John Paulson’s Interview With The Financial Crisis Inquiry Commission

John Paulson’s Interview With The Financial Crisis Inquiry Commission
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John Paulson, of the eponymous uber-hedge fund did an hour-long interview with the Financial Crisis Inquiry Commission.  I listened to it (thanks to NYT Dealbook, although not sure where they got it from), and really, I got a kick out of it even though I think my carpal-tunnel is really flaring up now.  Anyway, without further ado, here’s what the man behind the Greatest Trade Ever has to say about the Financial Crisis…
Description: asked what he saw, when, and why he decided to get short, he said “First thing we noticed was that real estate market appeared very frothy, values rose very rapidly, which led me to believe real estate markets were over valued.”  That’s pretty simple/straightforward, no?  I think it’s pretty interesting that he said the 3 homes he’s bought were all out of foreclosure, and they’d increased in value 4-5x over a 2-3 year period through ~’2005.  Apparently the impetus for the research that led to The Trade was literally staring him in the face every time he got home from work!
He explained his approach, and the way he put it makes me really think the guys who didn’t leave their trading desks & “never saw the bubble/crash coming” really had their heads buried in the sand deeper than I previously thought.  As Paulson said, “Credit markets were very frothy, very little attention paid to risk, spreads were very low, we thought when those securities correct, it could present opportunities on short side.”
Their research approach was pretty straight-forward: Focus on subprime, where they were amazed at how low quality the underwriting was, and how low the credit characteristics were on the loans.  They found the average FICO  was around 630, and over half of the loans were for cash-out refi’s, which were based on appraised, not sales prices (so “value” could be manipulated).  For many of these loans, LTV was very, very high, 80, 90, 100% with many of them concentrated in California (no surprise there).  Close to have of the mortgages they looked at were of the stated-income, no-doc variety.
Those who did report incomes had D/I ratios of > 40% before taxes and insurance.  80% of them were ARMs, so-called 2/28’s with teaser rates around 6-7% for those first 2 years, but after they reset, the rates were L+ 600bps which at the point would have doubled the interest rate on these loans, and Paulson & Co thought there was very little – if any – chance borrowers would be able to afford the higher payments.
Once the rates reset, the only thing these borrowers could do would be to sell, refinance, or default.  These were people spending > 40% of their gross income on their mortgages already, once the rate jumped up after the teaser period, they expected that many borrowers would simply default, and the price of the RMBS into which these loans were securitized would fall drastically, while the price of the protection (CDS, etc) Paulson bought on them would skyrocket.
Paulson & co also went much further in their analysis, well-beyond what many of those on Wall Street were doing.  In May, 2006, they researched growth of 100 MSA‘s and found that there was a correlation between growth and the performance of subprime loans originated within them.  As growth rates slowed, defaults rose.  From 2000-2005, they found that with 0% growth, there’d be losses of around 7% in the mortgage pools.
When they looked at the structure of the RMBS they found the average securitization had 18 separate tranches and that the BBB level only had 5.6% subordination, essentially, once losses surpassed that point, the tranches would become impaired, and if they reached 7% losses (what Paulson thought would happen once home price appreciation only slowed to 0%), the entire tranch would get wiped-out entirely.
By mid-2006, home prices not only had slowed to 0% but were actually decreasing, albeit slowly, only about 1%.  Even still, demand from institutional investors was so great, spreads tightened to 100bps. Why?  Because as Paulson went on to explain, institutional investors were buying up the BBB tranches (the lowest investment grade ones) in hoards.
While he didn’t say it, I will (for the umpteenth time!): This is what happens when institutions effectively outsource credit research to the Ratings Agencies, even though many had/have internal credit analysis groups (ahem IKB ahem).  They buy the highest-yielding security you can find that meets your investment guidelines, which meant that for many, they could only buy securities deemed by the brain trusts at the Ratings Agencies as “Investment Grade.”
Paulson started their credit fund in June, 2006, and as he explained, it wasn’t really as simple as it may seem. Historically – going back to about WWII – the average loss on subprime securities was 60bps, nowhere near what Paulson & Co expected was about to happen.  As he said “according to the mortgage people, there’d never been a default on an investment grade (IG) mortgage security.”  These same people were also of the mindset that they’ll NEVER get to the levels where the BBB tranches are impaired let alone wiped out completely.   These were also the same people who said that not since the Great Depression there hadn’t been a single period where home prices declined nation-wide.  These same people thought, worst case, home price growth would drop to 0% temporarily and then return to growth, just like before.

Why would “the mortgage people” expect anything else?  From their desks on the trading floors in Manhattan, Stamford, London, and everywhere else, things looked just peachy!  Spreads were tightening, demand for product was up, and more importantly, so were bonuses!  As far as they knew, the mammoth mortgage finance machine they’d created, based on their complex models and securities was working perfectly…
Paulson also made a distinction missed by many if not most: Everyone was looking at nominal home price appreciation, but real appreciation numbers were much different.  Going back 25+ years using real growth rates, they found that prices had never appreciated nearly as quickly as they had from 2000-2005, and that this trend was unlikely to continue for much longer, i.e. there would be a correction and then mean reversion.  Their thought was that once this correction came about, because of the poor mortgage quality and questionable assumptions/structures in mortgage securities, losses would be much worse than estimated.
Paulson was intent to make one distinction, one that must have been the cause of at least some frustration (followed by fantastic jubilation), that they did their own analysis, they weren’t really trying to attack “the mortgage people’s” views specifically.  Instead, they were trying to understand the conventional wisdom and understand why they had contrary viewpoints.  As myself and countless others have pointed out over the years since, the mortgage industry (I guess we’ll stick with calling them “the mortgage people?”) brushed Paulson off as “inexperienced, as novices in the mortgage market, they were very, very much in the minority…Even our friends thought we were so wrong they felt sorry for us…”
The mortgage people didn’t see any problems because there’d never been a default, except for one manufactured housing (mobile home) deal in the early 1990’s in California.
“The Ratings agencies – Moody’s – wouldn’t let you buy protection on securities from a particular state, because they ensured that the pools were geographically diversified, so they were essentially national pools, although California loans had the highest concentrations therein the pools correspond to the level of home sales in each state.”
What I found surprising from the interview is that Paulson actually praised the mortgage underwriting/originating practices of the big established banks like Wells Fargo and JP Morgan, which he said generally had the best underwriting standards and controls.  The worst were from the New Centuries and Ameriquests, eclipsed in their lax standards only by the mom & pop type shops who were really just sales businesses who made money on the volume of product they originated and sold to Investment Banks like Lehman and Morgan Stanley that didn’t have their own origination network.
These smaller “rogue” mortgage originators were mostly private entities who weren’t under the same scrutiny of their larger, publically-traded “competition.”  Their sales teams were compensated purely on quantity of loans originated with little-to-no care for quality.  These were the guys who routinely falsified documents, appraisals, incomes, assets and/or encouraged borrowers to do the same.  These were the kind of places that made Countrywide’s standards and controls look almost honorable by comparison.
The FCIC then asked Paulson about the infamous ABACUS debacle.  Paulson’s tone when responding to questions from the FCIC here was so, so, awesome; you could hear it in his voice, like he wanted to just say “are you guys freaking kidding me?  Seriously?!?!  REALLY?!??!” every time they asked him about how CDO’s got made.  He basically said (paraphrasing) “If ACA and IKB or Moody’s didn’t like the ~100 subprime reference securities we helped pick for the deal, they could have…not bought the deal or – get this – replaced them with ones they liked better…I couldn’t have gone short if they hadn’t gone long, they agreed on the reference portfolio, it got rated, boom, done”  It sounded like he just wanted to say something like “Hello morons?!  This is how Finance works, HELLOOO!!!”
The ABACUS conversation ended pretty awkwardly (as you might imagine), and then the FCIC moved onto asking Paulson about his Prime Brokerage relationships and what he thought about the Banks.  Interestingly (to me, at least), Paulson had much of it’s assets with Bear Stearn’s Prime Brokerage primarily because the way Bear was structured , the PB assets were ring-fenced from the rest of Bear’s assets in a separate subsidiary, so even if Bear went down, the PB assets would theoretically be safe.  The rest of Paulson’s assets were with Goldman’s PB.  When Bear’s Cioffi/Tanin-run internal hedge funds failed, Paulson saw that as the proverbial canary in a coal mine; they knew the crap that Bear, Lehman, and everyone else had on their books.  They didn’t pulled all of their cash balances from their prime brokers and set up a contra-account at Bank of New York, where, by the time Lehman went Bankrupt, they were holding most of their assets in Treasuries there.
Next, the FCIC asked him about regulators and banks and what people could (or, better, SHOULD) have done that might have prevented the crisis.  Paulson called out the Fed for not enforcing the mortgage standards that were already in effect.  He mentioned that pre-2000, no-doc loans were only given to people who could put 50% down and only represented about 1% of the mortgage market, but only a few years later, originators were “underwriting” NINJA loans with 100% LTV!
Paulson went on to explain how simple fixes, so-to-speak, just enforcing existing regulations like requiring income/asset verification, that homes were owner-occupied, and a downpayment, as low as 5% would have made a huge difference.  Most of the mortgages that failed didn’t have those characteristics.  Excessive leverage and poor understanding of the credit, problems Paulson also say brought down Bear and lehman.  They were leveraged (total assets: tangible common equity) on average, 35:1.  At that sort of massive leverage, a 3% drop in assets would wipe out every $ of equity!
Even if that ratio was brought down to 12:1 and you increase their capital ratio to 8%, the banks still couldn’t hold some of the riskier, more illiquid assets like Private Equity interests, equity tranches of CDO’s, lower-rated buyout debt from many real estate deals, and other assets that themselves were already highly-leveraged.  Adding further leverage to assets themselves already levered an additional 12:1 is just lunacy.  No financial firm should be able to do that, at max those assets should only be allowed to be levered 2:1 (similar to the max leverage for stocks due to Fed Regulation T).
He went on (this is pretty much verbatim, emphasis mine): “Under those scenarios, I don’t think either bank would default.  AIG FP was absurd and exemplified the derivative market where you can sell protection with zero collateral.  AIG FP Sold $500bn in protection with $5bn collateral, 100:1 collateral.  ACA was collateral agent, they were like 120:1 leveraged.  $50bn protection on $60mm collateral.  You have to hold collateral, we need margin requirements for both buying & selling protection.  It’s not the derivative itself that’s the problem, it was the margin requirements (or lack thereof).  We need something like Reg T (max 2:1 leverage at trade inception).  What these guys did would be like like buying $100 of stocks with $1 of equity, a tiny downward move is a huge loss of equity.  In all, these four things would have likely prevented the crisis:

  1. Mortgage underwriting standards, simple & logical
  2. Higher bank capital ratios
  3. Higher capital against risk assets
  4. Margin requirements against derivatives

Paulson was then asked about the Ratings Agencies and what role they played in the bubble/crisis.  Regular readers know where I stand on them & NRSRO regs, and no surprise, Paulson is similarly critical, particularly of the issuer-pays compensation structure, calling it the perverse incentive that it really is, despite whatever nonsense rhetoric RA executives say.
That, combined with being public (or part of public companies) and they were in this race to keep pace with their competitors, to keep up earnings growth with their derivatives business, which he called a “perverse economic incentive that may have led to their laxness in rating securities”
He went-on to explain this same – in the immortal words of Citi CEO Chuck Prince – “keep dancing while the music’s still playing” – incentive structure led the Banks to take similarly short-sighted actions as they struggled to keep up earnings, growth, and of course, bonuses.  At that point, the only way to do that was to grow their balance sheets, add more leverage to earn spread.  In Paulson’s words “Once things go up like that, you don’t see any downside, so at top of market they just weren’t looking at the downside, just upside, became more and more aggressive until they blew up.”
Paulson said the Fed certaintly could have cracked-down on lax-underwriting standards, eliminated negative-amortization loans, stated-income, 100% LTV, IO’s, etc where most of the problems developed.  On the banks and more broad financial services industry, he said “…people became delusional, ‘we can leverage AAA 100:1…’ if you had margin requirements against derivatives, AIG could have NEVER happenedIf they held higher equity against risky investments, they would have never defaulted. Constructively, that’s what Basel 3 says, 8% equity/capital and higher risk weightings for illiquid risky type assets.  I think adoption of those rules will lead to a safer financial system.”
When asked about the role of Fannie May & Freddie Mac, he pointed out the problem was largely similar to what brought down the banks and AIG: excessive leverage and poor oversight/underwriting. “They deviated from their underwriting standards as a way to gain share in alternate mortgage securities, of poor quality & higher losses.  Second, they were also massively leveraged 80-120:1 if you include on-balance sheet assets & guarantees which is way more than any financial institution should have.”
Yea, I think 120:1 leverage is just a wee bit more than prudent, just a bit though…
From this interview it seems painfully clear that those with whom the safety of the Financial System rested were in a deep coma at the helm, Bank executives, regulators, Congress, institutional money managers, all of them.   It’s clear that the nonsensical argument put-forward by Tom Arnold & Yves Smith that those who were shorting housing, subprime, etc were NOT IN ANY WAY, SHAPE, OR FORM remotely responsible for causing the crisis.  Institutional managers were not gobbling-up BBB-rated RMBS CDO tranches because shops like Paulson & Co were shorting them. Like I said before: they wanted the highest yield they could get away with holding!
As Paulson said, anyone who looked at the data he did should have noticed the impending doom, but apparently, either very, very few people did that type or analysis or they did and just, like Chuck Prince said, kept on dancing until the music stopped.
These traders thought tight spreads indicated safety, which is just wrong in so many ways.  These are the same morons who – thought they should know better – constantly confuse correlation with causation.  Low spreads may have been historically correlated with low default and loss rates, but low spreads do not cause low losses/defaults.  Spreads, like stocks, trade as a function of supply and demand, and all low spreads indicate(d) is that, as Paulson noted, institutional managers were swallowing up as much of these MBS and derivatives (for reasons I explained above), and, like a bunch of lemmings, all thought history would continue despite significant evidence suggesting this time, it was actually different.
One other thing that critics and the public at large probably doesn’t know is that Paulson & Co had a MASSIVE internal, independent research effort wherein they did crazy things like *gasp* look at loan-level data.  Imagine that!  This enabled them to hunt for CDO and other product that contained an inordinate amount of crap for them to short.  This same work also helped them to buy RMBS/CMBS etc when the market turned in 2008 and 2009. They had done the work, and knew what they were willing to pay once it was time to go long.
I’m not saying there’s anything necessarily wrong technical, momentum, and quantitative trading strategies.  There is, however, something very wrong, and very dangerous about relying on these strategies alone while ignoring fundamentals, as evidenced by the housing crisis.  Those who did the hard work like Paulson & Co. made the greatest trade ever, while those who ignored or were otherwise blind to the fundamentals got absolutely crushed.


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