2010 and 2014). To make money, you need to buy low, sell high (you read it here first!), which requires actual transactions. And although the complaint details how many contracts Sarao traded and how many trades (e.g., 10682 buys totaling 74380 lots and 8959 sells totaling 74380 lots on 5 May, 2010-big numbers), it doesn’t say how the trades were executed and what Sarao’s execution strategy was.

The complaint goes into great detail regarding the allegedly fraudulent orders that were never executed, it is maddeningly vague on the trades that were. It says only:

[W]hile the dynamic layering technique exerted downward pressure on the market SARAO typically executed a series of trades to exploit his own manipulative activity by repeatedly selling futures  only to buy them back at a slightly lower price. Conversely, when the market mved back upward as a result of SARAO’s ceasing the dynamic layering technique, SARAO typically did the opposite, that is he repeatedly bought contracts only to sell them at a slightly higher price.

But how were these buys and sells executed? Market orders? Limit orders? Since crossing the spread is expensive, I seriously doubt he used market orders: even if the strategy drove down both bids and offers, using aggressive orders would have forced Sarao to pay the spread, making it impossible to profit. What was the sequence? The complaint suggests that he sold (bought) after driving the price down (up). This seems weird: it would make more sense to do the reverse.

In previous cases, Moncada and Coscia (well-summarized here), the scheme allegedly worked by placing limit orders on both sides of the market in unbalanced quantities, and see-sawing back and forth. For instance, the schemers would allegedly place a small buy order at the prevailing bid, and then put big away from the market orders on the offer side. Once the schemer’s bid was hit, the contra side orders would be cancelled, and he would then switch sides: entering a sell order at the inside market and large away-from-market buys. This strategy is best seen as a way of earning the spread. Presumably its intent is to increase the likelihood of execution of the at-the-market order by using the big contra orders to induce others with orders at the inside market to cancel or reprice. This allowed the alleged manipulators to earn the spread more often than they would have without using this “artifice.”

But we don’t have that detail in Sarao. The complaint does describe the “flashing” strategy in similar terms as in Moncada and Coscia, (i.e., entering limit orders on both sides of the market) but it does not describe the execution strategy in the layering scheme, which the complaint calls “the most prominent manipulative technique he used.”

If, as I conjecture, he was using something like Moncada and Coscia were alleged to have employed, it is difficult to see how his activities would have caused prices to move systematically one direction or the other as the government alleges. Aggressive orders tend to move the market, and if my conjecture is correct, Sarao was using passive orders. Further, he was buying and selling in almost (and sometimes exactly) equal quantities. Trading involving lots of cancellations plus trades in equal quantities at the bid and offer shares similarities with classic market making strategies. This should not move price systematically one way or the other.

But both with regards to the Flash Crash, and 4 May, 2010, the complaint insinuates that Sarao moved the price down:

As the graph displays, SARAO successfully modified nearly all of his orders to stay between levels 4 and 7 of the sell side of the order book. What is more, Exhibit A shows the overall decline in the market price of the E-Minis during this period.

But on 4 May, Sarao bought and sold the exact same number of contracts (65,015). How did that cause price to decline?

Attributing the Flash Crash to his activity is also highly problematic. It smacks of post hoc, ergo propter hoc reasoning. Or look at it this way. The complaint alleges that Sarao employed the layering strategy about 250 days, meaning that he caused 250 out of the last one flash crashes. I can see the defense strategy. When the government expert is on the stand, the defense will go through every day. “You claim Sarao used layering on this day, correct?” “Yes.” “There was no Flash Crash on that day, was there?” “No.” Repeating this 250 times will make the causal connection between his trading and Flash Clash seem very problematic, at best. Yes, perhaps the market was unduly vulnerable to dislocation in response to layering on 6 May, 2010, and hence his strategy might have been the straw that broke the camels back, but that is a very, very, very hard case to make given the very complex conditions on that day.

There is also the issue of who this conduct harmed. Presumably HFTs were the target. But how did it harm them? If my conjecture about the strategy is correct, it increased the odds that Sarao earned the spread, and reduced the odds that HFTs earned the spread. Alternatively, it might have induced some people (HFTs, or others) to submit market orders that they wouldn’t have submitted otherwise. Further, HFT strategies are dynamic, and HFTs learn. One puzzle is why away from the market orders would be considered informative, particularly if they are used frequently in a fraudulent way (i.e., they do not communicate any information). HFTs mine huge amounts of data to detect patterns. The complaint alleges Sarao engaged in a pronounced pattern of trading that certainly HFTs would have picked up, especially since allegations of layering have been around ever since the markets went electronic. This makes it likely that there was a natural self-correcting mechanism that would tend to undermine the profitability of any manipulative strategy.

There are also some interesting legal issues. The government charges Sarao under the pre-Dodd-Frank Section 7 (anti-manipulation) of the Commodity Exchange Act. Proving this manipulation claim requires proof of price artificiality, causation, and intent. The customized software might make the intent easy to prove in this case. But price artificiality and causation will be real challenges, particularly if Sarao’s strategy was similar to Moncada’s and Coscia’s. Proving causation in the Flash Crash will be particularly challenging, given the complex circumstances of that day, and the fact that the government has already laid the blame elsewhere, namely on the Wardell-Reed trades. Causation and artificiality arguments will also be difficult to make given that the government is charging him only for a handful of days that he used the strategy. One suspects some cherry-picking. Then, of course, there is the issue of whether the statute is Constitutionally vague. Coscia recently lost on that issue, but Radley won on it in Houston. It’s an open question.

I am less familiar with Section 18 fraud claims, or the burden of proof regarding them. Even under my conjecture, it is plausible that HFTs were defrauded from earning the spread, or that some traders paid the spread on trades they wouldn’t have made. But if causation is an element here, there will be challenges. It will require showing how HFTs (or other limit order traders) responded to the spoofing. That won’t be easy, especially since HFTs are unlikely to want to reveal their algorithms.

The spoofing charge is based on the post-Frankendodd CEA, with its lower burden of proof (recklessness not intent, and no necessity of proving an artificial price). That will be easier for the government to make stick. That gives the government considerable leverage. But it is largely unexplored territory: this is almost a case of first impression, or at least it is proceeding in parallel with other cases based on this claim, and so there are no precedents.

There are other issues here, including most notably the role of CME and the CFTC. I will cover those in a future post. Suffice it to say that this will be a complex and challenging case going forward, and the government is going to have to do a lot more explaining before it is possible to understand exactly what Sarao did and the impact he had.

 

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April 11, 2015

The Risks of Clearing Finally Dawn on Tarullo: Better Late Than Never, I Guess

Filed under: Clearing,Derivatives,Economics,Politics,Regulation — The Professor @ 10:11 pm

In October, 2011 I was in a group of academics invited to meet the Board of Governors of the Fed to discuss our research. The theme was network industries, and I was to make a presentation on the network aspects of clearing and its implications for systemic risk.

My most vivid memory of the meeting has little to do with my presentation. Instead, it relates to Ben Bernanke, who sat facing me, directly across the massive boardroom table. Bernanke obviously had a headache. He was rubbing his temples, and he asked a staffer to bring him a cold can of Diet Mountain Dew, which he held against his forehead while closing his eyes. Figuring that a Bernanke headache would portend bad financial news, I was sorely tempted to excuse myself to call my broker to sell the hell out of the S&P.

Sitting next to me was Governor Daniel Tarullo. Truth be told, I was not impressed by his questions, which seemed superficial, or his mien, which was rather brusque, not to say grouchy.

He was definitely not sympathetic to my warning about the potential systemic risks of clearing: he made some skeptical, and in fact dismissive, comments. It was quite evident that he was a believer in clearing mandates.

It appears that Tarullo is still struggling with the idea that CCPs are a risk, but at least he’s open to the possibility:

JPMorgan Chase & Co. and BlackRock Inc. have argued for years that a key response to the last financial crisis could help fuel the next one. [What? No mention of SWP? I was way ahead of them!] Global regulators are starting to heed their warnings.

At issue is the role of clearinghouses — platforms that regulators turned to following the 2008 meltdown to shed more light on the $700 trillion swaps market. A pivotal goal was ensuring that losses at one bank don’t imperil a wide swath of companies, and the broader economy.

Now, Federal Reserve Governor Daniel Tarullo is quizzing Wall Street after big lenders and asset managers said clearinghouses pose their own threats, said three people with knowledge of the discussions who weren’t authorized to speak publicly. Among the concerns raised by financial firms: Relying on clearinghouses shifts risk to just a handful of entities, and the collapse of one could lead to uncapped losses for banks.

. . . .

Tarullo, the Fed’s point man on financial regulation and oversight, has publicly conceded that it’s hard for banks to determine their own market risks if they can’t evaluate how badly they would be hit by the failure of a clearinghouse. It’s “worth considering” whether clearinghouses have enough funds to handle major defaults, he said in a Jan. 30 speech.

Tarullo’s speech is here. Although he is still obviously a clearing fan, at least he is starting to recognize some of the problems. In particular, he acknowledges that it necessary to consider the interaction between CCPs and the broader financial system. Though I must say that since he mentions multilateral netting as the primary reason why CCPs contribute to financial stability, and margins as the second, it’s painfully evident that he doesn’t grasp the fundamental nature of clearing. In the first instance, netting and collateral just redistribute losses, and it is not clear that this redistribution enhances stability. In the second instance, although he acknowledges the problems with margin pro cyclicality, he doesn’t explicitly recognize the strains that large margin flows put on liquidity supply, and the destabilizing effect of these strains.

So it’s a start, but there’s a long way to go.

Tarullo pays most attention to the implications of CCP failure, and to measures to reduce the likelihood of this failure. Yes, failure of a large CCP would be catastrophic, but as I’ve oft written, the measures designed to save them can be catastrophic too.

Tarullo would be well-advised to read this short piece by Michael Beaton, which summarizes many of the issues quite well. The last few paragraphs are worth quoting in full:

In general, I think what we need to take away from all of this is that systemic risk can be transferred – it’s arguable whether or not it can be reduced – but it certainly can’t be eliminated, and the clearing model that we are working towards is a hub and spoke which concentrates risk on a very, very small number of names.

A decentralised network is arguably stronger than a hub and spoke model, mainly because open systems are generally regarded as more robust than closed ones. The latter is what the clearing model operates on and you have that single, glaring point of failure, and there’s really no escape from that.

So, going back to the original questions – do I think the proposals are enough?  I think it goes a long way, but fundamentally I don’t think it will ever resolve the problem of ‘too big to fail’.  I’m just not convinced it’s a problem that is capable of resolution. [Emphasis added.]

Exactly. (The comparison of open vs. closed systems is particularly important.)

Since clearing mandates create their own systemic risks, the Fed, and other central banks, and other macroprudential regulators, must grasp the nettle and determine what central bank support will be extended to CCPs in a crisis. Greenspan extemporized a response in the Crash of ’87, and it worked. But the task will be orders of magnitude greater in the next crisis, given the massively increased scope of clearing. It’s good that Tarullo and the Fed are starting to address these issues, but the mandates are almost 5 years old and too little progress has been made. Faster, please.

 

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