Streetwise Professor

March 27, 2017

Seeing the OTC Derivatives Markets (and the Financial Markets) Like a State

Filed under: Clearing,Derivatives,Economics,Regulation — The Professor @ 12:07 pm

In the years since the financial crisis, and in particular the period preceding and immediately following the passage of Frankendodd, I can’t tell you how many times I saw diagrams that looked like this:



The top diagram is a schematic representation of an OTC derivatives market, with a tangle of bilateral connections between counterparties. The second is a picture of a hub-and-spoke trading network with a CCP serving as the hub. (These particular versions of this comparison are from a 2013 Janet Yellen speech.)

These diagrams came to mind when re-reading James Scott’s Seeing Like a State and his Two Cheers for Anarchism. Scott argues that states have an obsession with making the societies they rule over “legible” in order to make them easier to tax, regulate, and control. States are confounded by evolved complexity and emergent orders: such systems are difficult to comprehend, and what cannot be comprehended cannot be easily ruled. So states attempt to impose schemes to simplify such complex orders. Examples that Scott gives include standardization of language and suppression of dialects; standardization of land tenure, measurements, and property rights; cadastral censuses; population censuses; the imposition of familial names; and urban renewal (e.g., Hausmann’s/Napoleon III’s massive reconstruction of Paris). These things make a populace easier to tax, conscript, and control.

Complex realities of emergent orders are too difficult to map. So states conceive of a mental map that is legible to them, and then impose rules on society to force it to conform with this mental map.

Looking back at the debate over OTC markets generally, and clearing, centralized execution, and trade reporting in particular, it is clear that legislators and regulators (including central banks) found these markets to be illegible. Figures like the first one–which are themselves a greatly simplified representation of OTC reality–were bewildering and disturbing to them. The second figure was much more comprehensible, and much more comforting: not just because they could comprehend it better, but because it gave them the sense that they could impose an order that would be easier to monitor and control. The emergent order was frightening in its wildness: the sense of imposing order and control was deeply comforting.

But as Scott notes, attempts to impose control on emergent orders (which in Scott’s books include both social and natural orders, e.g., forests) themselves carry great risks because although hard to comprehend, these orders evolved the way they did for a reason, and the parts interact in poorly understood–and sometimes completely not understood–ways. Attempts to make reality fit a simple mental map can cause the system to react in unpredicted and unpredictable ways, many of which are perverse.

My criticism of the attempts to “reform” OTC markets was largely predicated on my view that the regulators’ simple mental maps did great violence to complex reality. Even though these “reform” efforts were framed as ways of reducing systemic risk, they were fatally flawed because they were profoundly unsystemic in their understanding of the financial system. My critique focused specifically on the confident assertions based on the diagrams presented above. By focusing only on the OTC derivatives market, and ignoring the myriad connections of this market to other parts of the financial market, regulators could not have possibly comprehended the systemic implications of what they were doing. Indeed, even the portrayal of the OTC market alone was comically simplistic. The fallacy of composition played a role here too: the regulators thought they could reform the system piece-by-piece, without thinking seriously about how these pieces interacted in non-linear ways.

The regulators were guilty of the hubris illustrated beautifully by the parable of Chesterton’s Fence:

In the matter of reforming things, as distinct from deforming them, there is one plain and simple principle; a principle which will probably be called a paradox. There exists in such a case a certain institution or law; let us say, for the sake of simplicity, a fence or gate erected across a road. The more modern type of reformer goes gaily up to it and says, “I don’t see the use of this; let us clear it away.” To which the more intelligent type of reformer will do well to answer: “If you don’t see the use of it, I certainly won’t let you clear it away. Go away and think. Then, when you can come back and tell me that you do see the use of it, I may allow you to destroy it.

In other words, the regulators should have understood the system and why it evolved the way that it did before leaping in to “reform” it. As Chesterton says, such attempts at reformation quite frequently result in deformation.

Somewhat belatedly, there are efforts underway to map the financial system more accurately. The work of Richard Bookstaber and various colleagues under the auspices of the Office of Financial Research to create multilayer maps of the financial system is certainly a vast improvement on the childish stick figure depictions of Janet Yellen, Gary Gensler, Timmy Geithner, Chris Dodd, Barney Frank et al. But even these more sophisticated maps are extreme abstractions, not least because they cannot capture incentives, the distribution of information among myriad market participants, and the motivations and behaviors of these participants. Think of embedding these maps in the most complicated extensive form large-N player game you can imagine, and you might have some inkling of how inadequate any schematic representation of the financial system is likely to be. When you combine this with the fact that in complex systems, even slight changes in initial conditions can result in completely different outcomes, the futility of “seeing like a state” in this context becomes apparent. The map of initial conditions is inevitably crude, making it an unreliable guide to understanding the system’s future behavior.

In my view, Scott goes too far. There is no doubt that some state-driven standardization has dramatically reduced transactions costs and opened up new possibilities for wealth-enhancing exchanges (at some cost, yes, but these costs are almost certainly less than the benefit), but Scott looks askance at virtually all such interventions. Thus, I do not exclude the possibility of true reform. But Scott’s warning about the dangers of forcing complex emergent orders to conform to simplified, “legible”, mental constructs must be taken seriously, and should inform any attempt to intervene in something like the financial system. Alas, this did not happen when legislators and regulators embarked on their crusade to reorganize wholesale the world financial system. It is frightening indeed to contemplate that this crusade was guided by such crude mental maps such as those supposedly illustrating the virtues of moving from an emergent bilateral OTC market to a tamed hub-and-spoke cleared one.

PS. I was very disappointed by this presentation by James Scott. He comes off as a doctrinaire leftist anthropologist (but I repeat myself), which is definitely not the case in his books. Indeed, the juxtaposition of Chesterton and Scott shows how deeply conservative Scott is (in the literal sense of the word).

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  1. 1. GFC
    2. Politician to prudential regulator ‘why didn’t you see this coming on bank balance sheets’.
    3. Regulator ‘OTC derivatives’.
    4. Politician ‘what’s a derivative’.
    5. Regulator explains.
    6. Politician ‘speculation is evil’.
    7. Regulator explains more.
    8. Politician ‘so if you saw these OTC positions the GFC wouldn’t have happened’.
    9. Prudential regulator ‘it couldn’t hurt’.
    10. Politician ‘let’s get trade repositories and central clearing for standardised products’.
    11. Politician and prudential regulator to clearing regulator ‘we think there should be a mandate for central clearing to keep the world safe for banks’.
    12. Clearing regulator ‘WTF’.
    13. Politician ‘it will avoid concentrated positions’.
    14. Clearing regulator ‘you do know what central clearing is right?’.
    15. Politician ‘well I’ll leave you guys to implement the details and I have arranged for securities regulators and central banks from across the globe to join in. Bye.’
    16. Prudential regulator to clearing regulator. ‘I just remembered I don’t like central clearing so I’ll leave you and the others to it.’
    17. Some people call it a crusade.

    Comment by noir — March 28, 2017 @ 7:15 am

  2. The “need” to simplify and control complex systems is intrinsic, human
    behavior. This will never change, regardless of the potential benefits
    of doing so. The greater the complexity, the greater the need.

    Comment by eric — March 28, 2017 @ 8:14 pm

  3. You forgot the exclamation point. It’s supposed to be Timmy!

    Comment by Howard Roark — March 28, 2017 @ 8:22 pm

  4. @Howard-Thanks for reminding me! He is not missed!

    The ProfessorComment by The Professor — March 29, 2017 @ 10:43 am

  5. From the point of view of an aerospace engineer: Any critical system on a commercial aircraft must have dissimilar redundancies in multiple locations. Even in that environment, which is as predictable and controllable as could be imagined, a central hub (or a small number of functionally-identical hubs with exposure to each other) would not be allowed by… drum-roll please… the aviation regulator!

    Things must be bad in the financial markets when the FAA’s regulations start to look sensible and relaxed by comparison.

    Comment by Hiberno Frog — March 30, 2017 @ 8:18 am

  6. Vlad:

    Thx for the laugh, Hiberno Frog.
    FAA’s Mission Statement: “WE aren’t happy. Until YOU’re not happy.”

    Safe travels.

    VP VVP

    Comment by VP Vlad — March 30, 2017 @ 12:36 pm

  7. “The fallacy of composition played a role here too: the regulators thought they could reform the system piece-by-piece, without thinking seriously about how these pieces interacted in non-linear ways.”

    Amen!!!!! one of the things that no regulator has seemed to understand is that OTC derivatives can be tailored to reduce or at least transfer basis risk: using “standardized” products by definition will not allow this where the risk to be hedged cannot be made to fit
    the standard offerings. This means that an additional cost is incurred by would be hedgers who otherwise either are willing or must transfer their risks to third parties. Now they are stuck with inappropriate instruments! Way to GO Timmmy! et al.

    Comment by Sotos — March 30, 2017 @ 12:44 pm

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