Daniel Goggin, Head of International Banking & Finance Clients from Blacktower Financial Management Group
MiFID was undoubtedly brought into being for all the right reasons. There were too many casualties of the 2008 financial crisis and the European Union (EU) understandably decided it needed to act in order to better regulate financial markets. Importantly, this included a desire to provide greater protection to investors. MiFID II was a natural progression of the initial directive and came into force last year (03 January 2018); it covers nearly all assets and professions within the EU financial services sector.
However, there is increasing realisation that imperfections in the instrument – which is comprised of 7,000 pages and nearly 1.5m paragraphs of rules – may have given rise to a number of unintended side effects. Some of the most disquieting of these concern the way in which the many demands for enhanced costs transparency, record-keeping, product governance and regulatory requirements have had a debilitating impact on smaller and mid-cap brokerages, many of whom have found that they are ‘drowning’ under the added burden.
But there is a light on the horizon: the rise of the networks or so-called ‘whale‘ firms who take on the burden of compliance and regulatory adherence has thrown a lifeline to the smaller brokers.
The difficulties were foreseeable
We should not be surprised at the fallout from MiFID II. Many firms were already struggling to survive in the face of the previous regulatory regime as well as coping with escalating professional indemnity costs. Further, when the FCA recently increased the Financial Ombudsman Scheme’s compensation limit from £150,000 to £350,000, some firms saw their PI excess go up by as much as 1000%. And, as is so often the case with target-driven regulations, the workers at the coal face are hamstrung; analysts are now likely to spend as much time proving that they have met certain targets – for example, regarding the frequency of interactions with clients – as they are to be carrying out actual research.
Rather predictably, it is larger firms that have best been able to prosper in this formidable and unforgiving environment. Not only do they have greater resilience to cope with onerous regulatory demands, they also have the resources to grapple with compliance and perhaps even circumvent some aspects. Smaller firms risk being pushed to the margins while larger firms consolidate, threatening a potential monopoly of the financial advice market.
Larger firms, know full well that they are too big to collapse. Couple this with their ability to develop ‘box-ticking’ systems that allow them to be technically, if not spiritually, compliant with MiFID II, and it is clear that however well-intentioned the directive might be, it has created extremely choppy waters for the smaller advisory and family offices. Such firms do not have the resources, power or sheer size to swim freely. Instead, they must take pains to ensure that every commercial and investment decision they make is thoroughly researched and justified – particularly when larger and consolidated firms have recently become engaged in a merciless series of price wars.
Against this background, smaller firms have found that unless clients are of high net worth, they are simply not valuable enough to warrant the amount of time, energy and expertise necessary to properly advance their interests and, anecdotally at least, there seems to have been an exodus of more senior analysts from smaller brokers. As compliance demands take their toll, bonuses and commissions are shrinking, leaving many smaller firms staffed only by junior analysts.
Could this be the beginning of an inexorable tide that takes financial advice firms towards consolidation and eventual monopolisation? Recent illustrations of this trend include Rothschild buying a stake in equity research house Redburn; the 2018 merger between finnCap and Cavendish; and Shore Capital’s recent acquisition of Stockdale.
Improving service but compounding the advice gap
It’s worth reiterating the point made above that an unintended consequence of MiFID II has been the way it has served to widen the proverbial advice gap that first became apparent following 2013’s RDR (Retail Distribution Review). With the initial cost of production of financial advice increasing, as well as the ongoing charging, risk and transparency demands, clients with less than £50,000 represent poor value to advisers.
Simon Harrington, senior policy adviser at the Personal Investment Management & Financial Advice Association (Pimfa), recently told the Financial Conduct Authority that RDR has served only to increase client costs and widen the advice gap. He said the FCA “needed to recognise the unintended consequences of the regulatory obligations that it places on firms.” *
However, we must be careful not to throw the baby out with the bathwater: it is clear that together RDR and MiFID have served to increase the quality of financial advice; it is just that such advice is probably available to fewer clients, with advisers now somewhat forced to service only more affluent clients who can help them meet their essential running costs.
Could the ‘whales‘ help keep the smaller fish buoyant?
The important question now has to be; ‘How do we enable smaller firms not only to survive but to prosper while also offering clients a valuable and adequately regulated service?’
It seems that the answer may be a new paradigm in which larger financial ‘whale’ networks effectively carry smaller and mid-cap brokerages on their backs to prevent them from ‘drowning’ in the face of the heightened regulatory demands and transparency requirements.
By making smaller firms part of established analyst coverage and corporate access networks, whales can help them negotiate the numerous and unforgiving currents and tidal swells created by both MiFID II and RDR.
By providing outsourced compliance support amongst other important resources, a network immediately presents a solution. Other advantages of network affiliation are numerous and can include access to global products and banking services, greater licensing options, use of back office systems and highly developed CRM suites, alongside the ability to offer established DFM portfolios.
For example, Nexus Global, the only IFA network to have gained Network Membership status with The Federation of European Independent Financial Advisers (FEIFA), offers its members a full network menu including free FEIFA membership for one year. IFAs can continue operating under their own branding and style while being covered by an overarching network of support.
In practice, partnership with such whale firms means that all of compliance, payroll, report/advice checking, marketing and more can be brought under a single umbrella, giving advisers more time to interact meaningfully with their clients and, crucially, to focus on what they do best: advancing their investors’ interests.
But there are risks …
While all that sounds brilliant, the danger with the new paradigm is a familiar one: the whales may simply become too big to fail. If a firm knows its collapse can precipitate a financial crisis it may be emboldened to act recklessly and to effectively intimidate the regulator. It may even move, or at least threaten to move, jurisdiction if it does not get what it wants. Furthermore, the richer a firm becomes, the more power it has and the greater its potential legal clout. And not only can it recruit the best lawyers, it can poach inside talent from the regulators, remaining one step ahead of them in the process.
A view to the future
Greater transparency in the financial services industry is undoubtedly a positive and noble intention – for example, recent research from Thomson Reuters has already indicated that MiFID II has served to halve the practice of dark pool trading in the EU.** Yet, as MiFID II is not yet two-years-old it is still too early to say just how beneficial or complicated its long-term impact may prove to be.
Of course, Brexit adds a further layer of uncertainty. There are even suggestions that post-Brexit, the UK may water-down or abolish MiFID II altogether, but bearing in mind that the FCA was instrumental in the development of the directive, it is hard to envisage any situation in which this could happen in the near-term.
Still, given some of the unintended consequences of MiFID II it is not unreasonable to suppose that MiFID III might be around the corner. Whatever the case, advisers, like clients, must remain on their toes; those who don’t are unlikely to survive.
Analysis: Carmakers wake up to new pecking order as chip crunch intensifies
By Douglas Busvine and Christoph Steitz
BERLIN (Reuters) – The semiconductor crunch that has battered the auto sector leaves carmakers with a stark choice: pay up, stock up or risk getting stuck on the sidelines as chipmakers focus on more lucrative business elsewhere.
Car manufacturers including Volkswagen, Ford and General Motors have cut output as the chip market was swept clean by makers of consumer electronics such as smartphones – the chip industry’s preferred customers because they buy more advanced, higher-margin chips.
The semiconductor shortage – over $800 worth of silicon is packed into a modern electric vehicle – has exposed the disconnect between an auto industry spoilt by decades of just-in-time deliveries and an electronics industry supply chain it can no longer bend to its will.
“The car sector has been used to the fact that the whole supply chain is centred around cars,” said McKinsey partner Ondrej Burkacky. “What has been overlooked is that semiconductor makers actually do have an alternative.”
Automakers are responding to the shortage by lobbying governments to subsidize the construction of more chip-making capacity.
In Germany, Volkswagen has pointed the finger at suppliers, saying it gave them timely warning last April – when much global car production was idled due to the coronavirus pandemic – that it expected demand to recover strongly in the second half of the year.
That complaint by the world’s No.2 volume carmaker cuts little ice with chipmakers, who say the auto industry is both quick to cancel orders in a slump and to demand investment in new production in a recovery.
“Last year we had to furlough staff and bear the cost of carrying idle capacity,” said a source at one European semiconductor maker, who spoke on condition of anonymity.
“If the carmakers are asking us to invest in new capacity, can they please tell us who will pay for that idle capacity in the next downturn?”
The auto industry spends around $40 billion a year on chips – about a tenth of the global market. By comparison, Apple spends more on chips just to make its iPhones, Mirabaud tech analyst Neil Campling reckons.
Moreover, the chips used in cars tend to be basic products such as micro controllers made under contract at older foundries – hardly the leading-edge production technology in which chipmakers would be willing to invest.
“The suppliers are saying: ‘If we continue to produce this stuff there is nowhere else for it to go. Sony isn’t going to use it for a Playstation 5 or Apple for its next iPhone’,” said Asif Anwar at Strategy Analytics.
Chipmakers were surprised by the panicked reaction of the German car industry, which persuaded Economy Minister Peter Altmaier to write a letter in January to his counterpart in Taiwan to ask its semiconductor makers to supply more chips.
No extra supplies were forthcoming, with one German industry source joking that the Americans stood a better chance of getting more chips from Taiwan because they could at least park an aircraft carrier off the coast – referring to the ability of the United States to project power in Asia.
Closer to home, a source at another European chipmaker expressed disbelief at the poor understanding at one carmaker of how it operates.
“We got a call from one auto maker that was desperate for supply. They said: Why don’t you run a night shift to increase production?” this person said.
“What they didn’t understand is that we have been running a night shift since the beginning.”
NO QUICK FIX
While Infineon, the leading supplier of chips to the global auto industry, and Robert Bosch, the top ‘Tier 1’ parts supplier, both plan to commission new chip plants this year, there is little chance of supply shortages easing soon.
Specialist chipmakers like Infineon outsource some production of automotive chips to contract manufacturers led by Taiwan Semiconductor Manufacturing Co Ltd (TSMC), but the Asian foundries are currently prioritising high-end electronics makers as they come up against capacity constraints.
Over the longer term, the relationship between chip makers and the car industry will become closer as electric vehicles are more widely adopted and features such as assisted and autonomous driving develop, requiring more advanced chips.
But, in the short term, there is no quick fix for the lack of chip supply: IHS Markit estimates that the time it takes to deliver a microcontroller has doubled to 26 weeks and shortages will only bottom out in March.
That puts the production of 1 million light vehicles at risk in the first quarter, says IHS Markit. European chip industry executives and analysts agree that supply will not catch up with demand until later in the year.
Chip shortages are having a “snowball effect” as auto makers idle some capacity to prioritize building profitable models, said Anwar at Strategy Analytics, who forecasts a drop in car production in Europe and North America of 5%-10% in 2021.
The head of Franco-Italian chipmaker STMicroelectronics, Jean-Marc Chery, forecasts capacity constraints will affect carmakers until mid-year.
“Up to the end of the second quarter, the industry will have to manage at the lean inventory level,” Chery told a recent Goldman Sachs conference.
(Douglas Busvine from Berlin and Christoph Steitz from Frankfurt; Additional reporting by Mathieu Rosemain and Gilles Gillaume in Paris; Editing by Susan Fenton)
Aussie and sterling hit multi-year highs on recovery bets
By Tommy Wilkes
LONDON (Reuters) – The Australian dollar rose to near a three-year high and the British pound scaled $1.40 for the first time since 2018 on optimism about economic rebounds in the two countries and after the U.S. dollar was knocked by disappointing jobs data.
The U.S. currency had been rising in recent days as a jump in Treasury yields on the back of the so-called reflation trade drew investors. But an unexpected increase in U.S. weekly jobless claims soured the economic outlook and sent the dollar lower overnight.
On Friday it traded down 0.3% against a basket of currencies, with the dollar index at 90.309.
The Aussie rose 0.8% to $0.784, its highest since March 2018. The currency, which is closely linked to commodity prices and the outlook for global growth, has been helped by a recent rally in commodity prices.
The New Zealand dollar also gained, and was not far off a more than two-year high, while the Canadian dollar rose too.
Sterling rose to $1.4009 on Friday, an almost three-year high amid Britain’s aggressive vaccination programme.
Given the size of Britain’s vital services sector, analysts say the faster it can reopen the economy, the better for the currency. Sterling was also helped by better-than-expected purchasing managers index flash survey data for February.
The U.S. dollar has been weighed down by a string of soft labour data, even as other indicators have shown resilience, and as President Joe Biden’s pandemic relief efforts take shape, including a proposed $1.9 trillion spending package.
Despite the recent rise in U.S. yields, many analysts think they won’t climb too much higher, limiting the benefit for the dollar.
“Our view remains that the Fed will hold the line and remain very cautious about tapering asset purchases. We think it will keep communicating that tightening is very far off, which should dampen pro-dollar sentiment,” said UBS Global Wealth Management strategist Gaétan Peroux and analyst Tilmann Kolb.
ING analysts said “the rise in rates will be self-regulating, meaning the dollar need not correct too much higher”.
They see the greenback index trading down to the 90.10 to 91.05 range.
The euro rose 0.4% to $1.2134. The single currency showed little reaction to purchasing manager index data, which showed a slowdown in business activity in February. However, factories had their busiest month in three years, buoying sentiment.
The dollar bought 105.39 yen, down 0.3% and a continued retreat from the five-month high of 106.225 reached Wednesday.
(Editing by Hugh Lawson and Pravin Char)
Will COVID Finally Give Big Banks Their Direction?
By Shreya Jain
If the recently finished 2020 has taught us anything, it is that we’d do well to re-evaluate the way things usually work. And in a world, that is still struggling to its feet after a tumultuous year, one can look around and notice that some pieces of reality have played musical chairs: social activities once regarded as keystones of public life are now greeted with deep suspicion, even fear; previously stable industries are on life support; and minimum wage employees suddenly bear the mantle of “essential workers” despite few immediate benefits of this increased responsibility.
Life, in other words, is not behaving as usual. And neither are the banks.
According to FDIC data, a record $2 trillion has been deposited in U.S. banks since the coronavirus first struck the U.S. in January. More than 5.2 million loans were issued by banks participating in the Paycheck Protection Program (PPP) to keep several businesses afloat during the COVID-19 induced pandemic. This is the primary role of banks – to accept deposits and to grant loans.
In a direct juxtaposition to this primary role, if we look at the sources of revenue for banks to determine its role, especially during crisis, it however tells a story of banking institutions deviating from their primary role.
Consider the revenue distribution for a few top banks (Fig. 1):
Fig. 1: Composition of total revenue in 2019 H1 and 2020 H1
For all three of these banks, an increasing percentage of total revenues has been coming from the Investment Banking division, primarily driven by the Fixed Income Market.
In fact, in the most recent Dodd-Frank Stress Tests (DFAST), Goldman Sachs and Morgan Stanley are ordered to hold the most capital of all the 34 firms tested- 13.6% and 13.2% respectively. Goldman Sachs and Morgan Stanley have particularly high stress buffers because of the nature of the Fed’s exams, which put extra pressure on banks that rely heavily on capital markets; Goldman Sachs also has their decision to maintain dividends.
There is an intriguing question in all this – one made easier by recent developments.
“Should Banks be in a Growth Business?”
There are a number of sources to draw from for a possible answer. We have a number of lessons from the past. The Glass-Steagall Act is a 1933 law that separated investment banking from retail banking. By separating the two, retail banks were prohibited from using depositors’ funds for risky investments. Only 10% of their income could come from selling securities. They could underwrite government bonds. 
However, the banking industry soon objected that the act was too restrictive. They believed they could not compete with foreign financial firms offering higher returns as the U.S. banks could only invest in low-risk securities. They wanted to increase returns while lowering overall risk for their customers by diversifying their business.
The most audacious move was when Citicorp and Travelers Group — a commercial bank and financial services company, respectively – merged to create Citigroup Inc. It was an unforeseen event that took the financial world aback for a number of reasons – not least of which was that such a move was technically illegal. But Glass-Steagall had a number of exploitable loopholes. This was just one possible outcome.
On November 12, 1999, President Clinton signed the Financial Services Modernization Act that repealed Glass-Steagall. This consolidated investment and retail banks through financial holding companies. , creating new entities supervised by the Federal Reserve. For that reason, only a few banks took advantage of the Glass-Steagall repeal. Most Wall Street banks did not want the additional supervision and capital requirements.
Those that did take advantage became “too big to fail”.
The Bigger They Are…
The focus today on “Growth” above and beyond what would otherwise be allowed under Glass Stegall Act has been worrisome. The thirty-four participants in the severely adverse scenario of this year’s Dodd-Frank Stress Tests (DFAST) estimated their risk-based Common Equity Tier 1 (CET1) capital ratio would trough to 9.9%, from an end-2019 amount of 12%. In the worst-case scenario –assuming a W-shaped recession where the US is hammered by a second wave of the illness– banks’ aggregate CET1 ratios are projected to plummet to 7.7% after taking $680 billion of loan losses.
While it’s true that banks with trading focus have fared better recently due to an unusual rally in the stock market, there is still some cause for concern. Should that rally turn into a correction or a crash, the FED- and ultimately the American taxpayers – could have to actually bailout these too-big-to fail banks.
A New York Fed paper, using data for more than 200 banks in 45 countries, found that banks classified by rating agencies as “more likely to receive government support” engage in more risk-taking. Moreover, the label of “too big to fail” and passing stress tests may create a false sense of security for large banks, thus encouraging them to continue taking risks with depositors’ money. Said differently, banks engaging in riskier behaviour are also more likely to take advantage of potential government support. Figure 2 shows that Banks with a higher probability of government support (as indicated by support rating floors – NF to AA-AA indicating increasing likelihood of government support) also have more trading assets on average.
Fig 2: Summary Statistics of Bank’s Balance Sheet by Support Rating Floors
The support itself is not seen as bearing great future results either. The paper shows that following an increase in government support, we see a larger volume of bank lending becoming impaired and increase in net charge-offs. Additionally, we find that the effect of government support on impaired loans is stronger for riskier banks than safer ones, as measured by their issuer default ratings.
So, should a Bank be focusing on its growth? Should Banks be limited in what they do? Is the present Stress Test sufficient? Or does passing the stress test only contribute to an inflated confidence and outsized risk tolerance given the potential consequences?
…The Harder They Fall
A number of open questions that the banking industry still has to figure out….
Let us turn once again to lessons from the past, 2008 The Financial Crisis.
The financial crisis of 2008 had its foundation in bad mortgages, but this wasn’t what ultimately brought the banks to the brink of collapse. Volcker noted when he proposed his idea (Volcker rule, a federal regulation that prohibits banks from conducting certain investment activities with their own accounts and limits their dealings with hedge funds and private equity funds, also called covered funds.) that the culprit wasn’t bad loans, but the exotic trades banks had made around them.
At the time, there was discussion of reinstating The Glass-Steagall Act but the banks argued that doing so would make them too small to compete on a global scale. The Dodd-Frank Wall Street Reform Act was passed instead. This Act requires the Fed to conduct an annual stress test of bank holding companies with $50 billion in assets – otherwise known as “too big to fail.”
Section 619 of the Act was The Volcker Rule aimed, once again, at separating the commercial and investment banking divisions of banks, but not with the same stringent restrictions as Glass-Steagall Act. It aimed to prohibit banks from using customer deposits for their own profit. Moreover, restricted banks from owning, investing in, or sponsoring hedge funds, private equity funds, or other trading operations for their own use. These steps were meant to protect depositors from the types of speculative investments that led to the 2008 financial crisis.
The idea became law in the Dodd-Frank reforms of 2010, but the rule-writing took another three years due to squabbles over how to separate prop trading from market-making and hedging. Instead of blanket bans, regulators sought to define each situation and carve out a string of exemptions, which is how the rule grew. The final rule also clarifies that certain activities are not prohibited, including acting as agent, broker, or custodian. As a result, the Volcker Rule has been in force since July 21, 2015
When the final version called on traders to certify the intent of each transaction, Jamie Dimon, the chief executive officer of JPMorgan Chase, complained that traders would need a psychologist and a lawyer by their side to make sure they were in compliance. Fed researchers found that the rule resulted in less-liquid markets for some bonds in times of stress. But by and large, banks adapted to it, though that did not stop them from lobbying for years to win procedural changes. Under the Trump administration, regulators showed a strong interest in simplifying the rule. The revamp, known as Volcker 2.0, is a steady effort to soften Volcker regulations during Trump’s administration.
Volcker2.0 – “Volcker 2.0” went into effect on October 1, 2020.
The Proposed Rule adds four new exclusions to the definition of “covered fund” — credit funds, venture capital funds, family wealth management vehicles and customer facilitation vehicles — thereby exempting them from the scope of the Volcker Rule.
Changes in proprietary trading include eliminating a requirement that banks reserve an initial margin over 15% of Tier 1 capital and may allow banks to invest in up to $40B more in credit-default swaps.
More capital will be available to venture capitalists, therefore making additional capital available to start-up companies. However, many believe this may be a short-lived change following the 2020 presidential election.
Volcker 2.0 is representative of a pendulum swing in financial regulatory compliance away from the strong reaction to the financial crisis of 2008.
Banks evaluated their capital market businesses to identify opportunities to leverage newly permitted activities and the reduced operational burden of Volcker 2.0. Different banks have commenced new strategies by increasing trading volumes and holdings. As an example, the table below (Figure 4) illustrates a trend in the commercial bank sector, and how the trading assets volume increased in 2019 in anticipation of the Volcker amendments.
Fig.4 : Total Trading Assets for Commercial Banks in the US
Is COVID-19 the new lesson? Is FED, via Stress Test trying to tighten regulatory burdens for Banks majorly associated with proprietary trading driven revenues such as Goldman Sachs and Morgan Stanley? As per FED Stress Test in 2020, Goldman Sachs and Morgan Stanley were the two banks that faced the highest jump in the required minimum CET1 ratio – 4.1% and 3.2% respectively. (Fig 5)
Fig.5: Minimum CET1 ratio in 2019 and 2020
On one hand, financial regulators eased the financial crisis-era Volcker Rule. Conversely, the same regulators brought about tighter requirements via Stress Test for banks that are focussed on Trading revenues.
The change in minimum CET1 ratio is inversely related to the PEG ratio (Q3 2020) right after when the minimum CET1 were to be met. Morgan Stanley and Goldman Sachs had PEG ratios of 0.97 and 1.44, the lowest amongst their peers, while they had the largest change in minimum CET1 ratio – 4.1% and 3.4% respectively.(Fig 6.)
Fig.6: PEG Ratio post change in required minimum CET1 ratio
With another administrative change (new government) will the Volcker Rule be changed again to go closer to what it was intended for. Will banks be forced to choose between proprietary trading and having a PEG ratio comparable to its peers?
Do Banks Get a New Normal Too?
Oz Shy, a professor at MIT proposes that if we were to ensure policymakers let banks fail – we need to prepare in advance for the next wave of bank failures by protecting depositors’ money, instead of just focusing on stress tests or size reductions.
Depositors should be simply allowed to have access to accounts that maintain 100 percent reserves. That is, every cent of their savings would be backed by hard currency. His research has shown that moving in this direction improves social welfare relative to the current system of purely fractional banking, in which banks only hold a fraction of their deposits. A 100 percent reserves policy would break our current system’s bundling of risk-taking with the job of keeping accounts safe and offering payment services. Only then, by ensuring depositors (and voters) aren’t at risk when there’s a crisis, would governments have the will to let banks fail – without any regard to their size – and at no cost to taxpayers.
And if a few banks want to be in growth business, they should be treated very differently than the other banks with a pure focus on transmission and custodian roles. More than what current stress test does. Maybe that’s the “new normal” banks need.
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