CVA - a business driver for breaking down asset silos

Xenomorph's analytics partner Numerix sponsored a PRMIA event at New York's Harvard Club this week on Credit Valuation Adjustment (CVA). The event also involved Microsoft, with a surprisingly relevant contribution to the evening on CVA and "Big Data" (I still don't feel comfortable losing the quotes yet, maybe soon...). Credit Valuation Adjustment seems to be the hot topic in risk management and pricing at the moment, with Numerix's competitor Quantifi having held another PRMIA event on CVA only a few months back. 

The event started with an introduction to CVA from Aletta Ely of JP Morgan Chase. Aletta started by defining CVA as the market value of counterparty credit risk. I am new to CVA as a topic, and my own experience on any kind of adjustment in valuation for instrument was back at JP Morgan in the mid-90s (those of you under 30 are allowed to start yawning at this point...). We used to maintain separate risk-free curves (what are they now?) and counterparty spread curves, which would be combined to discount the cashflows in the model.

Whilst such an adjustment could be calibrated to come up with an adjusted valuation which would be better than having no counterparty risk modelled at all, it seems one of the key aspects of how CVA differs is that a credit valuation adjustement needs to be done in the context of the whole portfolio of exposures to the counterparty, and not in isolation instrument by instrument. The fact that a trader in equity derivatives was long exposure to a counterparty cannot be looked at in isolation from a short exposure to a portfolio of swaps with the same counterparty on the fixed income desk.

Put another way, CVA only has context if we stand to lose money if our counterparty defaults, and so an aggregated approach is needed to calculate the size of the positive exposures to the counterparty over the lifetime of the portfolio. Also, given this one sided payoff aspect of the CVA calculation, then instrument types such as vanilla interest rate swaps suddenly move from being relatively simple instrument that can be priced off a single curve to instruments that needed optionality to be modelled for the purposes of CVA.

So why has CVA become such a hot topic at the banks? Prior to the 2008/2009 crisis CVA was already around (credit risk has existed for a long time I guess, regardless of whether you regulate or report to it), but given that bank credit spreads were at that time consistently low and stable then CVA had minimal effects on valuations and P&L. Obviously with the advent of Lehmans then this changed, and CVA has been pushed into prominence since it has directly affected P&L in a significant manner for many institutions (for example see these FT articles on Citi and JPMorgan)

A key and I think positive point for the whole industry is the CVA requires a completely multi-asset view, and given regulatory focus on CVA and capital adequacy then as a result it will drive banks away from a siloed approach to data and valuation management. If capital is scarcer and more costly, then banks will invest in understanding both their aggregate CVA and the incremental contribution to CVA of a new trade in the context of all exposures to the counterparty. Looking at incremental CVA, then you can also see that this also drives investment into real or near-realtime CVA calculation, which brings me on to the next talks of the evening by Numerix on CVA calculation methods and a surprisingly good presentation on CVA and "Big Data" from David Cox of Microsoft.

Denny Yu of Numerix did a good job of explaining some of the methods of calculating CVA, and in addition to being cross asset and all the implications that requires for having the ability to price anything, CVA is both data and computationally expensive. It requires both simulation of the scenarios for the default of counterparties through time, but also the valuation of cross-asset portfolios at different points in time. Denny mentioned techniques such as American Monte-Carlo to reduce the computation needed through using the same simulation paths for both default scenarios and valuation.

So on to Microsoft. I have seen some appalling presentations on "Big Data" recently, mainly from the larger software and hardware companies try to jump on the marketing band wagon (main marketing premise: the data problems you have are "Big"...enough said I hope). Surprisingly, David Cox of Microsoft gave a very good presentation around the computation challenges of CVA, and how technologies such as Hadoop take the computational power closer to the data that needs acting on, bringing the analytics and data together. (As an aside, his presentation was notably "Metro" GUI in style, something that seems to work well for PowerPoint where the slide is very visual and it puts more emphasis on the speak to overlay the information). David was obviously keen to talk up some of the cloud technology that Microsoft is currently pushing, but he knew the CVA business topic well and did a good job of telling a good story around CVA, "Big Data" and Cloud technologies. Fundamentally, his pitch was for banks and other institutions to become "Analytic Enterprises" with a common, scaleable and flexible infrastructure for data management and analysis. 

In summary it was a great event - the Harvard Club is always worth a visit (bars and grandiose portraits as expected but also barber shop in the basement and squash courts in the loft!), the wine afterwards was tolerably good and the speakers were informative without over-selling their products or company. Quick thank you to Henry Hu of IBM for transportation on the night, and thanks also to Henry for sending through this link to a great introductory paper on CVA and credit risk from King's College London. Whilst the title of the King's paper is a bit long and scary, it takes the form of dialogue between a new employee and a CVA expert, and as such is very readable with lots of background links.

 

 

 

PRMIA - From Risk Measurement to Risk Management by Samuel Won

I attended the PRMIA event last night "Risk Year in Review" at Moody's New York offices. It was a good event, but by far the most interesting topic of the evening for me was from Samuel Won, who gave a talk about some of the best and most innovative risk management techniques being used in the market today. Sam said that he was inspired to do this after reading the book "The Information" by James Gleik about the history of information and its current exponential growth. Below are some of the notes I took on Sam's talk, please accept my apologies in advance for any errors but hopefully the main themes are accurate.

Early '80s ALM - Sam gave some context to risk management as a profession through his own personal experiences. He started work in the early 80's at a supra-regional bank, managing interest rate risk on a long portfolio of mortgages. These were the days before the role of "risk manager" was formally defined, and really revolved around Asset and Liability Management (ALM).

Savings and Loans Crisis - Sam then changed roles and had some first hand experience in sorting out the Savings and Loans crisis of the mid '80s. In this role he become more experienced with products such as mortgage backed securities, and more familiar with some of the more data intensive processes needed to manage such products in order to account for such factors such as prepayment risk, convexity and cashflow mapping.

The Front Office of the '90s - In the '90s he worked in the front office at a couple of tier one investment banks, where the role was more of optimal allocation of available balance sheet rather than "risk management" in the traditional sense. In order to do this better, Sam approached the head of trading for budget to improve and systemise this balance sheet allocation but was questioned as to why he needed budget when the central Risk Control department had a large staff and large budget already.

Eventually, he successfully argued the case that Risk Control were involved in risk measurement and control, whereas what he wanted to implement was active decision support to improve P&L and reduce risk. He was given a total budget of just $5M (small for a big bank) and told to get on with it. These two themes of implementing active decision support (not just risk measurement) and have a profit motive driving better risk management ran through the rest of his talk.

A Datawarehouse for End-Users Too - With a small team and a small budget, Sam made use of postgraduate students to leverage what his team could develop. They had seen that (at the time) getting systems talking to each other was costly and unproductive, and decided as a result to implement a datawarehouse for the front office, implementing data normalisation and data scrubbing, with data dashboard over the top that was easy enough for business users to do data mining. Sam made the point that useability was key in allowing the business people to extract full value from the solution.

Sam said that the techniques used by his team and the developers were not necessarily that new, things like regression and correlation analysis were used at first. These were used to establish key variables/factors, with a view to establish key risk and investment triggers in as near to real-time as possible. The expense of all of this development work was justified through its effects on P&L which given its success resulting in more funding from the business.

Poor Sell-Side Risk Innovation - Sam has seen the most innovative risk techniques being used on the buy-side and was disappointed by the lack of innovation in risk management at the banks. He listed the following sell-side problems for risk innovation:

• politically driven requirements, not economically driven
• arbitrary increases in capital levels required is not a rigorous approach
• no need for decision analysis with risk processes
• just passing a test mentality
• just do the marginal work needed to meet the new rules
• no P&L justification driving risk management

Features of Innovative Approaches - Sam said that he had noted a few key features of some of the initiatives he admired at some of the asset managers:

1. Based on a sophisticated data warehouse (not usually Oracle or Sybase, but Microsoft and other databases used - maybe driven by ease of use or cost maybe?)
2. Traders/Portfolio Managers are the people using the system and implementing it, not the technical staff.
3. Dedicated teams within the trading division to support this, so not relying on central data team.

A Forward-Looking Risk Model Example - The typical output from such decision analysis systems he found was in the form of scenarios for users to consider. A specific example was a portfolio manager involved in event-driven long-short equity strategies around mergers and acquisitions. The manager is interested in the risk that a particular deal breaks, and in this case techniques such as Value at Risk (VaR) do not work, since the arbitrage usually requires going long the company being acquired and short the acquiror (VaR would indicate little risk in this long-short case). The manager implemented a forward looking model that was based on information relevant to the deal in question plus information from similar historic deals. The probabilities used in the model where gathered from a range of sources, and techniques such as triangulation where used to verify the probabilities. Sam views that forward-looking models to assist in decision support are real risk management, as opposed to the backward-looking risk measurement models implemented at banks to support regulatory reporting.

Summary - Sam was a great speaker, and for a change it was refreshing to not have presentation slides backing up what the speaker was saying. His thoughts on forward looking models being true risk management and moving away from risk measurement seem to echo those of Ricardo Rebanato of a few years back at RiskMinds (see post). I think his thoughts on P&L motivation being the only way that risk management advances are correct, although I think there is a lot of risk innovation at the banks but at a trading desk level and not at the firm-wide level which is caught up in regulation - the trading desks know that capital is scarce and are wanting to use it better. I think this siloed risk management flies in the face of much of the firm-wide risk management and indeed firm-wide data management talked about in the industry, and potentially still shows that we have a long way to go in getting innovation and forward looking risk management at a firm level, particularly when it is dominated by regulatory requirements. However, having a truly integrated risk data platform is something of a hobby-horse for me, I think it is the foundation for answering all of the regulatory and risk requirementst to come, whatever their form. Finally, I could not agree more easy analysis for end-users is a vital part of data management for risk, allowing business users to do risk management better. Too many times IT is focussed on systems that require more IT involvement, when the IT investment and focus should be on systems that enable business users (trading, risk, compliance) to do more for themselves. Data management for risk is key area for improvement in the industry, where many risk management sytem vendors assume that the world of data they require is perfect. Ask any risk manager - the world of data is not perfect and manual data validation continues to be a task that takes time away from actually doing risk management.

PRMIA on Data and Analytics

Final presentation at the PRMIA event yesterday was by Clifford Rossi and was entitled "The Brave New World of Data & Analytics Following the Crisis: A Risk Manager's Perspective".

Clifford got his presentation going with a humorous and self-depricating start by suggesting that his past employment history could in fact be the missing "leading indicator" for predicting orgnisations in crisis, having worked at CitiGroup, WaMu, Countrywide, Freddie Mac and Fannie Mae. One of the other professors present said that he didn't do the same to academia (University of Maryland beware maybe!).

Clifford said that the crisis had laid bare the inadequacy and underinvestment in data and risk technology in the financial services sector. He suggested that the OFR had the potential to be a game changer in correcting this issue and in helping the role of CRO to gain in stature.

He gave an example of a project at one of the GSEs he had worked at called "Project Enterprise" which was to replace 40 year old mainframe based systems (systems that for instance only had 3 digits to identify a transaction). He said that he noted that this project had recently been killed, having cost around $500M. With history like this, it is not surprising that enterpring risk data warehousing capabilities were viewed as black holes without much payoff prior to the crisis. In fact it was only due to Basel that data management projects in risk received any attention from senior management in his view.

During the recent stress test process (SCAP) the regulators found just how woeful these systems were as the banks struggled to produce the scenario results in a timely manner. Clifford said that many banks struggled to produce a consistent view of risk even for one asset type, and that in many cases, corporate acquisitions had exascerbated this lack of consistency in obtaining accurate, timely exposure data. He said that the mortgage processing fiasco showed the inadequacy of these types of systems (echoing something I heard at another event about mortgage tagging information being completely "free-fromat", without even designated fields for "City" and "State" for instance)

Data integrity was another key issue that Clifford discussed, here talking about the lack of historical performance data leading to myopia in dealing with new products and poor defintions of product leading to risk assessments based on the originator rather than on the characteristics of the product. (side note: I remember prior to the crisis the credit derivatives department at one UK bank requisitioning all new server hardware to price new CDO squared deals given it was supposedly so profitable, it was at that point that maybe I should have known something was brewing...) Clifford also outlined some further data challenges, such as the changing statistical relationship between Debt to Income ratio and mortgage defaults once incomes were self-declared on mortgages.

Moving on to consider analytics and models, Clifford outlined a lot of the concerns covered by the Modeller's Manifesto, such as the lack of qualitative judgement and over-reliance on the quantitative, efficiency and automation superceding risk management, limited capability to stress test on a regular basis, regime change, poor model validation, and cognitive biases reinforced by backward-looking statistical analysis. He made the additional point that in relation to the OFR, they should concentrate on getting good data in place before spending resource on building models.

In terms of focus going forward, Clifford said the liquidity, counterparty and credit risk management were not well understood. Possibly echoing Ricardo Rebonato's ideas, he suggested that leading indicators need to be integrated into risk modelling to provide the early warning systems we need. He advocated that the was more to do on integrating risk views across lines of business, counterparties and between the banking and trading book.

Whilst being a proponent of the OFRs potential to mandate better Analytics and data management, he warned (sensibly in my view) that we should not think that the solution to future crises is simply to set up a massive data collection and Modelling entity (see earlier post on the proposed ECB data utility)

Clifford thinks that Dodd-Frank has the potential to do for the CRO role what Sarbanes-Oxley did in elevating the CFO role. He wants risk managers to take the opportunity presented in this post-crisis period to lead the way in promoting good judgement based on sound management of data and Analytics. He warned that senior management buy-in to risk management was essential and could be forced through by regulatory edict.

This last and closing point is where I think where the role of risk management (as opposed to risk reporting) faces it's biggest challenge, in that how can a risk manager be supported in preventing a senior business manager from seeking a overly risky new business opportunity based on what "might" happen in the future - we human beings don't think about uncertainty very clearly and the lack of a resulting negative outcome will be seen by many to invalidate the concerns put forward before a decision was made. Risk management will become known as the "business prevention" department and not regarded as the key role it should be.

More formal management of instrument valuation needed

Xenomorph has today released its white paper “Instrument Valuation Management: management of derivative and fixed income valuations in a multi-asset, multi-model, multi-datasource and multi-timeframe environment”.

The white paper expands on the “Rates, Curves and Surfaces – Golden Copy Management of Complex Datasets” white paper Xenomorph published recently (see earlier post) and describes how, despite the increasing importance of instrument valuation to investment, trading and risk management decisions, valuation management is not yet formally and fully addressed within data management strategies and remains a big concern for financial institutions.

Too often, says Xenomorph, valuations (and the analytics used to process input and calculate output data) fall between traditional data management providers and pricing model vendors. This leads to the over–use of tactical desktop spreadsheets where data “escapes” the control of the data management system, leading to an increased operational risk.

Whilst instrument valuation is certainly not the primary cause of the recent financial crisis, the lack of high quality, transparent valuations of many complex securities resulted in market uncertainty and in the failure of many risk models fed by untrustworthy valuations.

“A deeper understanding of financial products reduces operational risk and promotes quality, consistency and auditability, ensuring regulatory compliance”, says Brian Sentance, CEO Xenomorph. “Clients’ requirements have evolved and portfolio managers, traders and risk managers recognize that it is no longer sufficient to treat valuation as an external, black-box process offered by pricing service providers”, he adds.

Nowadays, regulators, auditors, clients and investors demand even more drill-down to the underlying details of an instrument’s valuation. It is therefore important to implement an integrated, consistent analytics and data management strategy which cuts across different departments and glues together reference and market data, pricing and analytics models, for transparent, high quality, independent valuation management.

“Our TimeScape solution provides a valuation environment which offers rapid and timely support for even the most complex instruments, allowing our clients to check easily the external valuation numbers, based on their choice of model and data providers”, says Sentance. “Otherwise, what is the point of good data management if the valuations and the analytics used are not based on the same data management infrastructure principles?”

For those who are interested, the white paper is available here.

 

Rates, curves and derived data management remains a neglected area following the crisis

Xenomorph has released its white paper 'Rates, Curves and Surfaces – Golden Copy Management of Complex Datasets'. The white paper describes how, despite the increasing interest in risk management and tighter regulations following the crisis, the management of complex datasets – such as prices, rates, curves and surfaces - remains an underrated issue in the industry. One that can undermine the effectiveness of an enterprise-wide data management strategy.

In the wake of the crisis, siloed data management, poor data quality, lack of audit trail and transparency have become some of the most talked about topics in financial markets. People have started looking at new approaches to tackle the data quality issue that found many companies unprepared after Lehman Brothers' collapse. Regulators – both nationally and internationally – strive hard to dictate parameters and guidelines.

In light of this, there seems to be a general consensus on the need for financial institutions to implement data management projects that are able to integrate both market and reference data. However, whilst having a good data management strategy in place is vital, the industry also needs to recognize the importance of model and derived data management.

Rates, curves and derived data management is too often a neglected function within financial institutions. What is the point of having an excellent data management infrastructure for reference and market data if ultimately instrument valuations and risk reports are run off spreadsheets using ad-hoc sources of data?

In this evolving environment, financial institutions are becoming aware of the implications of a poor risk management strategy but are still finding it difficult to overcome the political resistance across departments to implementing centralised standard datasets for valuations and risk.

The principles of data quality, consistency and auditability found in traditional data management functions need to be applied to the management of model and derived data too. If financial institutions do not address this issue, how will they be able to deal with the ever-increasing requests from regulators, auditors and clients to explain how a value or risk report was arrived at?

For those who are interested, the white paper is available here.

A French Slant on Valuation

Last Thursday, I went along to an event organized by the Club Finance Innovation on the topic of “Independent valuations for the buy-side: expectations, challenges and solutions”.

The event was held at the Palais Brongniart in Paris, which, for those who don’t know (like me till Thursday), was built in the years 1807-1826 by the architect Brongniart by order of Napoleone Bonaparte, who wanted the building to permanently host the Paris stock exchange.

Speakers at the roundtable were:

• Eric Benhamou, CEO  Pricing Partners
• Francis Cornut, Président  DeriveXperts
• Jean-Marc Eber, Président LexiFi
• Patrick Hénaff, Associated Professor at the University of Bretagne (see model validation paper for additional background)
• Claude Martini, CEO  Zeliade Systems

The event focussed on the role of the buy-side in financial markets, looking in particular at the concept of independent valuations and how this has taken an important role after the financial downturn.  However, all the speakers agreed that remains a large gap between the sell-side and buy-side in terms of competences and expertise in the field of independent valuations. The buy-side lacks the systems for a better understanding of financial products and should align itself to the best practices of the sell-side and bigger hedge funds.

The roundtable was started by Francis Cornut of DeriveXperts, who gave the audience a definition of independent valuation. Whilst valuation could be defined as the “set of data and models used to explain the result of a valuation”, Cornut highlighted how the difficulty is in saying what independent means; there is in fact a general confusion on what this concept represents: internal confusion, for example between the front office and risk control department of an institution, but also external confusion, when valuations are done by third-parties.

Cornut provided three criteria that an independent valuation should respect:

• Autonomy, which should be both technical and financial;
• Credibility and transparency;
• Ethics, i.e.: being able to resist to market/commercial pressure and deliver a valuation which is free from external influences/opinions.

Independent valuations are the way forward for a better understanding of complex, structured financial products. Cornut advocated the need for financial parties (clients, regulators, users and providers) to invest more and understand the importance of independent valuations, which will ultimately improve risk management.

Jean-Marc Eber, President LexiFi, agreed that the ultimate objective of independent valuations is to allow financial institutions to better understand the market. To accomplish this, Eber pointed to the fact that when we speak about services to clients, we should first think of what are their real needs. The bigger umbrella of “buy-side” implies in fact different needs and there is often a contradiction on what regulators want: on one side, having independent valuations provided by independent third parties; on the other side, independent valuations really mean that internal users/staff do understand what there is underline the products that a company have.In the same way, we don’t just need to value products but also measure their risk and periodically  re-value them.It is important, in fact, to have the whole picture of the product being evaluated in order to make the buy-side more competitive.

Another point on which the speakers agreed is traceability: as Eber said, financial products don’t exist just as they are, but they go under transformation and change several times. Therefore, the market needs to follow the products across its life cycle till its maturity stage and this pose a technology challenge, in providing scenario analysis for compliance and keeping track of the audit trail.

At the question, ‘what has the crisis changed’ panellists answered:

Eber: the crisis showed the need to be more competent and technical to avoid risk. He highlighted the need to understand the product and its underlying. Many speak of having a central repository for OTCs, obligations, etc but this needs more thinking from the regulators and the financial markets. Moreover, the markets should focus more on quality data and transparency.

Eric Benhamou, CEO pricing Partners, sees an evolution of the market as the crisis showed underestimated risks which are now being taken in consideration.

Claude Martini, CEO Zeliade, advocated the need for financial markets to implement best practices for product valuations: buy-side should apply the same practices already adopted by the sell-side and verify the hypotheses, price and risk related to a financial product.  

Cornut admitted  things have changed since 2005, when they launched DerivExperts and nobody seemed to be interested in independent valuations. People would ask what value they would get from an investment in independent valuations: yes, regulators are happy but what’s the benefit for me?

This is changing now that financial institutions know that a deeper understanding of financial products increases their ability to push the products to their clients. The speech I enjoyed the most was from Patrick Hénaff, associated professor at the University of Bretagne and formerly Global Head of Quantitative Analysis - Commodites at Merrill Lynch / Bank of America.

He took a more academic approach and contested the fact that having two prices to confront is thought to reduce the incertitude on the product but highlighting as this is not always the case. I found interesting his idea of giving a product price with a confidence interval or a ‘toxic index’ which would represent the incertitude about the product and reproduce the model risk which may originate from it.

We speak too often about the risk associated to complex products but Hénaff, explained how the risk exists even on simpler products, for example the calculation of VAR on a given stock positioning. A stock is extremely volatile and we can’t know its trend; providing a confidence interval is therefore crucial. What is new instead, it is the interest that many are showing in assigning a price to a determinate risk, whilst before model risk was considered a mere operational risk coming out from the calculation process. Today, a good valuation of the risk associated to a product can result in less regulatory capital used to cover the risk and as such it is gaining much more interest from the market.

Henaff describes two approaches currently taken from academic research on valuations:

1) Adoption of statistic simulation in order to identify the risk deriving from an incorrect calibration of the model. This consists in taking historical data and test the model, through simulations and scenarios, in order to measure the risk associated in choosing a model instead of another;)

2) Have more quality data. Lack of quality data implies that models chosen are inaccurate as it is difficult to identify exactly what model we should be using to price a product.

 

Model risk, which as said above was before considered  an operational risk, now becomes of extremely importance as it can free up capital. Hénaff suggested that is key to find for model risk the equivalent of the VAR for market risk, a normalized measure. He also spoke about the concept of a “Model validation protocol”, giving the example of what happens in the pharmaceutical and biologic sectors: before launching a new pill into the market, this is tested several times.

Whilst in finance products are just given with their final valuation, the pharmaceutical sector provides a “protocol” which describes the calculations, analysis and processes used in order to get to the final value and their systems are organized to provide a report which would show all the deeper detail. To reduce risk, valuations should be a pre-trade process and not a post-trade.

This week, the A-Team group published a valuations benchmarking study which shows how buy-side institutions are turning more and more often to third-parties valuations, driven mainly by risk management, regulations and client needs. Many of the institutions interviewed also admitted that they will increase their spending in technology to automate and improve the pricing process, as well as the data source integration and the workflow.

This is in line on what has been said at the event I attended and confirmed by the technology representatives speaking at the roundtable.

I would like to end with what Hénaff said: there can’t be a truly independent valuation without transparency of the protocols used to get to that value.

Well, Rome wasn’t built in a day (and as it is my city we’re speaking about, I can say there is still much to build, but let’s not get into this!) but there is a great debate going on, meaning that financial institutions are aware of the necessity to take a step forward. Much is being said about the need for more transparency and a better understanding of complex, structured financial products and still there is a lot to debate.  Easier said than done I guess but, as Napoleon would say, victory belongs to the most persevering!

Analytics Management by Sybase and Platform

I went along to a good event at Sybase New York this morning, put on by Sybase and Platform Computing (the grid/cluster/HPC people, see an old article for some background). As much as some of Sybase's ideas in this space are competitive to Xenomorph's, some are very complimentary and I like their overall technical and marketing direction in focussing on the issue of managing of data and analytics within financial markets (given that direction I would, wouldn't I?...). Specifically, I think their marketing pitch based on moving away from batch to intraday risk management is a good one, but one that many financial institutions are unfortunately (?) a long way away from.

The event started with a decent breakfast, a wonderful sunny window view of Manhattan and then proceeded with the expected corporate marketing pitch for Sybase and Platform - this was ok but to be critical (even of some of my own speeches) there is only so much you can say about the financial crisis. The presenters described two reference architectures that combined Platform's grid computing technology with Sybase RAP and the Aleri CEP Engine, and from these two architectures they outlined four usage cases.

The first use case was for strategy back testing. The architecture for this looked fine but some questions were raised from the audience about the need for distributed data cacheing within the proposed architecture to ensure that data did not become the bottleneck. One of the presenters said that distributed cacheing was one option, although data cacheing (involving "binning" of data) can limit the computational flexibility of a grid solution. The audience member also added that when market data changes, this can cause temporary but significant issues of cache consistency across a grid as the change cascades from one node to another.

Apparently a cache could be implemented in the Aleri CEP engine on each grid node, or the Platform guy said that it was also possible to hook in a client's own C/C++ solution into Platform to achieve this, and that their "Data Affinity" offering was designed to assist with this type of issue. In summary their presentation would have looked better with the distributed cacheing illustrated in my view, and it begged the question as to why they did not have an offering or partner in this technical space. To be fair, when asked whether the architecture had any performance issues in this way, they said for the usage case they had then no it didn't - so on that simple and fundamental aspect they were covered.

They had three usage cases for the second architecture, one was intraday market risk, one was counterparty risk exposure and one was intraday option pricing. On the option pricing case, there was some debated about whether the architecture could "share" real-time objects such as zero curves, volatility surfaces etc. Apparently this is possible, but again would have benefitted by being illustrated first as an explicit part of the architecture.

There was one question about the usage of the architecture applied to transactional problems, and as usual for an event full of database specialists there was some confusion as to whether we were talking about database "transactions" or financial transactions. I think it was the latter, but this wasn't answered too clearly but neither was the question asked clearly I guess - maybe they could have explained the counterparty exposure usage case a bit more to see if this met some of the audience member's needs.

The latter question on transactions above got a conversation going on about resilliancy within the architecture, given that the Sybase ASE database engine is held in-memory for real-time updates whilst the historic data resides on shared disk in Sybase IQ, their column-based database offering. Again full resilience is possible across the whole architecture (Sybase ASE, IQ, Aleri and the Symphony Grid from Platform) but this was not illustrated this time round.

Overall good event with some decent questions and interaction.

Dodd Frank Regulation - being seen to be doing something?

I went along to a Six Telekurs event "Securities Valuations: Is the Price Right?" last week - good event with some interesting speakers, most notably Paul Atkins of Patomak Partners to talk about the Dodd-Frank Wall Street Reform and Consumer Protection Act 2010. Paul is based out of Washington and was not very complimentary about what has been going on.

He started by saying that the Act was very large in size, with over 2319 pages (compared to SarbOx with only 60) and given this size he suggested that you could guess how many in Congress had actually read it. Background to the Act were:

• "Political Tailwinds" such as:
  • New Democrat Government with tenuous majority
  • Ambitious legislative plans
  • Bleak economic back-drop
• An angry populace:
  • TARP bailouts/Wall St bonuses
  • Recession and high unemployment
  • Perception that Govt. contributed to crisis
• Aggressive case for new regulation based on:
  • Lack of confidence in current systems and regulation
  • "Too big to fail" demonstrating that regulators lack the toolsets necessary to deal with such events
  • High leverage across the financial system and the economy
  • Poor risk management by existing participants
  • Opaque shadow banking system and opaque derivatives markets

He summarised that Housing and the Credit Rating Agencies were the key fundamentals behind the financial crisis.

Paul said that with the new regulation had the following features:

• The Act is a sweeping revision of financial regulation in the US
  • few dodged the regulatory changes (notably insurance managed to do this)
• The Federal Reserve has emerged pre-eminent amongst all regulatory bodies in the US.
• Significant discretion has been yielded to regulators to work out specifics
• Sheer size and ambiguous wording of the Act exacerbates the uncertainty in the market and economy and will require further fixes over coming years
• The Act does not reform Government Sponsored Enterprises (Fannie Mae, Freddie Mac)
• Far from reducing/simplifying the number of agencies involved in regulation the Act eliminated 1 agency and created 13 more
• Paul asked the question whether spreads and volatility will rise in the market due to new regulation (such as the Volcker rule) and whether ultimately this will trickle down to hinder or benefit SMEs.
• The Act will likely result in regulatory arbitrage opportunities and Paul said this was not a good thing for the United States

Paul said that in his view Congress learned the wrong lessons from the crisis:

• No reform of Fannie Mae and Freddie Mac
• Government Housing Policy left unaddressed
• Transparency still lacking despite efforts from FASB on fair value
• International Policy Co-ordination is still an open question as to its extent
• No reform of existing regulator structures
• The crisis has resulted in payoffs to favoured groups (Unions, Trial Lawyers etc)

Paul talked about how hedge funds and private equity funds were going to experienced increased regulation with them having to register if they have over $100M assets under management and future implications for systemic risk provisions. He mentioned that Venture Capital investments had escaped being required to register if the lock-up period was over 2 years.

He briefly discussed the coming changes in OTC derivatives on centralised clearing, post trade reporting and new liability provisions. Paul was also concerned about certain SEC related issues such as "Whistleblower" provisions which contain a bounty programme of about 10-30% of any fine subsequently awarded against a financial institution. He re-iterated that it was not yet clear what all of the bodies involved in regulation would be doing, and at the same time as this was the case the very same bodies were also being given very strong powers such as that of legal subpoena.

Paul was a very knowledgeable speaker and had some good points to make. Listening to him speak it would seem from my perspective that the Act is a prime example of "being seen to be doing something" to address the crisis rather than something better structured, with all of "law of unintended consequencies" risks that such an initiative entails.

 

 

 

The Humans Between Risk and Data

Some of my thoughts on risk management, data management and human behaviour, are to be found on page 20 of the Inside Reference Data Special Report "Managing Risk"

XTrakter Conference

I went along to the XTrakter Annual User Conference in London on Thursday - Good event with some great speakers. Angela Knight, CEO of the British Bankers Association, gave a talk to start off the day. Angela seemed a lot less on the defensive than when I have heard her on national radio here in the UK, usually being interrogated by some journalist who wants answers to difficult questions on the financial crisis and the banks role within it.

Angela said that we were in year 3 of the "crisis" with 2008 being about the banks, 2009 being about governments and politics and 2010 being the year of sovereign debt. I guess she enjoyed saying this but that everyone is blaming "Anglo Saxon Banking" for our problems and yet it was not the banks that contributed to the fundamental problems that Greece is facing.

One major theme of her talk was decidedly Euro-Sceptic in tone, which was that the UK idea of internationality and international trade was different from that of Europe. She perceived that in the UK one of our trading parties is Europe, whereas international trade in Europe was more about inter-European and not world-wide trade - I think that there are elements of truth in this but not sure that Germany industry for example would agree that it is not conscious of truly "global" trade? She said that she was concerned by the rules and regulation being put up by governments, particularly in respect of there being too much and in too short a time.

Angela was an engaging speaker and at the very least her opinions prompt reaction, however I have to end this quick post with the best quote of the morning from Anthony Belchambers, CEO of the Futures and Options Association. Anthony said that current frenzy around political and regulatory initiatives to control the financial markets remind him of:

"A bar room brawl, where the brawlers don't punch the person that started the fight, they punch the person they have always wanted to punch..."

The Value in Product Control

Good post from Robert Peston on the BBC website on part that the Product Control Group did (or rather didn't?...) play in the problems at Lehman's, according to the official US bankruptcy report on Lehman's by Anton Valukas.The post highlights the report's findings that the Product Control Group did not have the quant experience to keep up with CDO trading desk.

Interesting findings on Lehman's, but variants on this theme seem to be elsewhere too. A contact who knew Merrill's New York trading operation in the run up to the crisis recently asked me how many quants did I think used to work on the CDO trading desk. The surprising (?) answer was not one...

Risk, Data Transparency and the MBS Market

I spent the morning yesterday over at the FIMA USA event in New York, and caught the panel discussion chaired by Neil Edelstein of GoldenSource. Stand out speakers were Amy Hawkins of BNY Mellon and John Bottega of the Federal Reserve.

Neil started the panel by asking the panel for their thoughts on the current drive to improve "data management for risk". Transparency and quality were mentioned a lot unsurprisingly, with John Bottega adding that he was aware that a lot of banks were now focussed on the data that in the past had been "not available" for risk management, not just the quality of data that is readily accessible. All panelists focussed on the need to manage risk across the whole institution, not just by product silo.

On the topic of data standards and transparency, John referred the audience to testimony on the Mortgage Backed Securities (MBS) market presented to the US Government by the XBRL group. Apparently the filing process for mortgages allows free format filing and so is of little use from an automated processing point of view. John also pointed out that a key piece of data in assessing risk is that the "first time buyer" flag was found to be present in only 15% of the filings.

John also mentioned that if loans and mortgages could be given standard identifiers, then this would enable new levels of risk management - for instance it should be able to extract those obligations against a specific region that for example is experiencing economic recession. These would be the benefits of getting data standards in place.

As was later expanded upon in a later talk by Kay Vicino of Northern Trust, there was a lot of panel discussion on organisational data governance and the management structures needed to achieve it. On the governance side of things then whilst it is not an exciting topic, it is obviously vital - main point seems to be establishing data ownership and responsibilities which brings me back to the point that a lot of (most?) data management issues are down to managing people and organisational politics, not just down to good technology (although it helps!).

Overall a reasonable panel, and the XBRL testimony looks worth a more detailed read (if the testimony link doesn't work then go to the www.xbrl.org site and search for a report called "Using Standards for Transparency")

One man's speculation is another man's insurance...

The current finanical crisis in Greece has prompted an outburst of entertaining discussion at the FT about CDS contracts, initiated by a feature article by Wolfgang Munchau who advocates that naked CDS contracts should be banned. The main argument used is that you should not be able to insure against a risk that you do not face e.g. buying insurance on somebody else's house then arranging to have the house burnt down. In support of Mr Munchau, one reader letter points out that insurance without interest in the insured item has been illegal since 1746, which on the face of it seems a long enough time to be a credible point in the discussion.

However, in using this argument then Mr Munchau seems be to attacking the whole of the derivatives industry not just CDS, for example the same argument could be used to ban the use of naked index puts to hedge equity market risk. I guess he is also helping some of the politicians in the EU direct attention away from Greece's financial mismanagement more towards the "evils" of the derivatives markets and hedge funds.

Some good letters in response, for instance this one with a good illustration of what hedging would be like without intermediaries to buy and sell risks that they do not own, plus another more direct one from the Association of Corporate Treasurers.

Whilst talking of Greece and credit, the FT Alphaville team also poked some fun at Anatole Kaletsky, the economist of the London Times Newspaper, who has recently done some interesting articles in the paper concerning his predictions about the stresses being suffered by Greece and the Euro. From their post, it would seem that Mr Kaletsky also runs a credit related fund, so it is implied that some of his newspaper views need to "calibrated" against his own vested interests...

Beyond Golden Copy?

Interesting reading in a survey put together by Lepus and Thomson Reuters and publicised on Finextra this week. Summary findings:

• Data management budgets are increasing, with 77% of firms intending to increase spend on data quality and consistency and 32% saying spend would increase significantly.
• Tearing down data silos is a key initiative, 70% of firms are looking to revise data management solutions as a result of the crisis, and 31% of firms cited data quality and consistency as the most important driver.
• Data management for risk is the top concern, with 87.25% of firms looking to integrate data repositories in risk, and 62.5% saying that they were close/very close.

This seems to be consistent with another article on Finextra this week, with Deloitte predicting a much greater spend on risk management projects. Putting the marketing aspects aside for a moment, I don't think it is abundantly clear from the actual content of the Lepus survey as to why the title includes the phrase "...Beyond Golden Copy" other than the type of data management they refer to seems to have more emphasis on global/firm-wide data integration than your traditional EDM golden copy data warehouse approach.

It is also interesting to hear so much about consistent data across the entire enterprise (driven by risk and regulation) which seems to echo the "big EDM" projects of old that did prove that successful, and to some degree is at odds with what the likes of Golden Source and Asset Control are currently saying about choosing smaller projects to bite off on rather than the enterprise approach. I would suggest however that there is no issue in having smaller projects in mind so long as they are compatible with the overall goal.

The integration and consistentency of data across front, middle and back office was also interesting, and in particular the front office integration echos some of the things I have been saying about the need for analytics management and the management of front office data as part of the data management process, not something to be ignored in the hope it sorts itself out.

"Cut and Paste" Valuation Services

You can talk about more robust modelling, more stringent scenario testing and even moving everything onto an exchange, but unless we move the principles of good data management (in my view: consistency, security and quality of all types of data) into the front office then we will continue to get front-office mis-marking as described in this article in the FT.

Thanks to Ralph Baxter from Cluster7 for highlighting this article for me and those of you interested in this topic of operational risk and spreadsheet mis-use should maybe go along to EuSpRiG this year, and maybe take a look at a paper Xenomorph presented at a previous conference.

More Products, Less Complexity?

Decent article(and title!) explaining ETFs in FTfm today - growth of the market sounds impressive, from $40bn in the year 2000 to over $1,000bn under management now. Seemed like a bit of a day for new financial products in the FT, with the LSE announcement of opening up direct bond trading to retail investors through offering corporate bonds issued in sizes well below the usual £50,000 size (and catching up with more usual practice in Europe). Whilst not a retail product (I guess some of us already have life insurance?), longevity derivatives seem to continue their rise too in liability driven investment.

Meanwhile over on Linkedin, Structured Products magazine are asking just what constitutes a "complex" product? A decent question since complex products are not necessarily risky, but certainly "complexity is in the eye of the beholder" is most likely answer in my view - echoing a growing problem in finance, regulation and economics at the moment; there are too many people searching for the unique "right" answer to questions that simply do not have one. Maybe we should stick to the answer to everything being "42" and give up the search for the question?...

RiskMinds - The Failure of Risk Models

Avinash Persaud of Intelligence Capital gave the opening talk of the morning at RiskMinds (see first of set of posts from last year here) and put forward a lot of the very good ideas that he has contributed to in the recent Warwick Commission Report. Main points that Avinash made:

• Regulators were admirably quick in working out where past regulation had gone wrong in focussing too much on micro (individual institution) rather than macro (whole market)/systematic risk.
• The regulators then came out with promising papers on counter cyclical regulation and other positive ideas.
• These new ideas do not win votes however and do not satisfy the public's desire to punish someone - Avinash called this the "Bad Apple" policy, with "bad bankers, bad products, bad jurisdictions" being the perceived guilty parties.
• All past crises have resulted in demands for three things: i) more risk management; ii) more regulation; and iii) more transparency.
• These are fine as demands but evidently do not prevent financial crises.
• Avinash recalled his work back at JPMorgan in the early 90's when the 4:15 report was produced for Sam Weill, which eventually led to VAR reporting becoming widespread.
• He then fast forwarded to the Asian crisis of 97 where he saw the failings of VAR (or rather its widespread use) first hand with all players using VAR which when volatility increased caused an increase in VAR causing JPM (and all) to sell causing markets to fall, increasing vol causing more selling, increasing correlation and leading to what is called the "loss spiral".
• In light of the recent crisis, Avinash said the public perception is that bankers created a load of toxic bombs (products), through them at an unsuspecting public and ran away...
• ...and in his opinion the reality is that banks created a load of toxic bombs and ran straight towards them i.e. this was a failure of risk management where bankers did not understand the risks they were buying and selling.
• He then took us back to the 1950's and the formation of modern portfolio theory with Markowitz and Danzig working at the RAND Corporation.
• At that time banks and insurers were still separate, with FX and capital controls still in place meaning that not only could the "efficient frontier" of investment portfolios be observed but it could also be acted upon.
• Now everyone has the same information everyone can observe the efficient frontier of investment opportunities but cannot exploit or act upon it, since usually everyone moves in (the "herd") and the value observed is changed by this crowded participation in the market. Here he seems to be echoing a lot of what Bob Litterman said at QuantInvest last week over the "crowded trade" and that the barriers to market knowledge and our ability to act on this knowledge have been lowered forever.
• Avinash put forward that many of the models we use today assume the statistical independence of decision making process whereas the reality is that the market is homogenous (everyone is thinking/acting the same) and hence these models are invalid in this "crowded" context.
• In light of this, the problem of risk management is not about exogenous risk (risks from outside the market, from Black Swan events to normal distributions) but more about endogenous risk i.e. peoples behaviours upon seeing opportunities cause strategic risks. (Interesting given Jean-Phillippe Bouchard at QuantInvest commenting on what makes prices move). Put another way, behaviour is the issue not the financial instruments themselves.
• Avinash proposes that risk capacity (the ability of an institution to absorb a particular type of risk) shoudl be thought through more fully, with for example insurance and pension institutions with long-term liabilities having a much greater capacity to absorb liquidity risk than banks, and banks with short term funding being a better position to manage a loan book.
• He pointed out that regulation that uses market prices to protect us against movements in market prices is doomed to failure before it starts.
• Booms occur due to some perceived "paradigm shift" technolgy leading to dramatically improved risk/return ratios - he cited things such as cars, electricity, rail, dotcom and the mantra from those involved that "This time it is different..." (see "bubble" post from last year)
• Avinash thinks the regulators are significantly to blame for the last crisis since they themselves said the latest financial innovations in credit derivatives were making us safer through sharing out risk in the system.
• He said that there is no theory for making a complex system "safe" as a whole and that the regulators did not/do not "get" this idea.
• Diversity of approach and risks in a large systems (macro financial markets) is our only current defence and regulatory "best practice" has driven conformity not diversity in the market, making systemic risks higher not lower.
• So the regulators are themselves creating a homogenised market.
• In terms of solutions, he proposes that risk and audit committees need separating so that risk management does not become a "tick box" exercise.
• He further proposes that the risk management function is given some capital so that it can place hedges at a macro level for institution (i.e. looking at the resulting risk when divisional risks have been aggregated) - here is proposing moving to risk "management" as opposed to the much more common risk "reporting" found in many institutions.
• One risk management indicator idea he proposed was to put a portfolio management model together that was linked to VAR in order to see where the "herd" is moving to (e.g. low vol, high return Asian markets of the past etc) and to move or hedge against this.
• He is concerned that applying Basel II regulation to the Insurance industry with Solvency II will mean that all players will be dancing to same VAR tune which will introduce more risk as more institutions are forced to react in the same way to market movements and volatility.
• On the same lines, Credit Rating Agency regulation will create barriers to changes in ratings methodology in response to endogenous market risk, again meaning that everyone will be forced to behave and act in the same ways.
• He summarised that "endogenous risk" (movements in the market caused by the market) and not statistical distributions that are the key issue and diversity is the only solution.

Entertaining speaker with some interesting ideas that fly in the face of much of what is being done by the regulators today, and generally well received by many of the risk managers present. Behavioural finance and the "crowded trade" (i.e. everyone doing the same thing in the market causing movements within the market) seem to be key themes occuring in a lot of what academics and practitioners have said on risk management recently. Now what to do about it? Not sure that less (not more) regulation will find many fans at the moment...answers on a postcard please!

Views on Fair Value...

Busy week last week for events in London, this time over at the Goodacre / Six Telekurs on Thursday morning. Guy Sears of the IMA was chair of the event, and the event did have a "buy-side" focus to it. Richard Newbury of Six Telekurs started the event and made the following points on the current state of regulation:

• UCITS IV - Richard cited the stats that there are around 37,500 funds in the EU with average value of approximately $180M each as compared to only 8,000 funds in the US with average value over $1B. Richard said that such a proliferation of funds was costly and the more EU could standardise funds and their ability to be transacted everywhere in the EU the better.
• Reg NMS - Richard took a little humorous dig at US regulators when he reminded us that Congress authorised the SEC to form a "National Markets System" in 1975 and so this had taken around 30 years to implement. Whilst Reg NMS is often compared to MiFID, he said that Reg NMS had led to consolidation in the US while obviously MiFID has led to fragmentation in the EU.
• Hedge Funds - Both EU and US regulators are looking at the hedge fund industry. He mentioned the battle the UK was having with some of the (misguided?) regulation that the EU is trying to introduce with over 30,000 HF related jobs in London. The new regulation is likely to increase reporting requirements leading to more need for regular, standardised fair value reporting.
• Credit Rating Agencies - Richard mentioned how there will be more ratings and more ratings types, and the regulation introduced to ensure the CRA do not fall into the conflict of interest trap.
• Data Management - He mentioned the importance of data management within what is happening in the industry and noted how the profile of data management was on the increase.

Mike Jenkins of Ernst & Young tried his best to make the accountancy treatment of derivatives interesting and didn't do too bad an effort but I only took the following few notes from his talk:

• Unlike US GAAP with FAS 157 there is no single standard Fair Value (FV) definition in IFRS, and unsurprisingly IASB are addressing this.
• Mike spent some time mentioning Level 1(quoted), Level 2 (observable) and Level 3 (unobservable) pricing inputs for securites, taken from the IASB exposure draft ED/2009/5 (also see Rowe in earlier post)

Matthew Cox of BoNY Mellon Security Services then gave his presentation on the difficulties/challenges of providing a valuation service to their asset management clients:

• His division often have a "2 hour" window to produce valuations for NAV reporting, often for a 12 midday valuation
• Data exceptions for investigation went through the roof this year due to increased volatility (comment: didn't get chance to ask whether the validations set were "normalised" for market volatility i.e. a price movement threshold would not be fixed but rather be multiplied by a factor relating to recent volatility levels)
• Matthew was very complimentary about the efforts his team put in to cope with this increase in data exceptions.
• He mentioned how many of his clients of established "Fair Value Committees" over the past couple of years, comprised of staff from compliance, risk management, portfolio management etc.
• Matthew mentioned the importance of time zones in valuation and the timeliness of data, with the availability of intraday CDS prices contrasting with bonds who price only from the evening close of the day before.

The panel debate was moderated by Guy Sears, and included the above speakers plus Nigel Reynolds from TD Waterhouse):

• Matthew said that his division sometimes shared the "consensus" price from other clients when one client is looking for some guidance.
• He mentioned that a key timeframe in establishing FV was establishing what is a "reasonable" time frame for sale of a security.
• Nigel Cox said that "suspended stocks" had been a real issue over the past year, where the client "context" (position, situation etc) would very much determine what value a client would want assigned to a holding.
• Guy Sears suggested that valuations should be provided with a confidence interval and not just as a single price
• Mike of E&Y said that this is what full disclosure now requires, other memberrs of the panel suggested this was realistic but not what clients (humans?) expect to receive - they want a single number.
• Guy wondered whether it was an issue that one entity might value an asset at a value X whilst another would value the liability at Y (not equal to X)
• Mike of E&Y pointed out that this was an issue in that current accountancy rules allow a security to be reclassified from "fair value" pricing to "historic cost" basis - this discretion is being removed in future rule implementations
• One member of the audience pointed out that Bloomberg, Reuters and Markit were all trying to extract more revenue from data used for valuation purposes.
• Matthew advocated that the market needed more competition between niche data vendors such as Markit and SuperDerivatives to ensure innovation in service and more competitive pricing.
• The audience asked Guy of the IMA whether the association should have offered more guidance on fair valuation process and best practice.
• Guy said they have provided some, but he advocated that trade associations should not have opinions, since it was not healthy to have the asset management industry collectively herding towards the same valuations.

Well attended event with some good speakers, particularly Guy Sears as host was funny, knowledgeable and kept the other speakers on their toes. I would say the most interesting point was still that "opinions" form prices, opinions formed in the investment/funding "context" of the party with an interest in valuing a security - conceptually this seem to make the asset servicing companies a little uncomfortable since what they are contracted to do is to provide the "right" set of numbers by their clients. Human beings feel more comfortable fixating on a single number than a range of possible outcomes/results it would seem!...

Paying a margin call for the grim reaper...

Seems that liability driven investment and the use of longevity derivatives is set to rise for pension funds, according to an FT article about a survey by Aberdeen Asset Management. Maybe Deutsche Borse was ahead of the game with real-time death data...

Shipping Fair Value...

...seems like the shipping industry is as about as confused as the finance industry about establishing "fair value" for assets according to this article in the FT.

Integrated Data and Analytics Management

Xenomorph was one of the sponsors on the “Integrated Data Management” webcast last week, hosted by Inside Reference Data (audio recording available here). There were a number of interesting questions that arose from the Webinar.

One fundamental although somewhat academic question was "What is Integrated Data Management?". Certainly everyone seemed convinced that there would be less "Enterprise Data Management" (EDM) projects in future, given the expense, scope and scale of such projects. The concensus was that whilst the need for data management was better under stood across all financial institutions, data management projects would be bitten off in more manageable chunks by asset type, business function or division (so are silos back in fashion I ask myself?!). Coming back to the original question, I guess my slant on Integrated Data Management is that we are seeing more and more data management projects that have an integrated reference data and market data elements to them, primarily driven by the need to sort out data quality/completeness/depth for use within risk management (in light of the financial crisis).

Related to risk management, a topic I pushed was that given the origins of data management for STP/back office, and given the interest in low latency tick data management/analyis in the front office, there seems to be a market gap (particularly in the US?) on how to manage data such as IR/credit curves, volatility surfaces and other derived data sets. These data sets seem to fall into the gap between what is thought of as market data (primarily just prices) and what is reference data (IDs and terms & conditions). This is another area where a more integrated approach to data management would be beneficial, particularly in making all these datasets available for risk management.

Coming back to a "hobby-horse" of mine, then I also raised the issue that whilst it is fine to be doing great data management (high quality, complete datasets etc) what is the point if all of your data is ignored by the front office and Excel is used to download the data traders and risk managers need from Open Bloomberg. I think the management of unstructured data (spreadsheets, word docs etc) needs to be elevated as an issue since this (unfortunately?) is where most data resides currently, despite what we data management professionals like to think.

I also think that the principles of good data management (centralisation, quality and transparency) could apply to other things and not just raw "data", but what about centralised pricing and valuation, centralised curves and centralised scenarios for risk? Again what is the point of doing good data management if the ultimate "information" (e.g. a valuation) is done using poor quality data, with a complete lack of transparency over the data and model used.

A good question was asked about models, which was that given pricing models and their weaknesses have formed some part of the recent crisis, do we need more complex models. On having a few conversations about this and thought about it some more, then some would say it is complexity that got us into the crisis so this is the last thing we need. My view is that we do not necessarily need more complex pricing models and valuation techniques, but we certainly need more robust ones which does not necessarily imply more complexity. Coming back to a point raised by David Rowe previously, then I think all quants and risk managers should think about a "second means of valuation" for all the theoretical models they use, and that hedgeability (see recent post on pricing model validation) seems to be the common theme in producing more robust pricing models.

Pricing Model Validation: Mitigating Model Risk

I managed to catch some of the day yesterday at the "Pricing Model Validation: Mitigating Model Risk" conference. I thought it would be worthwhile going along since firstly the past 12-18 months have made model risk very topical (take a look at previous posts from Riskminds, the Modeller's Manifesto and Wilmott/Rowe).

Secondly more of our clients are looking at managing and centralising pricing models/curve calculators in addition to just managing the underlying data (see this Insight Investment client case study for a recent public example). I am calling this "Analytics Management" which is the business-focussed technology stack that combines pricing models/calculators/analytics with all of the "Data Management" underneath. But enough of my thinly-veiled positioning statements...and on with some of the (hopefully) useful content from the conference outlined below - maybe scan the headings in bold below for those talks of interest but I would particularly recommend the ones by Tanguy Dehapiot and Yuyal Millo...

Model Risk 2009 defining and forecasting. First speaker was Professor Phillip Sibbertsen of the University of Hannover on defining and measuring model risk. Phillip started by saying that "Model Risk" was a new category of risk within the confines of "Operational Risk", and that operational risk as defined by the regulators does not yet currently include the "model risk" of market risk and credit risk, nor the "model risk" of the operational risk model itself. (I am sure I could write that up better!...). Phillip put forward that model risk is not formally a "risk" since it has no probability distribution and that he suggested it should be thought of as "model uncertainty". He also clarified that model risk applies both at the large, portfolio scale (e.g. choice of VAR model etc) and at the smaller, instrument level scale (i.e. pricing of derivatives).

Additionally in terms of measuring model risk then he excluded human failure from model risk measurement since in his view this was difficult to quantify - this approach did not meet with the approval of some of the audience were questioning how this could be excluded from a practical point of view. Phillip's colleague, Corinna Luedtke, then presented some work they had done on calibrating different GARCH models to observed data and showing how even a poor model could produce reasonable forecasts of risk if the time period was short. The work was interesting but again the audience highlighted that the human choice (failure?) in choosing the set of models to try was part of "model risk" and should not be excluded from the definition of model risk.

Is a model accurate? Testing the implementation of a model. Second speaker was David Chevance, Head of Equity & FX Model Validation at Dresdner Kleinwort. David outlined the different sorts of model risk: mathematical errors, missing risk factors, divergence from industry practice, model inconsistencies and implementation risk. He then outlined the sources of these risks: bugs, approximations, numerical precision, numerical boundaries and limitations on numerical methods (e.g. Sobol numbers in high dimension monte-carlo simulations).

David said a key area to start with in validating a model implementation was the front-office documentation of the product, its inputs and payoffs, its pricing model but also details of calibration methods used/needed etc. He made the point here that the documentation can sometimes specify just the deal, but sometimes can express the pricing methodology and pricing parameters. The emphasis was on completeness, accuracy and making use of all of the information available in the documentation. Obviously the ability to review the code used to implement the model was also necessary.

He discussed the trade-offs between a simple validation approach in terms of speed and efficiency of resources against the more time-consuming, resource hungry but more accurate approach of full replication of the model. He also suggested that in choosing a method of validation it was important to balance resource demands against what is actually being validated: payoffs from a single trade, a type of pricing model or a family of financial products. Desired accuracy of the validation was also important, given the trade-off between accuracy and effort, and the fact that small bugs are much more common than large.He finally discussed model version control, the necessary discipline of documenting changes and regression tests for new models, and the regular cycle of model review. Overall it was an interesting talk with a good practical focus.

Practical aspects of valuation model control process. One of the most entertaining and interesting speakers of the day was Tanguy Dehapiot, Head of Validation and Valuation, Group Risk Management at BNP Paribas. He started by referring to a few documents "Supervisory guidance for assessing banks’ financial instrument fair value practices", April 2009 (BCBS 153) which was then implemented within “Enhancement to the Basel II framework” (BCBS 157). The first part of his presentation was around these documents and what the regulators expect to be in place, so I guess the best approach is to read them (the BCBS 153 document content is only 12 pages long, quite short for a regulator!)

Tanguy pointed out that in his view "Mark to Market" and "Mark to Model" are often misleading as both are often required. He prefers the term "Valuation Methodology". He proposed four valuation modes: Direct Price Quotation, Use of Similar Instruments, Risk Replication, Expected Uncertain Cashflows (NPV) and categorised a useful hierarchy/matrix of which financial products fit into which valuation mode and for what purposes. Within model risk, he split off judgemental errors (choice of model etc) as part of market risk and credit risk and operational errors (model implementation and coding) as more definable and avoidable parts of operational risk.

He had some interesting slants on data, saying that he had been surprised that even getting all of the static data necessary to price simpler instruments like bonds had proven difficult. He outlined how model parameters are often stored across a variety of systems (curve definitions in one place, pricing methodology somewhere else) implying to me that this is sometimes difficult to pull together and needs some centralisation to improve transparency around this.

His opinion on market parameters (both observed prices and derived data such as implied volatility surfaces) were often stored in a larger central database but warned that this market parameter database needs to be reviewed as part of the model validation process since some of its data is derived (i.e. calculated, maybe using a model!) and as such should not be taken as perfect for all time and for all purposes. He said that it was important to categorise the origin of data and suggested the following types:

• Quoted on an active exchange
• Actual private transaction in an active market
• Tradable broker quotes
• Consensus prices from market makers
• Non-binding indicative prices from market makers
• Counterparty valuation, collateral valuation
• Actual transactions in inactive market

Tanguy proposed that there should a valuation matrix for each instrument, where there might a different valuation methodology used for end of day valuation verses intraday, for risk or for trading, for pricing individually or within a portfolio reval. I guess here the rational is appropriateness, efficiency and transparency about what needs to used when. He also added that he disliked the term "Model Validation" since it seemed to imply that a model was "valid" and preferred "Model Approval" to cover the decision to use a model and "Model Review" to cover model analysis. He said he found managing the "stock" of existing models (and keeping up with when to review them) more difficult than managing the "flow" of new models and products.

Overall Tanguy was a very interesting and funny speaker with lots of practical insights and a fair amount of opinion thrown in, which is always good in my view.

The usefulness of inaccurate models: Financial risk management "in the wild". This talk was given by Dr Yuval Millo of the London School of Economics and he focussed on the evolution of the use of the Black Scholes Merton (B-S-M) model at the CBOE and how the model came to be the means by which the whole options market "communicated". Yuyal is a social scientist and prefaced his talk by stating that "Social Sciences are good at predicting the past"

First thing I didn't know (amongst the many things I do not know...) is that the B-S model was not published until a couple of weeks after the CBOE started trading stock options in April1973. Yuyal said that initially the B-S-M derived prices were not accurate at all (around 25% off the market price on CBOE) and that the model was based on assumptions that plainly were not the case on the exchange (only calls available, no short selling, no continuous trading). The model was used by local Chicago trading firms and the story goes that Fischer Black sold large paper "sheets" of option pricing matrices to these traders (there being no calculators/PCs/mobiles around at the time).

As the markets developed, larger East Coast banks entered the market with stocks being held and traded in New York and options being traded in Chicago, so trading became geographically dispersed. This started the need for "early morning meetings" to discuss the market and the B-S-M model and its parameters became the "lingua franca" or means of communication of options market participants.

He described the first years of the Options Clearing Corporation (OCC) which was set up to ensure that the financial obligations of options and buyers were met. Around 1979-80 the OCC worked overnight to calculate margin requirements, based on the (now?) arcane idea that different margin amounts should be associated with different option strategies (straddles, butterflies etc) and the job of the OCC was to take a portfolio of Option and optimise which combination of strategies would minimise the margin required for the whole portfolio. He said that there were disputes between traders and the OCC around margin levels and difficulties for the SEC with updating their Net Capital Rules as each new option strategy was created. Eventually, the OCC adopted the B-S-M model and implied volatility as the means of calculating margin against market value which enabled them to move away from the operational difficulty of strategy optimisation.

So the B-S-M became the way in which traders communicated about the market but also the model became vital operationally within clearing for the market. By 1987 B-S-M had become the de-facto standard for the market, with the model driving the market in turn driving use of the model. During the Oct '87 crash the model proved to be very innaccurate but the use of the model did not diminish - maybe pschologically the market participants needed a model (even a wrong model) to make communication easier.

I found this talk very interesting and members of the audience asked whether any similar analysis was going to be done on the Gaussian Copula model used to price CDOs. Yuyal said that one of his colleagues was undertaking this research currently. Given that he seemed to be very positive about the use of the B-S-M model within options markets I asked whether he had any opinions on Taleb's criticism of fiancial engineers and modelling. Yuyal said that he and Nassim were friends and agreed to disagree on certain topics...

Stress testing modelling parameters. Next up was Peirpaolo Montana, Head of Model Validation at West LB. Having joined the finance industry out of a career in mathematics and then at a regulator, Pierpaulo began by saying that back in the heady days of 2004 the banks thought that their own risk management systems and practices were well ahead of the regulators. He said that in light of the crisis this proved not to be the case but he now feels that this is now more evenly balanced (not sure I would agree, still lots of catchin to do for some institutions I would suggest).

He said that whilst regulators require the validation of risk models and pricing models, and that stress testing of a portfolio is required, that the stress testing of a pricing model is not a requirement and has received much less attention and in his view was not done to much degree before 2007. His point here was that pricing models should work under stress too, otherwise they are a weak foundation for building other risk measures such as stressed VAR.

Whilst focussing on pricing models, he mentioned that risk models also need to be carefully chosen and appropriate to the institution and the types of trading activities it undertakes. As an example he put forward that a simple VAR calculator might be appropriate for a long only equity fund but completely innappropriate for a relative value portfolio.

He said that stress testing had recently received much more attention as a risk management tool and cited the BIS document "Revisions to the Basel II market risk framework" where stressed VAR is introduced as part of the regulatory capital charge calculation. He also mentioned that in order to avoid "standard model" treatment of complex securitised products an institution must be able to demonstrate that its VAR model can cope with these products under times of market stress.

Pierpaulo then described the stress testing of base correlation in CDO pricing, and how even moving the base correlation from its usual level of 70% to 99% would not have predicted the valuations observed in the recent crisis. In this way he says that stress testing of models can detect implementation problems and some model weaknesses, but it cannot assist in coping with structural breaks in the market. He also discussed how the B-S-M model is used everywhere (even places it should not really be valid for) since it is a robust model based on the no-arbitrage hypothesis - in contrast the CDO base correlation and other models are not so robust since they are not arbitrage free.

(end of post!)
 

 

Regulatory moves and moods

Seems that the latest EU and Basel Committee proposals on banking regulation cannot make everyone happy (now there's a surprise...). Whilst many seem very happy at the incremental nature of the proposals to increase capital requirements for securitisations and proprietary trading, some of those in the Glass-Stiegal/banking utility camp are less than impressed. I am with the incremental camp myself, but have to acknowledge that the sceptics are not short of ammunition when saying that we are heading back to the future...meanwhile over in hedge fund land, London is currently in a very bad mood with the EU...

Das's Dazzling Derivatives

Satyajit Das adds an interesting contribution the debate on OTC derivatives and the drive towards CCP in his article in the FT today (see earlier post for background). The opening paragraph sets the tone:

'US and European Union proposals for over-the-counter derivative regulations are consistent with H.L. Mencken's proposition that "there is always a well-known solution to every human problem - neat, plausible and wrong".'

Main points from the article:

• A single CCP would certainly qualify for "too big to fail"
• The success of CCP depends on collateral and collateral valuations may underestimate risk and value since these are usually based on historical volatility
• Cross-margining exposes the CCP to correlation risks in offset methodologies
• CCP depends on valuing contracts that depend upon liquid markets
• CCP margining requirements may communicate market stress to more participants and in turn create more stress
• Regulators are missing the point with CCP and should look addressing the core issue of innovation and complexity hiding excessive profits in derivatives

As a related aside, probably also worth taking a look at the following article on the return of securitisation.

Lessons for Risk Management - Wilmott and Rowe

Great event organised by PRMIA and IAFE last night at Goldman's London offices with a long title:

 "A Little Thought Goes A Long Way and Lessons for Risk Management from the Current Crisis".

The event was moderated by Giovanni Bellossi of FGS Capital, and featured speaking slots by Paul Wilmott and David Rowe of Sungard. Here are my notes on the evening, please forgive any innaccuracies, and please persevere through some of the techy quant stuff, as their general points are well worth understanding.

• Giovanni quoted from Nassim Taleb about how VAR is invalid and that mainstream financial mathematics should be banned (or words to that effect, see earlier post on Taleb)

• He added that whilst what Taleb says cannot be ignored, he said that despite the current crisis and its causes that we should not "throw the baby out with the bathwater" and added that Taleb "...is not only able to recognise a cow but also knows how to milk one."

• Giovanni said that financial mathematics has much to offer and that whilst VAR is simply a number, one of its great benefits has to make one measure of risk simple and compelling enough to get traders and risk managers talking.

Paul Wilmott then took the floor and put forward his thoughts:

On Taleb and the Black-Scholes Model

• Paul mentioned that he and Taleb were great friends, and whilst he agreed with much of what Taleb says he has areas of disagreement, particularly over the use of the Gaussian distribution in finance and its implications for "fat tail" events
• Paul Googled "Taleb" and found more entries for Taleb than for Stephen Hawkin which shows how much attention had come his way due to the "Black Swan" debate
• He thinks that he and Taleb are the "Marmite of finance" (for those of you not in the UK who do not know Marmite, it is a sandwich spread that you either love or hate, never anything inbetween)
• He suggested that every quant needs a much more fundamental and practically grounded understanding of financial mathematics.
• Paul refered to some work (mentioned by Giovanni) that Peter Carr of Bloomberg had done on discrete daily hedging that showed that this option replication technique could remove up to 85% of the risk and that all quants should know about this 15% error term when trying to calculate an option price to the Nth decimal place.
• He described how in the past he had set up a volatility arbitrage hedge fund, wanting to improve upon the flawed assumption of the Black-Scholes (B-S) model that volatility is constant and to build the world's best volatility model for option pricing.
• Paul said that he did build the world's best volatility model (?!), but soon found it took too long to calculate, so he reverted back to B-S and has become an unfashionable fan of the model and its assumptions.
• He added that many of the variants on B-S to overcome its limitations have made the model worse and harder to calibrate.
• In some part due to Taleb's opinions on fat tails of distributions, B-S and other models are now very unpopular but Paul claims that not many people have actually bothered to robustly test the B-S model or take a practical, evidence based approach such as that adopted by Peter Carr.

• Paul then showed some example charts and said that with a limited number of opportunities for regular time-period hedging it was not valid to use risk-neutral pricing whereas if the same number of hedges could be used optimally (implying at irregular time periods) then risk-neutral was valid and hedging could be more effective. He emphasised that this was the kind of practical stuff that a quant should know and that quants show know less about esoteric complex financial mathematics.

Correlation

• Paul said that of all of the issues that need addressing in mathematical finance, the one that he has very few answers on is correlation.
• He showed that even basic questions about correlation are poorly understood, even by quants - a question he asks some quants was that if two asset prices both start out at 100, and they have a correlation (of returns) of 1 (perfect correlation) what is the price of the second asset after a year if the first moves to 200. The answer is not 200, and he showed how assets could diverge in overall direction but still have a correlation of 1 or rise together with a perfect negative correlation of -1.
• Paul illustrated how correlation was a very blunt measure that is mis-used by people to summarise the highly complex and historically unstable relationships between assets driven for example by industry sector success (leading to +ve correlation) or competitive success (leading to -ve correlation)
• As a result, he said that financial products whose value depends on correlation should not be transacted in any great size and moved on to the example of CDOs, where a CDO with 1,000 underlying mortgages has been modelled with 1/2 million correlations all assumed to be 0.6. Why this assumption should be made was his main point.

Sensitivity to Parameters

• His main point here was that a constant should not be varied, otherwise it is not a "constant", in particular focussing on volatility used in the B-S model and the calculation of Vega as prices are moving.
• Paul added that sensitivity measures may apply locally and is such may look comparible from one situation to another, but quants need to understand how outputs respond over a wider range of inputs, and not to be inhibited by accepted practices and beliefs.

Complexity

• Models need to be robust and transparent, and that quants should aim for the mathematical sweet spot.
• Paul put forward the following analogy that at least when driving an old car over a long distance, you knew that the car was likely to break down at least once, but you also knew that it was likely that you could fix it. Contrast this with driving a modern sports supercar and finding that it has (unexpectedly?) broken down - you don't know how to fix it, you do not complete your journey and it costs you an ordinate amount of money to put things right...

Self-Referential Feedback

• Paul described here how the hedging of derivatives contracts in the underlying markets can cause price movements in underlying markets that cause derivatives contracts to re-price that cause more hedging in the underlying markets...
• He was critical of credit derivative pricing as being too complex and too "mathsy" (...but had to admit that he had also endorsed some of this work at the time)

Calibration

• Paul said that model parameter calibration is the devil's work...
• He refered us to inverse problems in mathematics as a background to this issue in mathematical finance.
• He emphasised how markets and price behaviour is fickle and driven by human opinions and behaviours
• He said that on-going and regular re-calibration of a model is very, very likely to mean that the model is wrong (he had a particular example of calibrating a particular model he hates where vol is a function of underlying price and time.

David Rowe, Sungard's specialist spokesman on risk management, then took over from Paul and set out his five topics for discussion:

• Statistical Entropy - fundamentally that information can only be extracted from data, with the emphasis on extraction of information (from that already in the data) rather than creation of new information.
• Structural Imagination - that we need to be aware of how the market assumptions we make are themselves a model and that we need to spend more time on thinking about what could happen outside our current understanding or market experience.
• Self-Referential Feedback - the feedback loops in pricing, risk management and economics
• Complexity and Dark Risk - when you add (untested) complexity of a model to limited data sets you get a recipe for disaster.
• Alternate Means of Valuation - when the primary means of valuing a security is not available (illiquid markets anyone?) then what is the secondary means of calculation value.

Some further notes from David's talk:

• AAA rating should imply a failing once every 10,000 years, with some super senior CDO tranches being rated as better than AAA - David pointed out that even as recently as the early 1990s there were problems in the US housing market that indicated that AAA did not mean what it was taken to mean.
• On structural imagination, David said that quants and risk managers must look for unrepresented variables in a model and track them early to monitor their effects
• On feedback he cited an example where increased returns drove product innovation which drove up (CDO) volumes, which caused underwriting standards to fall, that allowed further complexity, that then led to unreliable risk estimation which then led to more product innovation... and so on.
• He suggested that quants adopt the "second means of valuation" mantra in a similar way to credit specialists always having the mantra when assessing credit of "what is the second means of repayment" (e.g. a lien on a house) when the primary means (mortgage payments) goes away.
• David showed a nice classification from an IASB paper on classifying financial instruments:

Level 1: fair values measured using quoted prices in active markets for the same instrument.

Level 2: fair values measured using quoted prices in active markets for similar instruments or using other valuation techniques for which all significant inputs are based on observable market data

Level 3: fair values measured using valuation techniques for which any significant input is not based on observable market data

David additional proposed the interesting level of "Level ?" for some products, and said that obviously more attention needs to spent on Level 2 and 3 instruments under conditions of reduced (non-existant?) market liquidity.

Summary Session:

Paul and David then answered some questions from the audience:

• Paul said that some risk managers lacked the imagination necessary for good risk management, being confined in standard procedures, beliefs and ways of doing things. He wants risk managers who are good at thinking laterally.
• Paul said that risk management was often an afterthought, not part of the trading process.
• David said that VAR has proven useful despite its weaknesses, in his opinion preventing failures from non-extreme events regardless of the recent extremes
• David said that in answer to Taleb's criticism of using history in modelling, it quite frankly is all we have to go on. He quoted Mark Twain in that:

"History does not repeat itself but it does rhyme"

The talks were interesting, and even on points that have been discussed elsewhere both speakers had some interesting slants and good analogies. But maybe I am biassed, as the wine afterwards wasn't bad either!...