Credit Risk Transfer; Developments from 2005-2007
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Basel Committee on Banking Supervision The Joint Forum Credit Risk Transfer Developments from 2005 to 2007 Consultative Document April 2008 Requests for copies of publications, or for additions/changes to the mailing list, should be sent to: Bank for International Settlements Press & Communications CH-4002 Basel, Switzerland E-mail: [email protected] Fax: +41 61 280 9100 and +41 61 280 8100 © Bank for International Settlements 2008. All rights reserved. Brief excerpts may be reproduced or translated provided the source is stated. ISBN print: 92-9131-760-8 ISBN web: 92-9197-760-8 THE JOINT FORUM BASEL COMMITTEE ON BANKING SUPERVISION INTERNATIONAL ORGANIZATION OF SECURITIES COMMISSIONS INTERNATIONAL ASSOCIATION OF INSURANCE SUPERVISORS C/O BANK FOR INTERNATIONAL SETTLEMENTS CH-4002 BASEL, SWITZERLAND Credit Risk Transfer Developments from 2005 to 2007 April 2008 Contents Summary ..................................................................................................................................1 About this report .......................................................................................................................2 Part I: CRT market developments since 2005.......................................................................4 1. Selected developments in CRT products and participants................................4 2. Who bears the risk in CRT? ..............................................................................8 Part II: CRT in the current credit market turmoil...................................................................12 3. Weaknesses in CRT markets in 2007 .............................................................12 4. Risk management challenges for banks and securities firms..........................15 Part III: CRT questions from the Financial Stability Forum and supervisors .........................19 5. Where are there information gaps in CRT?.....................................................19 6. What effect could CRT have on workouts? .....................................................20 7. Are there concerns about insider trading?.......................................................21 8. Are there concerns about market infrastructure? ............................................22 Part IV: Supervisors’ concerns and recommendations..........................................................24 9. Issues raised in Survey of Supervisors for Update of 2005 Paper ..................24 10. Recommendations...........................................................................................27 Appendix A: Developments in CRT products.........................................................................31 Appendix B Developments in CRT participants ....................................................................41 Appendix C: Understanding the credit risk of ABS CDOs ......................................................46 Appendix D: Constant proportion debt obligations: A case study of model risk in ratings assignment ........................................................................................................60 Appendix E The recommendations from the 2005 Report ....................................................73 Appendix F List of members of the Working Group on Risk Assessment and Capital ........79 Credit Risk Transfer Credit Risk Transfer Summary Credit risk transfer has grown quickly, often with complex products, and provides concrete benefits to the global financial system. The benefits of credit risk transfer (CRT) are well understood and have not changed since the Joint Forum’s first CRT report in 2005. CRT allows credit risk to be more easily transferred and potentially more widely dispersed across the financial market. CRT has made the market pricing of credit risk more liquid and transparent. But CRT also poses new risks. A failure to understand and manage some of these risks contributed to the market turmoil of 2007. Like the Joint Forum’s 2005 report, this report focuses on the newest forms of credit risk transfer, those associated with credit derivatives. These new forms of CRT were the impetus for the 2005 report, and their continued evolution and growth motivated this update. Several developments in CRT markets are important for understanding the evolving risks of CRT and the role of CRT in the market turmoil of 2007. Since 2005, CRT activity has become significant in two new underlying asset classes: asset-backed securities (ABS) and leveraged loans. Investor demand for tranched CRT products, such as collateralised debt obligations referencing ABS (ABS CDOs) and collateralised loan obligations (CLOs), was high. This demand encouraged significant origination and issuance of products in these underlying asset classes. ABS CDOs focused their portfolios on US subprime residential mortgage-backed securities (RMBS), while CLOs focused their portfolios on leveraged loans sourced from corporate mergers and acquisitions and leveraged buyouts. Across all CRT asset classes, the growth of indexes since 2005 is an important development. Indexes now represent more than half of all credit derivatives outstanding, up from virtually nothing in 2004. Indexes are widely used to trade investment-grade corporate credit risk across the major markets (North America, Europe and Asia). Indexes also have been created in the ABS and leveraged loan markets, the ABX and LCDX, respectively. In each of these markets, indexes provide a relatively liquid and transparent source of pricing, though the corporate indexes are much more liquid than the indexes in other market segments. Market participants have come to view the credit derivative indexes as a key source of pricing information on these markets. The liquidity and price transparency that indexes provide has enabled credit risk to become a traded asset class. The 2005 report noted the growing complexity of CRT products, and this trend has continued. The 2005 report discussed in some detail the complex risks of CDOs, with a particular focus on investment-grade corporate CDOs. This report focuses to a significant degree on ABS CDOs, which are an order of magnitude more complex than investment- grade corporate CDOs, since their collateral pool consists of a portfolio of ABS. Each of these ABS is itself a tranche of a securitisation whose underlying collateral is a pool of hundreds or thousands of individual credit assets. Referring to this complexity, one market participant described ABS CDOs as “model risk squared.” At the same time that CRT products have become more complex, the investors in CRT have grown more diverse and global. More market participants have become comfortable investing in CRT, which is an important factor explaining its growth. On balance, CRT activity has transferred credit risk out of the United States into global markets. In addition, since 2005, hedge funds have become an important force in CRT markets. Credit Risk Transfer 1 The combination of complex products and new investors has presented a business opportunity for credit rating agencies. For a number of years, rating agencies have rated CRT products, using the same letter ratings (AAA, AA and so on) originally developed for rating corporate bonds. Riding the wave of growth of CRT, in recent years structured finance securities have contributed a growing share of the earnings of rating agencies. All these factors together set the stage for the market turmoil of 2007. Market discipline had been weak as investors in ABS CDOs failed to adequately look through complex CRT structures to the underlying risks of the subprime mortgage market that they were taking on. In some cases, investors were too willing to rely solely on credit ratings as a risk assessment tool. Originators saw little incentive, financial or reputational, to monitor the quality of subprime mortgages that could be sold so easily into the securitisation market. When the subprime mortgage market came under stress due to weakening house prices, investors in ABS CDOs became aware that they were also at risk. One of the reputed benefits of the CRT market is its ability to spread credit risk to a wide range of market participants who are willing and able to bear it. For the riskier, more junior tranches of ABS CDOs, this appears to have happened. Many of these investors have taken losses without material knock-on effects to wider markets. But the same cannot be said of the investors in senior tranches. Three main categories of market participants bore the bulk of the senior tranche risk over 2005–07: (1) conduits that funded their CRT investments by issuing short-term commercial paper, (2) monoline financial guarantors, and (3) CDO underwriters that retained the super-senior risk after selling the riskier tranches. All three have come under stress, transmitting the initial subprime shock to the broader financial markets. The market turmoil spread because of risk management failures at several large banks and securities firms. Some firms took assets on their balance sheets or extended credit to off- balance-sheet entities, even though they had no contractual obligation to do so. In some cases firms did this for reputational reasons. Few firms had anticipated this strain on their balance sheet liquidity. Underwriters of ABS CDOs who had retained super-senior risk wound up taking material mark-to-market losses as the subprime crisis deepened. The complexity of some CRT positions, such as ABS CDO tranches, led to difficulties in valuation when market liquidity dried