WOULD THE CCAR CATCH WAMU? - MOODY'S ANALYTICS

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WOULD THE CCAR CATCH WAMU? - MOODY'S ANALYTICS
economic & COnsumer credit Analy tics

                                                       July, 2012

 Moody’s analytics

Would the CCAR Catch WaMu?

Prepared by
Tony Hughes
Senior Director
610.235.5000
Would the CCAR Catch WaMu?
By Tony Hughes

I
    n 2008, as a result of massive losses in its risky mortgage portfolio, Washington Mutual, better known as
    WaMu, failed. The bank had been in existence for more than 100 years, surviving the Great Depression, myriad
    smaller recessions, two world wars and many other tribulations. As the institution of bank stress-testing be-
comes more entrenched with every passing month, the episode becomes a salient and stark example of why such
an exercise is desirable. This is true for regulators, who are charged with avoiding the need for future bank bailouts,
and for bank managers, who want to avoid the ignominy of following WaMu down the sinkhole while still earning
good returns for shareholders.
    WaMu was not the only bank to fail in         it was instead the collective actions of many     used by the Fed in carrying out the CCAR.
the 2008/2009 recession though it was, by         WaMus that triggered the financial crisis and     Bear in mind that the public documentation
far, the biggest.                                 the subsequent recession that we are all still    on the methodology employed is relatively
    According to FDIC data, the history of        trying to shake off.                              scant, so some details will need to be in-
large-scale bank failures in the U.S. since           One of the Fed’s responses to the reces-      ferred1. We will then outline aspects of our
the formation of the Federal Reserve is           sion has been the institution of the Com-         approach to bankwide stress-testing by
marked by only three distinct events. Fail-       prehensive Capital Analysis and Review            describing the way our methodology devi-
ures spiked during the Great Depression of        stress-testing exercise. The purpose of the       ates from the inferred view of the CCAR.
the 1930s, the savings and loans crisis of the    CCAR—an annual test—is to determine the           As motivation for the analysis, we will seek
late 1980s and early 1990s, and the recent        soundness of banks and thus the robustness        to answer the question of whether either
period between 2008 and 2010. These eras          of the U.S. banking industry. Applying the        approach would have been able to identify
are interesting because in each case the          test to the biggest banks, the failure of any     problems at WaMu during the last few years
stresses were caused, at least in part, by the    of which could have macroeconomic con-            of the bank’s existence. Our basic conclusion
actions of the banks themselves; lack of ef-      sequences, Fed officials want to ascertain        is that, even under ideal conditions, a pro-
fective regulation was also central. All three    whether the banks hold sufficient capital to      cess like the CCAR would have been unlikely
events were sparked by the overly generous        cover losses that might arise under an ad-        to identify the WaMu failure in a manner
provision of credit through a boom and the        verse economic scenario. One could argue,         that would have allowed the bank to survive
subsequent rise in defaults that followed a       given that the Great Recession has already        and flourish. It is our contention, though,
correction in asset values. In the Great De-      exposed banks to severe stress, that survi-       that a process that incorporates the features
pression, it was margin lending on stocks,        vors are likely to be basically sound. With       we describe would have a far better chance
and the S&L and subprime crises were due          that said, we feel that the Fed is correct in     than one that does not. We hope to there-
mainly to mortgage lending. To add fuel to        trying to establish a stress-testing institu-     fore influence the Fed’s approach to design-
the argument, the same thing happened in          tion that will have solid foundations and         ing future installments of the CCAR.
commercial real estate and stocks in Japan        widespread acceptance the next time a truly           The main features we will focus on will
in the late 1980s, triggering a decade-long       stressful situation arises in the banking in-     be the need to take a dynamic, rather than a
banking crisis. A deep recession in the U.S. in   dustry. The new test has apparently caused        static, view of the portfolio, the endogeneity
the early 1980s, meanwhile, did not trigger       angst in many banks. This is not necessarily      of the economy in the context of a manic
major banking sector problems. Bank fail-         a bad thing—regulators are, after all, sup-       banking industry, the prejudice toward an
ures, simply, are not caused by recessions.       posed to be pebbles in the shoes of those         unnecessarily granular view of the portfolio,
Rather, it is banks causing recessions that       being regulated.
causes banks to fail. WaMu could not have             The purpose of this article is to describe,   1 Should the Fed release these details, we will make the in-
caused the 2008-2009 recession on its own;        insofar as can be ascertained, the process          formation available and if necessary revise our comparison.

MOODY’S ANALYTICS / Copyright© 2012                                                                                                                                1
ANALYSIS �� Would the CCAR Catch WaMu?

and the need to quantitatively assess the        to identify the linkages between credit per-                two banks with books that are currently
entire profit-and-loss statement of banks        formance and the modeled macroeconomic                      identical in every respect. Under CCAR, at
rather than just risks related to the as-        drivers and thus project credit performance                 least in terms of the statistical analysis used,
set side of the balance sheet. We will first     conditional on the adverse events actually                  both banks will be required to hold exactly
describe the salient features of the CCAR        occurring. We have numerous quibbles with                   the same amount of capital against any
exercise as it was implemented in 2011. We       the exact nature of the SSS: that it should be              future losses. Now suppose that one bank
will then outline our key arguments in turn      defined regionally, cover more factors, and                 has adopted an aggressive, some might say
before concluding with policy directions the     should be delivered with an accompanying                    reckless, growth policy and that the average
Fed might consider when moving forward           narrative describing the circumstances of the               quality of the assets held by the bank has
with the task of bank stress-testing.            event. These minor points are not the main                  been declining rapidly for the past couple
                                                 thrust of this article.                                     of years. The second bank appointed a new
How the CCAR Was Implemented                         In each major credit product category,                  chief executive officer a year or so back who,
    The CCAR seeks to answer the question        the Fed gives a very brief description of how               chastised by the events of the subprime
of whether the capital position of each bank     the models were developed. In general, the                  crisis, has adopted a sober, defensive strat-
is sufficient to withstand the effects of a      Fed sought to use a single, industrywide ge-                egy of careful loan underwriting; this bank
severe downturn in the macroeconomy. As          neric model to forecast each bank’s portfolio               is therefore seeing average loan quality get
part of the process, each bank submitted         so that the comparison was made on a fair                   better with every passing quarter. Which
a detailed capital plan covering activities      and equitable basis. The models use indus-                  bank is more likely to fail? The bank stress
over the nine quarters through early 2014.       try-level information derived from very high                test should assume that banks have ongoing
The Fed is keen to determine whether banks       quality data sources and, where possible,                   concerns and thus will continue to originate
have capital planning procedures in place        use loan-level specifications to determine                  new and extend existing loans both now and
to enable them to continue operations even       the relationships between credit variables                  in the future3. It should thus consider dy-
in a severe downturn. The banks submitted        and economic data2. Where loan-level data                   namics in the nature of each bank’s portfolio
detailed information about the nature and        are insufficient or unavailable, portfolio-                 position and not merely undertake a static
volume of loans in a wide variety of loan        level data are used instead. Each broad                     analysis of the current book. The Fed could
categories, and projections of credit losses,    product category, ranging from sandy credit                 argue that this point is already covered by
revenues, expenses and capital ratios were       cards, through rocky commercial mortgages                   the more qualitative aspects of the CCAR—
then constructed using a severe economic         to mountainous commercial loans, uses a                     banks need to justify future capital provi-
scenario supplied to the banks.                  somewhat different methodology. We note                     sioning plans—but we feel that the rigorous,
    The Supervisory Stress Scenario is at the    that all rock forms are mineral deposits of                 more objective, analytical parts of the CCAR
heart of the analytical components of the        one form or another so the discussion here                  should incorporate analysis of future loan
CCAR. The balance sheet position of each         covers all credit categories. Our purpose in                originations. Though we do not know which
bank was determined assuming both a base-        this article requires only a broad-brush view               specific loans will be undertaken in a future
line and stressed outcome for the economy        of the CCAR process.                                        period, we can estimate the relationship
and the results were compared. The Fed as-           Once the loan loss and revenue projec-                  between economic conditions and overall
sumed that all of the cash flows described       tions are aggregated for each bank, the Fed                 lending activity and use this as the basis to
in each bank’s capital plan would be fulfilled   compares the results with the capital held.                 project future overall loan volume and the
even if the adverse scenario was playing         If this is deemed insufficient, the Fed may                 underlying average quality thereof. If we
itself out. It was thus making the conserva-     limit capital disbursement from the bank,                   can then ascertain the relative risk appetite
tive assumption that dividend payments and       mainly in the form of denying requests for                  of banks, both planned and present, we can
the like would take place even if the bank       dividend increases or payments. Indeed, in                  further determine the share of this activity
was suffering extreme credit losses. Under       the 2012 installment of the CCAR several                    that each is likely to capture.
the SSS, the economy is assumed to suffer        banks were required to reduce plans to offer                    It is highly likely that the next stressful
an immediate, severe recession with an in-       a dividend to shareholders.                                 banking event will be sparked by loans that
determinate cause. The unemployment rate                                                                     do not exist today. Imagine an alterna-
spikes to 13% very quickly after the start of    Future Loans Are a Must                                     tive reality where the CCAR exercise was
the hypothetical scenario and median exist-         The CCAR process quantitatively judges                   conducted in October 2004. Further sup-
ing house prices fall by an additional 20%       the soundness only of loans currently held                  pose that the SSS employed at the time
to 25% across the U.S. This is quite a severe    on the balance sheets of the banks. Imagine                 exactly matched the economic data that
event and is comparable to the Moody’s An-
alytics S4 scenario, which is very dire in na-   2 The models are, in many cases, very reminiscent of many   3 Indeed the Fed has a mandate to ensure that lending and bor-
ture. The Fed takes these scenarios and seeks      existing Moody’s Analytics tools.                           rowing do not cease, even (or especially) in a deep recession.

MOODY’S ANALYTICS / Copyright© 2012                                                                                                                                        2
ANALYSIS �� Would the CCAR Catch WaMu?

were actually observed between that date                            embedded in the WaMu portfolio. Going                   The Fed is obviously concerned with the
and WaMu’s demise4. Even WaMu, at that                              forward, the Fed could induce a bubble in           identification of banks at risk of failure, but
point, had relatively few subprime, option                          each of the major lending categories in-            it should also be tasked with taking action
ARM and NegAm mortgages on its books. It                            dependently—commercial and industrial,              to avert such failures. Banks, and by exten-
is no coincidence that in October 2004, in a                        commercial real estate and retail—and then          sion regulators, can exert far more control
bid to boost its flagging mortgage business,                        assess whether each bank would survive              over loans that have yet to be booked. If the
WaMu announced option ARM mortgages                                 given existing and proposed business strate-        Fed is interested in using the stress test as
as its new flagship product. Over the subse-                        gies. The lesson of Japan also highlights the       a means to influence risk-taking behavior
quent 2½ years, WaMu would initiate most                            potential for multiple simultaneous bubbles,        in banks, it should seek to understand such
of the loans that would ultimately cause the                        and such a test should also be applied to           risks before the genie is let out of the bottle.
bank’s demise.                                                      each bank. A stress test involving multiple
    Is it possible to design a stress test, un-                     bubbles would almost certainly cause many           Endogeneity
der these hypothetical circumstances, that                          banks to fail but, at the end of the day, this is       All the evidence points to the Fed’s using
would have identified the susceptibility of                         the very point of conducting the test in the        a “tailpipe” model to conduct the stress test.
WaMu without a lot of false positives?                              first place.                                        A specific, generic stress scenario is delivered
    The CCAR process should be able to                                  The technology to conduct this type of          to banks and this is used by the Fed to con-
achieve this: if not, the process is danger-                        stress test already exists. In CreditForecast.      struct stressed forecasts. The exact genesis of
ously flawed. The key is to take the bank’s                         com, Moody’s Analytics constructs, using            the assumed stress is not stated. The econo-
publicly stated 2004 strategy at face value,                        Equifax data, forecasts and scenarios for the       my experiences a sharp recession under the
assume a successful ramp-up of its business                         industrywide aggregate consumer loan port-          scenario—we can only hazard guesses as to
in subprime and option ARM mortgages un-                            folio that include the nature, volume and           the causes of this hypothetical recession.
der rising asset prices and then project how                        subsequent performance of future cohorts.           The economy does not boom in the lead-up
these loans would have gone under subse-                            We can predict the nature of demand for             to the event, so it is fair to assume that the
quent recession conditions and falling house                        new loans at a future point in time—such            stress event is really a “double dip” version of
values5. Researchers in 2004 probably would                         demand is strongly pro-cyclical. We can also        the 2008-2009 Great Recession.
have understated the rise in mortgage activ-                        predict the overall aggregate balance sheet             Tailpipe models are so called because
ity during the boom, though a significant rise                      position of banks and the supply of liquid-         they assume that the economy can affect
in volume would have been predicted given                           ity provided by the Fed and bond markets.           the behavior of the entities being modeled,
the strength of house price appreciation                            We can predict inflation. Putting all this          but that the behavior of the entities them-
from 2005 to 2007 implied by the scenario.                          together allows us to infer, with some accu-        selves cannot affect the performance of the
Further, in terms of the loan-level assess-                         racy, the future price and volume of credit in      economy. If loans in the portfolio start to
ment of relative risk appetite, even if you                         a variety of different retail markets. A similar    default en masse, in the world defined by the
restrict yourself to loan data as they existed                      approach could be applied to commercial             Fed scenario, the fallout generated will not
back in 2004, we suspect that the folly of                          and industrial loans; indeed this is a feature      feed back to the behavior of asset markets
WaMu’s strategy would be fairly clear. It was                       of the recently released Moody’s Analytics          and thus the economy. Given that we have
well known even then that alternative mort-                         Stressed EDF product. In the approach to            just gone through a subprime-mortgage-
gage products aimed at low income clients                           modeling bank portfolios that is contained          triggered monster recession, one would think
were substantially riskier than traditional                         in the Moody’s CreditCycle product, indi-           that making the economy endogenous in any
products (i.e. the relative riskiness of vari-                      vidual bank loan underwriting criteria are          bank stress-testing paradigm would be at the
ous loan types was quite well understood at                         then combined with forecasts of economic            very top of the Fed’s analytical to-do list.
the time). A combination of stronger than                           conditions to project bank-level future origi-          The ability of the analyst to endogenize
normal loan growth, albeit weaker than that                         nations in terms of volume, quality and per-        the economy in modeling single portfolios
which actually occurred, combined with a                            formance. The structure here is that while          or single loans is highly doubtful. In macro-
reasonably accurate view of relative credit                         banks cannot influence the aggregate credit         economic analysis, individual entities such
risk would have suggested elevated losses                           supply curve in any given industry, they can        as banks are typically assumed to be price
                                                                    determine their own appetite to provide             takers, unable to influence overall economic
4 This scenario was obviously severe enough to fell a lot of        funding to various clients. We routinely find       outcomes. If one bank chooses not to extend
  banks, including WaMu. It’s worth noting that such a sce-         that the highest losses occur when a short          a loan to a broadly creditworthy individual,
  nario would have been criticized as being too tough had it
  been imposed back then.                                           boom occurs, allowing the bank to ramp up           another bank will fill the breach. In model-
5 Note that in this 2004 scenario, the economy experiences          volume in its portfolio, followed by a deep         ing industry-level aggregates, however, it is
  two years of solid growth followed by a very serious recession.
  A pure recession scenario applied to the static 2004 WaMu
                                                                    recession. In our view, the SSS should em-          straightforward to have feedback between
  portfolio would not have caused any red flags to appear.          body similar dynamics.                              the economy, credit volumes and loan per-

MOODY’S ANALYTICS / Copyright© 2012                                                                                                                                   3
ANALYSIS �� Would the CCAR Catch WaMu?

formance. Such interdependencies allow vi-         the Fed seems very concerned with classify-                       The Fed has, however, made it clear that
cious cycles, such as the three U.S. examples      ing the relative riskiness of any number of                   such a granular view of the portfolio is re-
cited in the introduction, to be accurately        different fragments of the banks’ loan port-                  quired. The speculation in the industry is that
represented. In our view, the Fed should           folios. In the document describing how first                  the next round of stress tests will apply loan-
have designed a stress test that provides          mortgages are treated, for example, the Fed                   level models—the ultimate in granular port-
internally consistent baseline and stressed        asked banks to quantify exposures in 19,440                   folio views, encompassing literally hundreds
projections of industry-level lending volume,      different portfolio segments. For HELOCs,                     of millions of prediction errors.
industry-level average loan quality and thus       meanwhile, 25,920 different segments were                         Granularity is not an end in itself. Indeed,
industry-level PD, EAD and LGD for each            required. The implication, we guess, is that                  focusing exclusively on individual trees, or
asset category. In stress-testing individual       WaMu was destroyed by a metaphorical                          even individual species of tree, in a dying for-
banks’ portfolios, assumptions of market           bomb in a third-floor broom closet and that                   est is a proverbially bad idea. In the subprime
share and loan-level empirical assessments         sifting through the building with a fine-                     crisis, all different species of mortgages
of relative risk appetite could then be used to    tooth comb would have been the only way                       experienced elevated default and loss rates.
allocate industry-level credit loss projections    to defuse the situation. Would WaMu have                      Some species were strong enough to survive
to individual banks. Because the aggregate         survived the CCAR if, say, 10 portfolio seg-                  while others are, quite literally, on the road
projections would then imbed vicious cycles,       mentations were used for analysis in place of                 to extinction. It is important to know how
individual bank or individual loan projections     the 45,360 different segments actually used                   robust particular species will be in the con-
would implicitly do so too.                        by the Fed? The reality, of course, is that                   text of a dying forest; this is very worthy of
    These macroeconomic principles of endo-        picking apart bank portfolios to that extent                  research and it is what the Fed’s CCAR test
geneity should be central to any bank stress-      clouds more than it illuminates. Show the                     apparently achieves. It is more crucial to
testing exercise. The CCAR project itself          CCAR description to William of Ockham and                     understand why the forest is dying and if it’s
does seem to reflect some macroeconomic            the Gordian nature of the Fed modelers’ task                  the loggers who are responsible.
principles, though details are unquestionably      would have been immediately apparent.                             Interestingly, a granular view is also avail-
(and almost certainly deliberately) sketchy.           At the end of the day, the Fed needs a                    able in another key factor that the Fed seeks
The description of the Fed’s approach to           prediction of portfolio level aggregates. It                  to forecast and stress-test: inflation. In our
mortgage stress-testing, for example, first        needs to know, under the SSS, if expected                     databases, there are more than 40 different
outlines the basic structure of the microeco-      portfolio losses exceed reserved capital. If                  sub categories of the CPI, in areas such as
nomic loan-level models that it presumably         the Fed looked only at a time series of past                  used vehicles and alcoholic beverages. Go-
uses to assess relative loan default likelihood.   bank losses relative to economic factors, it                  ing further, the Fed could use data sets such
It then goes on to say: “resulting estimates       could achieve its goal while committing only                  as that developed in the Billion Price Proj-
are combined with industry-wide informa-           a single, though possibly large, prediction er-               ect and base its national core CPI inflation
tion about the characteristics of outstanding      ror. In modeling 45,360 different segments6,                  forecasts on the dynamic behavior of every
residential mortgage loans as of September         it will commit 45,360 different errors. Even                  one of those prices. It does not follow this
30, 2011, and the variables defining the Su-       if these individual errors prove to be tiny,                  approach, preferring simple macro models
pervisory Stress Scenario…”                        adding up so many different errors will likely                that appropriately capture feedback loops
    To us, this description approximates a         result in the overall prediction error variance               and business cycles. Empirical studies have
hybrid approach, using a loan-level model          exceeding the rate of error committed under                   shown that even a small amount of granular-
to find relative concentrations in the banks’      the simple modeling approach. Note that we                    ity in inflation forecasting can be detrimen-
portfolios while using industrywide macro          are not advocating the simple approach—                       tal. No one has yet proposed forecasting the
data to pin down the broader performance           such a method would vastly understate                         national core rate of inflation by using the
of the industry should a stressful scenario        the importance of concentrations in the                       billion separate prices contained in the BPP.
unfold. Exactly how the estimates are “com-        portfolio, which is typically heterogeneous                   One wonders why the Fed views granularity
bined” is, however, unclear. Our approach to       in nature. We are instead asking the ques-                    as crucial in one of its endeavors and fatally
such combination of loan-level results with        tion of whether 45,360 segmentations is the                   poisonous in another. Prices, after all, are
industry-level aggregates, which we have           optimal number or whether something lower                     arguably far more heterogeneous than bank
previously documented, is to calibrate the         would achieve greater modeling precision. It                  credit portfolios.
loan-level results to industry-level baseline      seems clear to us that the optimal number                         Parsimony is a golden rule in forecast-
and stressed projections.                          would be in the tens or hundreds and cer-                     ing, of which stress-testing is a new, key
                                                   tainly not the tens of thousands.                             sub-branch. Every prediction comes with
Granularity and Red Herrings                                                                                     error, so making 45,360 distinct errors in
                                                   6 This number is only for the mortgage portfolio; the total
  The scant methodological descriptions of           number of portfolio segments considered would actually be
                                                                                                                 assessing a portfolio carries a high degree of
CCAR that exist in the public sphere indicate        around 100,000.                                             forecast risk. If these individual predictions

MOODY’S ANALYTICS / Copyright© 2012                                                                                                                             4
ANALYSIS �� Would the CCAR Catch WaMu?

are calibrated to a separate industry- or           sions—though the effect seems fairly weak.        of each bank’s liabilities book headed into a
portfolio-level prediction, this problem is far     Looking through the demand for money              stressful event.
less serious. A hybrid modeling approach en-        balances literature, which is a very old strand
sures that loan-level granularity can still be      in economics, splits the demand for bal-          Conclusion
achieved without compromising the accura-           ances between transactions demand—the                  Had WaMu been the only bank engaged in
cy of key industry- or bank-level projections.      cash that people need on hand to conduct          risky subprime lending, an entirely different
                                                    normal business—and the so-called specula-        story would now be playing itself out. Under
Liabilities Also Sink Banks                         tive demand. Transactions demand declines         this reality, WaMu would still exist and indeed
    The final months of WaMu were appar-            in recessions as nominal GDP growth slows         could well be seen as a model institution with
ently marked by two distinct bank runs. Both        or backtracks and rises in booms. Specula-        strong asset growth and elevated profitabil-
occurred at a time when senior executives ei-       tive demand for money depends crucially on        ity. It would likely be seen as a bank with a
ther thought that survival was possible or that     prevailing interest rates and the potential       strong social conscience given its willingness
a sale of the bank could still be made without      spoils that could be earned from alternative      to lend to individuals otherwise locked out of
FDIC intervention. The first run occurred in        investment options. In the current environ-       the mortgage market by blemishes in their
July 2008 as similar events were unfolding          ment where stock prices are stagnant and          former credit history. Indeed it could by now
at IndyMac. A total of $9.4 billion was with-       house prices are falling, we would expect         have even achieved CEO Kerry Killinger’s aim
drawn from WaMu during the month, even              retail speculative balances to be quite high      of being viewed as the Walmart, Starbucks,
though most of the funds taken out would            given the lack of alternative investments. The    Costco or Lowes/Home Depot of the banking
have been guaranteed by the federal govern-         proportion of people holding cash stuffed in      industry. WaMu failed not because of sub-
ment. The second run occurred in September          mattresses would also be quite high though        prime lending per se but because it was one of
in the weeks leading up to the failure, reaching    this effect is difficult to measure accurately.   the biggest and most egregious participants
a crescendo on September 18 when $2.8 bil-          On the commercial side, meanwhile, busi-          in a dangerous game that many were playing.
lion was withdrawn in a single day. These bank      ness investment has recovered somewhat            It is this collective behavior that is crucial in
runs were arguably the final nail in the coffin     since the end of the recession though cor-        understanding the circumstances under which
for WaMu, and within days the FDIC sold the         porate profitability has been very strong,        banks are bound to fail.
bank to JP Morgan for a paltry sum.                 yielding a large amount of corporate cash on           The existing CCAR methodology does not
    In WaMu’s case, you could argue that the        hand. Putting all this together, one starts to    adequately take account of collective behav-
bank run would not have occurred without            build up a model of aggregate, or economy-        ior in its structure. The economy is seemingly
the asset losses that had already become ap-        wide, demand for liquidity. The supply side,      treated as an exogenous driver of credit perfor-
parent. This presents a very interesting model-     meanwhile, is largely controlled by the cen-      mance and it overwhelming relies on an aggre-
ing problem whereby the capital adequacy            tral bank through the interest rate mecha-        gation of many separate credit decisions in de-
position of the bank—which you are trying to        nism and associated novel procedures such         termining the likelihood and severity of future
model and predict under stress—is directly          as quantitative easing.                           credit losses. Future lending behavior is not
affected by public perceptions of the bank’s            At the bank level, meanwhile, the abil-       factored in to the quantitative portfolio analy-
capital adequacy position. Failures, when they      ity of one bank to attract deposits more          sis, meaning that by the time WaMu might
come, will therefore happen with ferocity as        successfully than competing banks would           have been identified as at-risk by the CCAR,
the bank’s ability to raise new capital dwindles    crucially rest on the relative price and qual-    the seeds of its failure would have already been
in the face of mounting credit losses. The final    ity of the services offered. Factors such as      sprouting. One could reasonably argue that
death throes of a bank under stress probably        deposit interest rates would obviously be         booms rather than recessions cause banks to
cannot be predicted, especially in terms of         relevant but service related drivers such as      fail, and yet the SSS does not factor in a credit
timing; this is certainly true for an institution   loyalty schemes, branch and ATM spread,           boom in the lead-up to the hypothetical severe
that is currently healthy and solvent.              and branch staffing would all be critical. Fee    recession. We feel that future installments of
    What can be predicted, though, is the           structure would also be important in deter-       the CCAR should adequately consider these
bank’s deposit book on the eve of the crisis.       mining the price of services offered by the       kinds of macro-dynamic behavior in assessing
Assessment of aggregate bank deposits               bank in question. Using reasoning such as         individual bank capital adequacy.
shows that some counter cyclicality is evi-         that presented, one should be able to rea-             No bank is an island unto itself. Future
dent—deposits tend to decline during reces-         sonably forecast the size and dynamic nature      CCARs should fully reflect this.

MOODY’S ANALYTICS / Copyright© 2012                                                                                                                  5
AUTHOR BIO �� 							                                                                           		                www.economy.com

About the Authors
Tony Hughes
    Tony Hughes is senior director of Credit Analytics at Moody’s Analytics, where he manages the company’s credit analysis consulting projects
for global lending institutions. An expert applied econometrician, Dr. Hughes also oversees the Moody’s CreditCycle and manages CreditForecast.
com. His varied research interests have lately focused on problems associated with loss forecasting and stress-testing credit portfolios.
    Now based in the U.S., Dr. Hughes previously headed the Moody’s Analytics Sydney office, where he was editor of the Asia-Pacific edition
of the Dismal Scientist web site and was the company’s lead economist in the region. He retains a keen interest in emerging markets and in
Asia-Pacific economies.
    A former academic, Dr. Hughes held positions at the University of Adelaide, the University of New South Wales, and Vanderbilt University
and has published a number of articles in leading statistics and economics journals. He received his PhD in econometrics from Monash Univer-
sity in Melbourne, Australia.

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MOODY’S ANALYTICS / Copyright© 2012                                                                                                                                    7
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