first, an excerpt from Extend and Pretend by John Hussman
With regard to credit conditions, the U.S. financial system continues to pursue a strategy of "extend and pretend." A year ago, the Financial Accounting Standards Board (FASB) suspended rule 157, which had previously required banks to mark their assets to market value when preparing balance sheet reports. The basic argument was that fair values were not appropriate because there was "no market" for troubled assets. Certainly, the FASB could have implemented something at least modestly reasonable, such as 2-year or 3-year averaging, but instead, they changed the rules to allow "substantial discretion" in the valuation of bank assets in their financial reports.
To a large degree, the idea that there was "no market" for troubled assets was false even at the time. Last year, Dean Baker of the well-regarded Center for Economic Policy Research (CEPR) testified before Congress, observing "There has been considerable confusion about the nature of the troubled assets held by the banks. While banks do hold some amount of mortgage-backed securities, these securities are in fact a relatively small portion of their troubled assets. The troubled assets on the banks' books are overwhelmingly mortgages, both first and second or other junior liens, not mortgage-backed securities. The FDIC has acquired large quantities of mortgages from its takeover of several dozen failed banks over the last year. It auctions these assets off on an ongoing basis. The results of these auctions are available on the FDIC website. Non-performing mortgages typically sell in these auctions at prices in the vicinity of 30 cents on the dollar."
He continued, "It is not clear on what basis these auctions can be said not to constitute a market. While the downturn and the constricted credit conditions affect the market, it is simply inaccurate to claim that there is no market for these assets. The major banks are undoubtedly not pleased at the prospect of having to sell off their loans at these prices, but this merely indicates that they are unhappy with the market outcome, just as a homeowner might be unwilling to sell her house at a loss. However, the unhappiness of the seller does not mean that there is no market."
The impact of "extend and pretend" is to create a gap between the reported value of assets and the value they would have on the basis of the cash flows that those assets can reasonably be expected to generate over their maturity. In order to avoid having to restate assets, banks have allowed an increasing gap to develop between the volume of delinquent loans and the volume of loans actually in foreclosure, creating a growing "shadow inventory" of impaired but unmodified and unforeclosed loans.
Moreover, regulatory changes over the past year have affected what actually gets reported as "troubled." As the New York Times recently observed, " A bank owed, say, $4 million on a property now worth $3 million would previously have had to classify the entire loan as troubled. Now it can do that to the $1 million difference only." In effect, even though impaired loans tend to sell at only 30-50 cents on the dollar (reflecting a modest haircut to the amount typically received in foreclosure), banks can choose the amount of assets it reports as troubled simply by choosing what value to assign the property while it holds the bad loan on its books.
While it's interesting that credit card delinquencies have eased off modestly in recent months, this is not necessarily a healthy sign. Even in the third quarter of 2009, TransUnion reported that consumers delinquent on their mortgages but current on their credit cards increased by 6.6%. In effect, people have been choosing to pay their credit cards in priority to their mortgages.
As for policy efforts to reduce delinquencies, I've long argued that it is a bad idea for policy makers to announce delinquency prevention plans that have, as their centerpiece, publicly subsidized reductions in mortgage principal. It's one thing to extend the loan in a way that preserves its present value, by swapping a claim on future appreciation in return for principal reduction, but it's quite another to offer to cut the principal outright. The reason is that instead of confining the assistance to presently troubled borrowers, you create a whole new set of borrowers who then choose to be troubled in order to get the assistance. According to a University of Chicago study, "strategic defaults" - where people choose to default on their mortgages even though they can afford to pay - accounted for 35% of all residential defaults in December 2009, up from 23% in March 2009. Offering public subsidies for this behavior, when too many homeowners are already legitimately struggling, does not smack of a bright idea.
The New York Times recently provided a good picture of how the delinquency situation stood at the end of 2009 (based on FDIC data):
The real concern from my perspective remains the potential for a second wave of delinquencies beginning in data as of the first quarter of 2010 and extending well into 2011. While we've seen some suggestions that many Alt-A and Option-ARM loans have already been modified, the premise of this argument is problematic since it is also true that about three-quarters of modified mortgages go on to default a second time, and few of these modifications result in substantial alterations in principal or interest payments beyond 12 months.
In short, my impression is that investors are deluding themselves about the solvency of the banking system. People learned in the 1930's that when you don't require the reported value of assets to have a clear and tangible link to the value that the assets would have in liquidation, bad things happen. Yet this is what regulatory and accounting rules are allowing for the banking system at present. While I do believe that bank depositors are safe to the extent of FDIC guarantees, my impression is that the banking system is still quietly insolvent.
youll note hussman refers to the coming second wave of delinquencies and ultimately, foreclosures…to give you a visual idea of what hussman is talking about here, a couple charts: this first one accompanies an article at calculated risk: New Credit Suisse ARM Recast Chart (click to view full size)
this second chart is from an article at the burning platform: extraordinary recklessness; you can see here that although the subprime mortgage crisis is just about over, the next wave of Alt A & option ARM resets is still to hit full force..
these charts dont even include the souring commercial real estate loans on the banks books, the primary cause for our recent spate of “FDIC fridays”, and which elizabeth warren warns may cause up to 3000 more bank failures…so the question remains, how long can this “extend and pretend” go on?
Note: im adding this late edit since its important and i dont want it to be buried in the comments: John Hempton at Bronte Capital explains The arithmetic of bank solvency – part 1
First observation: at zero interest rates almost any bank can recapitalize and become solvent if it has enough time.
Imagine a bank which has 100 in assets and 90 in liabilities. Shareholder equity is 10. The only problem with this bank is that 30 percent of its assets are actually worthless and will never yield a penny. [This is considerably worse than any major US bank got or for that matter any major Japanese bank in their crisis.]
Now what the bank really has is 70 in assets, 90 in liabilities and a shareholder deficit of 20. However that is not what is shown in their accounts – they are playing the game of “extend and pretend”.
Now suppose the cost of borrowing is 0 percent and the yield on the assets is 2 percent. [We will ignore operating costs here though we could reintroduce them and make the spread wider.]
This bank will earn 1.4 in interest (2 percent of 70) and pay 0 in funding cost (0 percent of 90). It will be cash-flow-positive to the tune of 1.4 per annum and in will slowly recapitalize. Moreover provided it can maintain even the existing level of funding it will be cash-flow-positive and will have no liquidity event. (It does however need to be protected from runs by a credible government guarantee.)
Now lets put the same bank in a high interest rate environment. Assume funding costs are 10 percent and loans yield 12 percent.
In this case the bank earns 8.4 per year in interest (12 percent of 70) and pays 9 per year in funding (10 percent of 90). The same bank with the same spread is cash flow negative.
bottom line: expect the Fed to maintain low interest rates “for an extended period” while we continue to extend and pretend..