Archive for the ‘Asset Liability Management’ category

Open or Closed?

July 9, 2013

Moorad Choudry provides a good description of how banks think about ALM in a new article in The Actuary, Asset/liability management: solid as a rock?.  

But he misses one very important point that to RISKVIEWS explains the difference between banks and insurer/pension plans with regard to ALM.  That difference is the title of this piece.

The bank ALM model assumes that the bank will remain Open.  Therefore, the bank always has the option to obtain the funds that are needed to pay near term liabilities.  Unless the unfortunate occurrence of a liquidity problem.  The second part of this story is that banks do not mark their banking book of assets to market.  The banking book supports their “maturity transformation” business.  By keeping from that MTM step the bank keeps its large mismatch “off the books”.  This position has been the case, according to Choudry, since the the first banks.

Insurer and Pension ALM assumes that the company/fund becomes Closed and no longer has any access to new funds.  The new idea, that is a part of IFRS accounting that an insurer will mark everything to market is entirely consistent with the assumption that the company is assumed to be Closed.

That Closed company assumption along with the approach to ALM that insurers now use crept into insurance practice in the past 40 years with application of ideas that were no more than 75 years old.  One source speaks of these ideas as Anglo-American practices.  And in the discussions of Solvency II, one of the thorny topics goes back to this assumption since the German life insurance industry tends to favor an Open company approach.

The insurance company adoption of Closed company ALM started after some insurers suddenly went into the maturity transformation business in a big way only to learn that there was a definite limit to the amount of maturity transformation that could be done by an insurer relative to the capital and operations of the insurer.  Some insurers, notably The Equitable, experienced very large losses and had their business severely disrupted.  Almost 20 years later, as if to prove the necessity of the Closed company approach, General American also experienced massive losses when most funds were withdrawn from their maturity transformation business.

Looking at the ALM topic in this manner allows one to see the real and fundamental difference between the two approaches and in a non-pejorative manner.

In one sense, the insurers seem to be much too restrictive, too risk adverse, in their approach to ALM by adopting a full Closed.  Of course, insurers are not all planning on Closing,  on going out of business.  So preparing for this risk as if they were seems like extreme over caution.

On the other hand, banks, over the centuries have been subject to numerous runs and mass failures.  The Open company approach leaves a bank subject to a large contagion risk.  Once one bank has a problem, all banks may become subject to excessive withdrawals and all but the most secure banks that had been run with an Open company approach will experience severe trouble which could lead to a cascade of failures.  That is the reason why one of the fundamental functions of the Central Banks is to provide emergency liquidity to banks that are fundamentally sound.

If insurers shifted to an Open company approach to ALM, then insurers would also be subject to the same sort of fragility as the banks.  Insurers are in a different business from banks, usually providing longer term promises that require a much higher degree of confidence in their ability to be able to fulfill those promises under extremely stressful circumstances.  If insurers were operated with the same degree of fragility as banks, it is quite possible that their business model would fail completely.

Very High cost for Asset Allocation Advice

May 10, 2012

Most investors in hedge funds must be looking at them totally marginally.  Certainly that is the way that hedge fund managers would suggest.

What that means is the ther investor should not look at the details of what the hedge fund is doing, it should only look at the returns.  Those returns should be looked upon as a unit.

Certainly that is the only way to think of it that matches up with the compensation for hedge fund managers.  They get paid their 2 and 20 based solely upon their performance.

But think for a moment about how an investor probably looks at the rest of their portfolio.  They look at the portfolio as a whole, across all asset classes.  The investor will often make their first investment decision regarding their asset allocation.

While hedge fund managers have argued for treating their funds as one or even several asset classes, they are almost always made up of investments, long and short, in other asset classes.  So if you are an investor who already has positions in many asset classes, the hedge fund is merely a series of moves to modify the investors asset mix.

So for example, if the hedge fund is a simple leveraged stock fund, the hedge fund manager is lowering the investor’s bond holdings and increasing the stock holdings.

So if an investor with a 70% 30% Stock bond mix changes their portfolio to 65%, 25%, 10% giving 10% to a hedge fund manager who varies runs a leveraged stock fund that varies from all cash to 4/3 leveraged position in stocks, then they have totally turned their asset mix over to the hedge fund manager.

When the hedge fund is fully levered in stocks then their portfolio is 65% long Stocks, 25% long bonds, plus 40% long stocks and 30% short bonds.  Their net position is 105% stocks with  5% short bonds.  But that is not quite right.  If you only get 80% of your performance, your position is 97% stocks and 1% bonds.  That is right, it is less than 100%.  Only it is really worse than that.  That is the allocation when performance is good.  When the stock market goes really poorly, you get the performance of the 105%/(5%) fund. 

Other funds go long and short large and small stocks.  The same sort of simple arithmetic applies there. 

It is really hard to imagine that anyone who thinks that there is any merit whatsoever to asset allocation would participate in this game.  Because they will no longer have any say in their asset allocation.  What you have done is to switch to being a market timer.  In the levered stock example, you now have a portfolio that is 65% long stocks and 35% market timing.  

So in most cases, what is really happening is that by investing in a hedge fund, the investor is largely abandoning most basic investment principles and shifting a major part of their portfolio asset allocation to a market timer. 

At a very large fee.

ERM in a Low Interest Rate Environment

June 14, 2011

(Excerpts from presenation at Riskminds USA)

A discussion of how the current low interest rate environment impacts choices for (1) interest rate risk, (2) other risks and (3) Enterprise Risk Management.
How an insurer might react to low interest rates depends to a large extent on risk taking strategy and their point of view about interest rate risk.  There are four primary strategies for interest rate risk:
  • Minimize Risk
    • The Classic ALM approach is designed to minimize risk.  Duration mismatch is a measure of the degree to which you failed to achieve risk minimization.  Most ALM programs allow for an acceptable level of mismatch which might be an operational risk acceptance or it might be an option to take some interest rate risk tactically.  Risk is evaluated compared to Zero (matched position).
  • Accumulate Risk
    • The classic approach of banks to interest rate risk is to accumulate it.  The Japan carry trade is an interest rate accumulation trade.  Life Insurers usually Accumulate Mortality Risk.  Non-Life Insurers usually Accumulate attritional Risks  Accumulation of risk usually means that there is no limit to the amount of the risk that may be taken if it is priced right.  Risk is evaluated compared to expected cost using Utility theory – accept risk if expected value >0.
  • Manage Risk
    • The New ERM approach to Risk is to Manage Risk by looking at Risk vs. Reward for the portfolio of risks including diversification effects.  Taking a Strategic or Tactical approach to making choices – Return Targets “Over the Cycle” or “Every Year”.  Risk is evaluate with an Economic Capital model.  Risk means increase in total enterprise Economic Capital.
  • Diversify Risk
    • Many firms pay attention to diversification, but few make it the cornerstone to their ERM.  Firms focused on diversification will accumulate a risk as long as it does not come to dominate their risk profile and if it is expected to be profitable, often taking a purely  Tactical approach to which risks that they will accumulate.  They may not even have a chosen Long Term Strategic view of most risks.  They evaluate each risk in comparison to other risks of the enterprise.  The target is to have no single large risk concentration.
There are two aspects of Point of View that you need to be clear about:
  • Long Term Strategic vs. Short Term Tactical
    • You might ignore both and imply avoid a risk
    • You might ignore Strategic and take risks tactically that might not make sense in the long run
    • You might Strategically decide to take a risk and ignore Tactical which means you take the risk no matter the environment
    • You might pay attention to both and always take the risk but vary the amount of the risk
  • Going Concern vs. Going out of Business
    • Classic ALM (and Economic Capital models) use a “going out of business” model
    • But the “Going Concern” model is much more complicated and requires assumptions about future business and should include a going out of business assumption
With these questions resolved a company can go about setting their strategy for interest rate risk taking in a low interest environment.
To do that they may want to look at three scenarios:
·Scenario 1 – Interest Rates stay low
·Scenario 2 – Interest Rates increase slowly
·Scenario 3 – Interest Rates increase quickly
For each scenario, look at the implications for both interest rate risk as well as all of the other aspects of their risk profile and their business strategy.  If a scenario shows results that are unacceptable, then the planners and risk managers need to develop strategies to avoid or mitigate the projected problem, should that scenario come to pass as well as triggers for initiating those activities should the scenario appear imminent.

Managed Risk Taking

May 12, 2010

Is your ALM system a risk management system or is ALM a process at your firm for managed risk taking?

It appears that banks and insurers both use the term ALM to refer to the process that they use with interest rate change risk.  But in general, banks are using ALM as a part of a managed risk taking system, while insurers are most often using ALM as a risk management system.

The difference is in the acceptable targets.  Insurers most often have a target for matching of assets and liabilities to within a 0.50 tolerance in difference in duration for example.  The tolerance is most often justified as a practical consideration, allowing the managers of the ALM system to avoid making too many expensive small moves and to gently steer the portfolio into the matched situation.

Banks will have a much larger mismatch allowance.  A part of the basic business of banks is to borrow funds short term and to lend them long term.  There is a significant duration mismatch embedded into their business model.  The ALM managers are there to make sure that the interest rate risk does not grow beyond those tolerances.  The bank should be setting the limit for mismatch to a level of loss that they can afford.

It is fascinating that for the most part, insurers who are generally buy and hold risk takers are unwilling to take advantage of the generally upward sloping yield curve in anywhere near the level that banks are.  Insurers tend to look at their risks as good risks and bad risks and to avoid any exposure to the bad risks if possible.  Interest rate change risk is seen as a bad risk, probably because (a) there us no underwriting, no selection involved and (b) the risk is totally uncontrollable.

Insurers like risks where they can develop an expertise of underwriting the risk, selecting the better risks over the worse risks.  Interest rate risk, at least within economies has no specific risk component.  If there was underwriting involved, that underwriting would be trying to figure out the forces that drive interest rates up and down.  And that is very difficult to do.

The interest rate change risk is totally uncontrollable because there is no claims management.  There is a major subjective, personal element in the form of the central bankers setting the rates at the short end.  The rates at the long end are driven by both supply and demand as well as by inflation assumptions.  So to get interest rates risht, one would need to read the minds of the central bankers, predict the need for funding and the amount of capital available at various rate levels for various terms as well as the expectations of the market for inflation.  Good luck.

There is another difference between banks and insurers that perhaps explains the difference in strategies.  THe banks are usually able to get their money on a short term basis, paying the low short term interest rates.  Insurers, on the other hand usually get their funds for a longer term.  They may not always need to promise a long term interest rate, but they usually want to keep their customers for the long term, so they want to make plans to pay interest rates at a level consistent with long term.

And if you follow yield curves over time, you will notice that the steepest and most reliable part of the yield curve is at the very short end of the curve.  At the middle of the curve, there is not always an upward slant that is large enough to justify the risk of a significant mismatch, not is it reliable enough to build your business off of it.

So maybe the two segments have it right for their situations.  Banks can have their managed risk taking system while insurers need their risk management system.

Assumptions Embedded in Risk Analysis

April 28, 2010

The picture below from Dour VanDemeter’s blog gives an interesting take on the embedded assumptions in various approaches to risk analysis and risk treatment.

But what I take from this is a realization that many firms have activity in one or two or three of those boxes, but the only box that does not assume away a major part of reality is generally empty.

In reality, most financial firms do experience market, credit and liability risks all at the same time and most firms do expect to be continuing to receive future cashflows both from past activities and from future activities.

But most firms have chosen to measure and manage their risk by assuming that one or two or even three of those things are not a concern.  By selectively putting on blinders to major aspects of their risks – first blinding their right eye, then their left, then by not looking up and finally not looking down.

Some of these processes were designed that way in earlier times when computational power would not have allowed anything more.  For many firms their affairs are so very complicated and their future is so uncertain that it is simply impractical to incorporate everything into one all encompassing risk assessment and treatment framework.

At least that is the story that folks are most likely to use.

But the fact that their activity is too complicated for them to model does not seem to send them any flashing red signal that it is possible that they really do not understand their risk.

So look at Doug’s picture and see which are the embedded assumptions in each calculation – the ones I am thinking of are the labels on the OTHER rows and columns.

For Credit VaR – the embedded assumption is that there is no Market Risk and that there is no new assets or liabilities (business is in sell-off mode)

For Interest risk VaR – the embedded assumption is that there is no credit risk nor new assets or liabilities (business is in sell-off mode)

For ALM – the embedded assumption is that there is no credit risk and business is in run-off mode.

Those are the real embedded assumptions.  We should own up to them.

Making Better Decisions using ERM

April 21, 2010

Max Rudolph provided a lecture on ERM for the University of Waterloo and the Waterloo Research institute in Insurance, Securities and Quantitative finance (WatRISQ).

Key Points:

ERM’s Role in Strategic Planning

  • Understanding the Risk Profile
  • Solutions are Unique
  • Using Quantitative and Qualitative Tools

ERM is Not:

  • A Checklist Exercize
  • A Rating Agency Exercize
  • Just About Risk Mitigation

Have You ever heard of the Financial Crisis?

And Much more…

Max Rudolph

Any Road Will Do

February 20, 2010

Is what the Cheshire Cat told Alice.  Since she did not know where she was going.

And unfortunately, that is where the European Bank Supervisors seem to be regarding Risk Management.  They just published a short paper entitled “High level principles for risk management”, which despite the lofty title gives very little clear guidance at a high level.   I will instead point you to something along the same lines that WAS well written that DOES represent actual principles of risk management.  I refer you to the BIS report in Interest Rate Risk Management from 1997.  Their 11 top principles are listed below.

A. The role of the board and senior management

Principle 1: In order to carry out its responsibilities, the board of directors in a bank should approve interest rate risk management policies and procedures, and should be informed regularly of the interest rate risk exposure of the bank.

Principle 2: Senior management must ensure that the structure of the bank’s business and the level of interest rate risk it assumes are effectively managed, that appropriate policies and procedures are established to control and limit these risks, and that resources are available for evaluating and controlling interest rate risk.
Principle 3: Banks should have a risk management function with clearly defined duties that reports risk exposures directly to senior management and the board of directors and is sufficiently independent from the business lines of the bank. Larger or more
complex banks should have units responsible for the design and administration of the bank’s interest rate risk management system.

B. Policies and procedures

Principle 4: It is essential that banks’ interest rate risk policies and procedures be clearly defined and consistent with the nature and complexity of their activities. These policies should address the bank’s exposures on a consolidated basis and, as appropriate, also at the level of individual affiliates.

Principle 5: It is important that banks identify the risks inherent in new products and activities and ensure these are subject to adequate procedures and controls before being introduced or undertaken. Major hedging or risk management initiatives should be approved in advance by the board or its appropriate delegated committee.

C. Measurement and monitoring system

Principle 6: It is essential that banks have interest rate risk measurement systems that capture all material sources of interest rate risk and that assess the effect of interest rate changes in ways which are consistent with the scope of their activities. The assumptions underlying the system should be clearly understood by risk managers and bank management.
Principle 7: Banks must establish and enforce operating limits and other practices that maintain exposures within levels consistent with their internal policies.

Principle 8: Banks should measure their vulnerability to loss under stressful market conditions – including the breakdown of key assumptions – and consider those results when establishing and reviewing their policies and limits for interest rate risk.

Principle 9Banks must have adequate information systems for monitoring and reporting interest rate exposures to senior management and boards of directors on a timely basis.

D. Independent controls

Principle 10: Banks must have adequate internal controls for their interest rate risk management process and should evaluate the adequacy and integrity of those controls periodically. Individuals responsible for evaluating control procedures must be independent of the function they are assigned to review.

Principle 11: Banks should periodically conduct an independent review of the adequacy and integrity of their risk management processes. Such reviews should be available to relevant supervisory authorities.

These principles are so universal that you will find that if you simply substitute the name of any other risk for the words “interest rate” in the sentences above, you will still have an excellent list of risk management principles.  In fact, just substitute the words “Bank”  or even “Insurer” for interest rate above and you now have a complete and coherent set of PRINCIPLES FOR RISK MANAGEMENT.

The most puzzling thing to me is that this BIS report has long been superseded by something with wording much more like the meandering and fuzzy report of the CEBS.  Don’t take my word for it, the newest version of this BIS interest rate risk management paper is available on their website.  Compare the wording of that report to these crystal clear principles and let me know where you see any improvements.


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