9631_Behavioural Finance – Risk attitudes in the aftermath of the Economic

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Behavioural Finance – Risk attitudes in the aftermath of the Economic
Crisis

Ronan MacDonell
Student Number 1952330

Submitted in partial fulfilment of a Masters in International Banking and Finance,
Liverpool John Moores University. (Course Code: B9AC028)

Dublin Business School

August 2014
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Declaration:

I declare that all the work in this dissertation is entirely my own unless the words have been
placed in inverted commas and referenced with the original source. Furthermore, texts cited are
referenced as such, and placed in the reference section. A full reference section is included
within this thesis.

No part of this work has been previously submitted for assessment, in any form, either at Dublin
Business School or any other institution.

Signed:…………………………

Date:……………………………
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CONTENTS
Page
Acknowledgements…………………………………………………………….
4

Abstract………………………………………………………………………..
6

Chapter 1: Introduction………………………………………………………
7

Chapter 2: Literature review…………………………………………………
11

Chapter 3: Methodology………………………………………………………
32

3.1 Research approach to examination of Risk Market ……………………….
33
3.1.1 Research philosophy and design…………………………………………
34
3.1.2 Research strategy and materials………………………………………….
35
3.2 Ethical issues and procedure……………………………………………….
36
3.3 Population and sample……………………………………………………..
37
3.4 Data collection, editing and coding………………………………………..
38

Chapter 4: Research findings………………………………………………..
40

Chapter 5: Conclusions and Further Research ……………………………
55

Chapter 6: Recommendations and future intentions………………….……
61

Chapter 7: Self-reflection on own learning and performance………..……
66

Chapter 8: References……………………………………………….……….
72

Chapter 9: Appendices………………………………………….……………
78

Appendix 1 (Research Questionnaire)…………………………………………
78

Appendix 2 (Transcripts – Interview A through E)……………………………
80

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Acknowledgements

I would like to gratefully acknowledge a number of people who helped me start and complete
this thesis. The initial seed of my research topic was planted by a DBS Lecturer, Mr Andrew
Quinn, during one of his classes. I would like to thank my supervisor, Mr Justin O’Keefe. Justin
was astute enough to recognise at one point that I was struggling to put a complete structure
around my research. With some guidance from him I was able to gain momentum. I would also
like to thank the MSC International Banking and Finance lecturing staff for the insightful
approach they took to teaching this course. It was of significant benefit when conducting this
research.

I am indebted to a group of industry professionals for allowing me to include them in my
research investigation. I would like to register a sincere note of thanks to those who allowed me
to interview them. I was fortunate to get in front of people who were able to recognise that I was
outside of my comfort zone at times. The encouragement I got from them actively participating
in the interviews was greatly appreciated.

I would like to acknowledge my employer, Abbott Medical Optics, for the value they have
placed in me by sponsoring me to take on this education. Additionally the support I have had
throughout the course has been appreciated.

To the proof readers and grammar police, you know who you are, I am sincerely grateful. I am
fortunate to have a very solid family unit and I was very grateful of the support and genuine
interest shown in my work by my parents.

Last but not least, I would like to thank the four most important people in my life, my wife and
three daughters, for sticking with me throughout. Doing research during the summer holidays is a
major logistical effort!! To my wife, for all the patience and proof reading, thank you.

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Over the course of this research process, especially during the last 8 weeks I have taken solace
from the day dream of a well-earned holiday once the thesis is complete. I am grateful to now be
on the cusp of that rest.

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Abstract

Problem:
The aim is to look at the factors impacting the risk market in the aftermath of the financial crisis.
Inevitably this will focus on changes after the collapse of Lehman Brothers which sent financial
markets into turmoil. The model incorporated for this was focusing on core areas of attitudes to
risk management within institutions, regulatory compliance and finally change management and
culture. The intention was to focus on the resurrection of this market to understand where the
bulk of reform came from. Discovery was initiated to understand if markets were shutting down
or were they adapting to the new horizon.

Methodology:
The research was conducted via a qualitative interview process with a sample size of six. The
sample comprised four separate global institutions and one global multi-national company. The
represented a cross sectional qualitative data collection.

Conclusions and recommendations:
The conclusions that came out of the research were borne out of a consistently distinct response
from the qualitative sample. The data collected demonstrates that institutions have become
significantly overburdened with regulatory reform. As the group are agreed that enhanced
regulation was needed in the aftermath of very loose regulation policy between 2006-2008 the
challenge focused on how stringent governance controls could be maintained while taking some
of the excessive reporting requirements out to allow it to be sustainable into the future. The
concern was that without some unburdening the controls may result in policy loosening of an ad-
hoc nature. This is not in the interest of competition. Recommendations have been drawn that
will require the engagement of all parties to address the post-recession market and ensure an
efficient work place.

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Chapter 1: Introduction

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General Overview:
As a researcher one was interested to understand how the response to the financial crisis of 2008-
2009 was viewed in the market. One was interested to understand if the actions that were taken
in response has a positive or negative impact on the financial services industry. While this thesis
proves that the impact was positive it was not without a significant shift in the compliance effort
that has changed the face of the industry forever. Reform was required, justified and effective. In
2005, Alan Greenspan, while Chairman of the US Federal Reserve suggested that complex
financial transactions had contributed to the development of a more flexible efficient and
resilient financial system. At the time this was viewed as a very reasonable perspective on the
market. What few knew then was how comprehensively false it would be proven to be a few
years later. US Economist Paul Krugman has since gone on to summarise that Regulatory
Reform coupled with new technologies has stimulated the development of financial products
such as Asset Backed Securities that when executed correctly should offer the dispersion of risk.
This commentary confirms the view of this author that Regulatory Reform on a global scale was
both necessary and effective in light of recent systemic failure. Other researchers has been
carried out around the subject of system failure including by Achorya in 2009. It was intended
for this research to approach an alternative area.
Of particular interest was the possibility to assess both the operational risk side of the market
with the regulatory reform initiatives. This has been proven but as it turned out less focus was
needed for the product side. The focus was now very much on the implementation of reform and
how it was interpreted by institutions. In fact what was clear from the qualitative research
conducted in this thesis was that focus should remain on reform and that it should be a
fundamental pillar of the industry going forward. In future, continued oversight and policing via
regulators is essential to ensure that a repeat of the failure of 2008-2009 is not repeated. Wallace
et al (1988) discussed the liquidity problem within banks. This is not a new problem where banks
borrow short and lend long. They are effectively illiquid hence the liquidity problem created
because banks do not match the maturities of assets and liabilities. As far back as 1960 Friedman
commented that banks executing demand deposits should be subject to one hundred percent
reserve requirements. That view seems excessive but it is relevant in the current market as capital
adequacy ratios become an everyday component of banking. The need to ensure capital adequacy
ratios is all jurisdictions of operation is now a requirement under that guidelines of the Basel
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Committee of Banking supervision (BCBS) framework called Basel III. It is ones hope that
within this thesis the dominant notion of regulatory reform being a joint effort is apparent. It is
required that the onus of compliance be placed banks but with required participation from the
Financial Regulator and counterparty partners.

Methodology Overview
When building a questionnaire for this research effort one was driven via the literature review to
weight it heavily with discussion topics around the regulatory response and the implementation
of it. This questionnaire will be attached to this document as an appendix. Significantly, the
introduction of new reforms as well as how the regulator can collect and interpret the data was a
core theme. Another question address the changes in the market today with the emergence of role
of Corporate Treasury who have taken on more significance as they have very stable balance
sheets and high capital reserves. Another focus of the questions asked was around the ability to
police regulatory reform when faced with jurisdictional issues. The author asked if capital
adequacy levels be correctly maintained by an institutions who conducts business on many
markets around the world. The author worked to understand if a central capital reserve was
required of if the capital should be in the jurisdiction of trading. As it turns out, The Dodd-Frank
reform act, which is prominent in this research, addresses the need for capital levels to be
maintained where the risk occurs. A final element of this questionnaire is specifically with regard
to how institutions have reacted to the reform. It is very clear that in the wake of this crisis the
instituions have taken on this new reform in an aggressive manner despite the very significant
cost it has added to the business. However, it is still unclear how big an impact the reform and
capital requirements will have on consumers as they will likely bear the cost of reform
compliance in the long run. Additionally, they will incur the cost of the banks having to maintain
shareholder return with a smaller notional cash pool to execute upon.
The basic types of risk underpin the research. Exchange risk, Interest rate risk, Commodity risk
and Equity risk are the accepted risk types and were researched via the use of secondary data
sources which will be clearly referenced within this literature review. When referencing the
generally accepted risk types the author’s opinion was that certain risk areas would be most
relevant. In particular, Equity risk and Commodity risk. Equity risk is the financial risk of
holding equity in a particular investment such as real estate or stocks. One should focus on
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systematic and non-systematic risk. Being unable to control the internal risks of a stock is a
given however, market risk can be diversified. The suggested action here is to manage this risk
through diversification depending on risk appetite. An investor can diversify a portfolio using
Beta. Mathematically Beta could be defined as “….the covariance between the stock returns and
the market returns and the variance of the returns on the market.” (Brealey,Allen,Myers,
Principles of Corporate Finance (Chapter 34). In theory, Beta is defined as a measure of the
volatility or systematic risk of a security or a portfolio in comparison to the overall market
In this research I will focus on some core elements which make up the areas discussed in this
research which will be based on
 Risk Management
 Regulatory Compliance / Governance
 Change Management / Culture
It is the hope of this author that it is clear to the reader that these fundamental themes that make
up the research problem are proved to be the central points changing the banking framework
today.

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Chapter 2: Literature Review

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The global financial crisis of 2008–2009 brought the world banking system to the brink of
collapse. Extensive and costly national rescues of some very big banks were required to ensure
the continued operation of financial markets. Glitches in global regulation were seen as
contributory to the extent of the crisis (Avgouleas 2009). In the aftermath, the Basel Committee
of Banking supervision (BCBS) embarked on a program of substantially revising its existing
capital and liquidity guidelines. The resultant capital adequacy framework, termed ‘Basel III,’
received G20 endorsement in November 2010 (KPMG, 2011). The guidelines represent the
biggest regulatory change that the banking industry has seen in decades (PWC 2011). While the
national authorities are adopting the core framework, there are strong indications that the high
level of complexity and interdependency within the global regulatory landscape poses a
significant challenge to actual implementation, resulting in a divergence across various
jurisdictions (KPMG). There are other complex financial regulations (with cross-border
implications) such as Dodd-Frank and EMIR that also have to be considered. Sheng, in his
Working Paper of 2013 suggests that the combined effect of all these regulations, complex,
undefined and wide-ranging in coverage, is seen to have held down the banking system.

Behavioural finance is the study of the influence of psychology on the behaviour of financial
practitioners and the subsequent effect on markets (Sewell 2007, revised 2010). Ben Steverman,
in a 2014 Bloomberg report, noted that it is hard today to find a place where concepts of
behavioural finance aren’t being applied to real-world situations. Avgouleas, in 2009, argued
that the some of the measures endorsed in Basel III, such as increased disclosure and a stronger
capital base, and others targeting the enhancement of market discipline would prove less
effective than anticipated because they largely ignore the behavioural elements of the crisis.

This researcher was interested in examining the attitude to risk in financial institutions post the
global economic crisis. It was anticipated that attitude to risk within financial institutions might
have changed over time since the crisis and the introduction of new global regulation. Of
interest was whether these changes were specifically related to the crisis and the aftermath and
the behaviour and attitudes of those responsible for risk within certain institutions.

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Risk products, while evolving, have had the same fundamental characteristics over time. In the
aftermath of the global crisis, the focus seemed not to be on rebuilding these products but rather
on the governance structures of the institutions. A literature review was undertaken in order to
identify the current trends in the risk market. Themes emerging from this review include a
particular emphasis within institutions on attitude to financial risk, governance and change
management. These have been further refined to provide topic strands include risk management
and attitudes, regulatory compliance/governance and change management/culture. The findings
from the literature review are presented here.

In order to prepare for the literature review the author was conscious that doing a qualitative
research piece would require input from sources to understand the meaning they had construed
from topics (Merriam, 2009). This allowed one to understand where the focus of literature to be
reviewed should lie. In this case, all regulatory compliance elements took on most significance.
During the process of the review, the author, to highlight the criteria to be considered by
financial institutions post crisis, developed a visual structure of the interrelation of the many
factors under the risk umbrella. This structure is presented below.

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Risk
Risk Attitudes
Governance /
Regulatory
Compliance
Financial
Institutions
Corporates / MNC’s
Risk Tolerance
Risk Policy
Sovereign
Rating Agencies
EMIR
Dodd Frank
Risk Tolerance
Risk Policy
Brand Damage
Quantitative
Easing
Fiscal policies
Basel iii
Basel iv
Current
Attitudes
Risk Free Rate
High Grade
Corporates

Fig 2.1 Structure Overview (Researcher)

In order to discuss the internal workings of a financial institution regarding risk, it is essential to
understand the pressures on these institutions from not only the regulatory bodies relevant to
their geographical area but public /client perception and therefore business. Brand damage is a
key factor in this debate. According to the Brands Finance annual report 2012, brands are the
most valuable intangible assets in business today. Over recent years the public reputation of
banks has soured immensely. Banks were viewed as sales-driven with focus on profit margin
alone. Capitalism clearly calls for a focus on the net profits of any organisation however
consumers today are looking to partner with banks that have proven adjustment in this regard. In
their recent document, entitled “Remaking Financial Services: Risk management five years after
the financial crisis”, Ernst and Young polled 70 global financial institutions and purport some
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insightful views with regard to brand. Forty three percent of those polled indicated that their
organisation had a strong risk culture. Ernst and Young interpreted this as suggestive of a new
focus on risk. They recognised that changes are at early stages but appreciate the positive
indications. The document also makes reference to the fact that organisational boards are
beginning to comprise more members with specific risk management backgrounds. Additionally,
roles such as Chief Risk Officer are now in a more prominent position and in many cases are
reporting directly to the Chief Executive Officer.

Ernst and Young explain that the top down approach of organisations with boards of directors
supporting developments under the new regulatory requirements and understanding of the need
for change will drive significant positive change in risk policy. Those involved in the financial
market now understand that the naivety demonstrated previously will not be an excuse in times
of future difficulties. They suggest that banks are forced to demonstrate that they are still ‘open
for business’ within the risk market. New and likely improved policies around risk, which are
more diverse than previously, are seen as helpful. Coupled with this top-down thinking, strongly
supportive risk culture is needed in order for individuals to have the ability to execute on the
policy provided with utmost transparency. This concept provides a basis for a line of
questioning related to the effect of change in risk protocols since 2008 on attitude to risk within
an institution as perceived by the interviewees.

Relevant literature is contained around the notion of bank stress tests and more importantly the
methodologies adopted to complete them. The research findings of this topic should provide
some interesting data around changing methodologies. The difficulty is extracting the data from
the system and then analysing it for validity. Analysis of the Ernst and Young paper has given
rise to some focused ideas for questioning during the qualitative research to follow from this
literature review.

The concept of stress testing has taken on additional emphasis post the financial crisis. Stress
tests were given a new role as crisis management tools. The economic criterion around stress
testing differs on a regional basis. In the US the Federal Reserve, via its Board of Governors,
published guidance on stress testing for banking organisations with large consolidated assets
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(http://www.federalreserve.gov/bankinforeg/srletters/sr1207a1.pdf
May
14th,
2012).
The
document refers to five core principles. The first states that a banking organisation’s stress
testing framework should include activities and exercises that are tailored to and sufficiently
capture the banking organisation’s exposures, activities, and risks. It is clear that the overall risk
profile of the institution needs to be evaluated as a whole and not sub-divided into separate risk
groups as previously. At any one time the overall risk profile must be up to date and available for
review by the financial regulator. Additional principles focus on measurement to ensure results
can be ranked and benchmarked against other financial institutions within the US. Of
significance is principle 5, which relates to governance and internal policy. Over the years,
financial issues have often been preceded by a weakness in governance and the absence or
bypass of internal policy (Lumpkin 2009 OECD report). Governance will be covered later in this
review, however, for now it is possible to conclude that top-down governance is required, as
previously discussed and supported by effective internal control policy documents. These
developments within institutions may have resulted in changes to daily business within banks
and it is this aspect that is to be explored during the research interview process.

The Federal Reserve has assigned specific economic criteria to stress testing by financial
institutions in the US. As part of the interview process an understanding is sought regarding the
suitability of banks to maintain internal models of stress testing or should the relevant regulator
undertake testing.

The economic criteria include:
 Unemployment increases above 11.3%
 House prices fall by 25% or more
 The Dow Jones Industrial Average falls by 50% or more.

The equivalent in Europe, of the US Federal Reserve, is the International Monetary Fund (IMF).
Similarly to the Federal Reserve, the IMF has published documentation on stress testing. Recent
commentary in the Financial Times has noted the widely accepted credibility issues within bank
stress testing in the Eurozone; whereas the US process is seen as a model for market reassurance,
the European equivalent has been criticised for being overly easy to pass (Fleming et al. 2014).
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Indeed in 2010, Ireland’s two biggest banks needed a bailout within months of passing testing
processes. The whole concept of stress testing is to examine the worst-case scenario. For banks
this should predominantly include economic indicators as laid out above. Sensitivity analysis is
critical. Taleb in his 2012 Black Swan Report for the IMF notes that stress tests must be
conducted in times of economic recession or downturn in order to capture effectively the tail
events and assist in detecting potential indicators of difficulties.

Stress testing should also help garner an understanding of whether all risk has been managed
effectively on the balance sheet. As mentioned previously, some limitations to European stress
testing models have been noted in comparison with the US. Ahead of US Stress tests, capital was
set aside to complete a full balance sheet cleanup. Unfortunately, in Europe, capital was not
available for a full balance sheet clean up and so testing was less complete. This led some
commentators to suggest that European stress tests were too lenient and were not far ranging
enough to gauge the real position of the bank and its balance sheets. Current testing practices are
not based on a systematic and comprehensive set of principles but ‘have emerged from trial and
error and often reflect constraints in human, technical and data capabilities. (Macrofinancial
Stress Testing – principles and practices, IMF Monetary and Capital Markets Dept, 22 August
2012).

Audit reform is very much a requirement in the post financial crisis world. Among the
consequences of this financial crisis are the creation of the European Financial Stability Fund
(EFSF) and the European Stability Mechanism (ESM). Initially it was the EFSF that was
replaced by the ESM as the funding mechanism for distressed banks in Europe. In November
2010 the EFSF published the Charter for Audit and Control. The mission of the charter backs up
the concept of risk analysis via stress testing. The ‘Mission and Scope’ chapter of this document
provides some core components on which to base aspects of the planned qualitative research.
Firstly, that risks are appropriately identified. (EFSF Charter for Audit and Control, available at
http://www.efsf.europa.eu/attachments/efsf_internal_audit_charter_en.pdf November 2010) Of
key importance is that the actions of employees are in compliance with policy, standards,
procedures and also the law. It will fall to the head of Audit and Control to be responsible for
implementation and execution. This function head will need to ensure that a plan is implemented
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that is compliant and achievable and measurable. An escalation path and associated scale for
non-conformance and fraud must be structured. Of additional relevance is independence. Within
the coming research it will be critical to understand whether the relevant audit body has the
independence to execute completely. In the case of Ireland for example, the Central Bank
Reform Act, 2010, created a new single unitary body – the Central Bank of Ireland – responsible
for both central banking and financial regulation; ultimately, as the Act states, to prevent
potential serious damage to the financial system in the state, support the stability of that system
and to protect users of financial services.

A further move, in the USA, towards the transparency demanded by all regulatory bodies post
crisis, is the requirement for publication of stress testing results and derivatives reporting under
the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010). The Act allows for
changes that affect the oversight and supervision of financial institutions. Under the guidance of
the US Secretary of the Treasury a new agency to strictly enforce participation and compliance
will introduce requirements of more stringent regulatory capital requirements (Morrison and
Forester 2013). Dodd-Frank has seen some regulation success as both banks and corporates now
have a greater responsibility to deliver derivatives reporting. However, this piece of legislation
presents the most ambitious change in the regulation of financial institutions since the Great
Depression, and its implementation will affect not only every financial institution that does
business in the United States, but many non-financial institutions as well (Financial Services
Committee, Washington 2010. Dodd-Frank is a huge piece of legislation, numbering over 2,300
pages in length and requiring federal regulators to embark on more than 400 rule-makings. The
level of complexity in this legislation is clearly complicated for institutions to interpret and
ensure their compliance. Again, this issue gives rise to a line of questioning for interview
purposes, in exploring the impact of this legislation on attitude to risk.

Risk Attitudes (Operational):
Damodaran (2008) engages in a discussion of risk free rates. Historically, an investor
could always be certain of a risk free rate. These rates are generally applied to government debt
that would be viewed as without risk due to the low likelihood of sovereign default. In fact,
pricing within risk markets always uses the risk free rate in its assumptions and calculation. An
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example of this would be the Capital Asset Pricing Mode for pricing an individual security or
portfolio. The market has always used models, which were built on assumptions, including the
availability of the risk free rate. The difference in today’s market is that the risk free rate is less
available due to sovereign credit issues (Jaramillo & Tejada, 2011). In their Working Paper for
the IMF, Jaramillo and Tejada (2011) explore the current trends in risk free rate offerings.
Interest rates are currently at historical lows and with it bond yields are both low and stable. The
USA, UK, Germany and Japan, for example, still maintain the capability to offer a risk free rate.
However, this is less straightforward nowadays when viewed from the perspective of the
Eurozone or other less capitalised sovereign nations that have been badly impacted by the
financial crisis. In the Eurozone the impact stems from strong economies facing off with weaker
economies. Interconnectivity brought about by initiatives such as Fiscal Compact now mean that
it is a very central view (Lane 2012, Trinity publication).

Impacting attitudes to risk and the element of risk culture post the economic crisis is the
possibility of failure in the Eurozone leading to a break-up. Indeed, the school of Oxford
Economics stated ‘the economic and financial strains now being felt in parts of the Eurozone
mean that the possibility that EMU will not survive in its current form can no longer be ruled out
(Oxford Economics 2010). During this time Banks and Corporates were considering contingency
plans if the break up of the Eurozone, as feared, had become a reality. The analysis of Mattern et
al. (2012) for McKinsey of Eurozone economics expresses concern that continuation of
economic events eroding the trust of investors cannot be ruled out, making debt rollover
impossible. If not counteracted by adequate liquidity support, this could lead to the break-up of
the European Monetary Union.

In the event of renewed financial crisis the difficulty would sit firmly with periphery nations.
This is confirmed by Oxford Economics (2010), Mattern et al (2012) and others. Capleton
(2013) sets out an Irish example. An investor buys Irish bonds in the market, deeming the risk
acceptable as the bond is within a European zone and has a functioning currency. However, in
the event of a Eurozone break up the holder of this bond would face a grave issue. In the event
the Euro ceased to exist all participating economies would be stand-alone again and would
require a fall back to type. It is very likely that the currency would de-value and the holder of
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the bond would incur significant loss. However, in the event the bondholder held a German bond
then the likelihood is not on default or devaluation. It does demonstrate a clear disadvantage for
the periphery nations and significant concerns remain in place for periphery default (Oxford
Economics 2010). Again, possible unwillingness on behalf of financial institutions to investing
in certain sovereign bonds will be further explored with the individuals selected for questioning.

A further example presented by Blinder (2010) for Princeton University is based around
Quantitative Easing but this is only a workable solution for economies with full sovereign
control over monetary policy. Economies in this situation have the ability to print money and
capitalise the market. In the Eurozone, however, the flexibility of member nations to quickly add
capital is considerably less due to the fact that the EU does not have full control of the monetary
system. The Long Term Reset Options (LTRO) was the compromise to this with the goal of
capital injection in to the European market to promote economic growth.

Bate et al. (2014), in their analysis of FX derivatives markets post crash, posed the question
whether high-grade corporates (Pfizer, Apple, IBM, Microsoft) were really a better risk option
than sovereigns bonds? A key element of the financial crisis with regard to risk is the very
considerable shift away from Sovereign debt onto corporate debt. In their discussion, they
excluded the US, UK, and Japan as having the ability to offer the risk free rate as they also had
control of their monetary system. However, when other countries were considered, they
wondered at the possibility that Corporates such as Apple, Microsoft or Pfizer, to name a few,
could be a more realistic risk target. It would take a considerable shift for cash managers to
revert to Corporate Commercial Paper for a liquidity return in the range of a standard hard
currency risk free rate. In Europe, the crisis demonstrated that Sovereigns at risk of default and
running significant deficits would see bond yields climb considerably but the control system has
limited scope for rescue. The contagion in this case is heightened. Within the Eurozone,
Quantitative Easing is not possible such as it is in the US or the UK. From a corporate
perspective a fundamental shift occurred in the aftermath of the financial crisis. This shift was
the adjusted risk attitudes of those large corporates globally. Traditionally, Corporates would
generally operate a risk-averse policy. However this was offset somewhat by the availability of
banks earning AAA and AA ratings based on the rating agency models of Standard and Poors,
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Fitch and Moody’s and the demand from Corporates for enhanced yield risk products. Enhanced
yield products would have been a riskier blend of equities than previously demanded. These
ratings did provide a significant overlap between the risk products being offered by banks and
the risk policy being adopted by Corporates. In the opinion of this author it is clear that the
Rating Agencies failed in the same way banks and regulators failed. It must be born in mind that
rating agencies are not wholly independent. A rating agency will not provide said rating for free
however, an institution is only likely to pay for a rating if it is investment grade and higher. The
domino effect after 2008 following the downgrade of a lot of sovereign debt as well as bank debt
was a renewed shift to capital protection. Corporates could not put a padlock on cash reserves
quickly enough and yield became of little consequence. Even today, six years on, focus is still
very much concerned with ensuring no loss on capital. Gains in the form of yield based on risk
appetite remain of little significance. In the historically low interest rate environment Corporates
continue to use vanilla products such as Time Deposits. The proposed qualitative research will
seek to expose the level of fear in the current economic climate within corporates and the
banking sector towards sovereign bonds.

As set out in the previous section, in the market post 2009 we have seen investors who are
concerned with sovereign debt risk moved towards the bonds of high-grade corporates such as
Microsoft and Pfizer. The bank lending market retracted considerably at the time of the financial
crisis and was very slow to recommence. This was a significant limitation to the recovery cycle
of the enduring financial crisis and is seen as a result of increased regulatory reform in the
market. This reform was very much necessary and is discussed in depth as part of this literature
review.

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Figure 2.2 – Bond Yield Curve
Source: Financial Times, 20 June 2014

As sourced in the Financial Times bonds yields are offering historically low yields in this
sustained period of low interest rates. Figure 2.2 indicates a flat line of zero percent out as far as
two years on the curve with rates going no higher than two percent for maturities out as far as 30
years. As such, Investors are now looking for a short to medium term enhanced yield on cash
piles. As such, high-grade corporate bonds have turned into an attractive alternative for investors.
What makes this interesting is the volumes are significantly different when viewed regionally by
economy. Bowman et al (2012) review how the introduction of new risk products such as a range
deposit which pays an enhanced yield return provided the foreign exchange pair is trading within
a certain range at maturity. The yield can be increased by taking a narrower range in the FX
price. This increases the risk of the product which can be priced by market norms. The trend
between core euro-area economies is significantly different to periphery euro area economies.
The opinion of this author would agree with other commentators Van Trigt et al (2014) that this
change in risk attitude could in itself pose significant future concerns. Van Trigt and his research
team reference how periphery nations such as Ireland, Portugal and Spain are back in vogue.
This is very much a demand-driven investor alternative, which would suffer a significant shock
should demand fall sharply. In essence, they say, a continuation of this will require continued
growth and fiscal discipline as well as increase in inflationary levels. In the event of continued
or renewed recession and a sharp increase in bond yields the high grade corporations would find
it difficult to access funding. The risk of default would be heightened significantly. It would
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suggest that a short to medium term tenor market may remain buoyant but as a longer term
option the merit would be reduced due to increased volatility.

Regulatory Reform

Having reviewed the concepts of regulatory reform, two aspects of regulatory reform have
emerged as fundamental:
 Aspect 1: Reform to reduce the probability of an institution failing due to a lack of capital
in the form of reserves, liquidity, governance and risk management.
 Aspect 2: Reducing the impact of failure
Pre September 2008 the potential options seemed to revolve around a bail out /rescue package or
failure. Post financial crisis a third option of dividing the balance sheet into a good/bad bank and
splitting out the loan portfolio accordingly became apparent. The possibility of a pre-insolvency
recapitalisation via a bail-in by creditors emerged also. This alternative is very interesting as the
only way it will work is if warning signs are detected. This makes the concept of regulatory
reform even more critical. This concept will be dealt with in chapter four.

The response with regard to governance has been significant in Ireland and the Eurozone as a
whole. The literature review has included a comprehensive review of the various published
governance reports. These were referenced previously within this document. The Governance
reports assess the failures that in some part led to the financial crisis and some of the key factors
required for future success. Of importance is whether the regulatory response to this crisis has
been sufficient. The concern is that the response is too narrow when looking at banks on a
national level. This has been somewhat offset by the policies of the EFSF and ESM.

In the Irish Times, 3rd December 2013, the then-Governor of the Central Bank, Patrick Honohan
commented that ‘bank asset review has been elaborate and expensive’ and that it was a ‘ground
clearing exercise’. In the article he discusses a very interesting concept that would have a
significant impact on Market risk and Value at Risk (VAR). He suggests that in Ireland, Irish
banking may move to a three-way division. Multi-National Companies and high net worth
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individuals would be serviced by a set of international banks. Middle market companies and
Small and Medium Enterprises would be serviced by a group of Irish-owned banks and finally, a
community-banking sector servicing all the rest. This would have a significant impact on the
physical measurement of risk. Capital reserves among community sector banks and the Irish-
owned banks would be restricted and as such lending would be impacted. It could be assumed
then that this would restrict the local economy during times of recession or reduced credit. It
would ensure that a local bank does not have the ability to create financial instability.

The Central Bank of Ireland developed the Probability Risk and Impact System (PRISM) and
launched it in November 2011. PRISM deals with how risk based supervision is being
implemented. The objective is to monitor the financial industry to the point that an individual or
material fail is less likely to undermine overall financial stability.
‘Under Prism, the most significant firms – those with the ability to have the greatest
impact on financial stability and the consumer – will receive a high level of supervision
under structured engagement plans, leading to early interventions to mitigate potential
risks. Conversely, those firms which have the lowest potential adverse impact will be
supervised reactively or through thematic assessments, with the central bank taking
targeted enforcement action against firms across all impact categories whose behaviuor
risks jeopardising our statutory objectives including financial stability and consumer
protection’. (Central bank of Ireland, 2014)

BASEL III:
As described earlier, The Basel Committee of Banking Supervision launched their new set of
guidelines, Basel III, as a framework with specific focus on capital reform, liquidity standards
and systemic risk. These guidelines were then adapted and interpreted by national bodies and
used to build the Dodd-Frank Act in the US and CRD4 in Europe. The new guidelines were
considerably more dynamic than previous attempts and far more complex. Additionally they
were interdependent with other areas, which immediately caused concern around
implementation. To date, regulators have generally disagreed on the interpretation and
implementation around Basel III and indeed there is much speculation around the emergence of a
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Basel IV (KPMG 2013). In the US the focus under Basel III interpretations has been very much
on capital adequacy and liquidity buffers. In Europe, in addition, significant focus is being
placed on risk management, stress testing and alignment. In essence, a greater focus on risk
culture within organisations. The absence of an agreed strategy will undoubtedly increase
barriers to implementation. In fact, it is possibly more accurate to anticipate that the varying
interpretations will create a barrier to success. It is predicted that the increased capital adequacy
ratios coupled with enhanced policy around risk culture will result in a reduction in the number
of bank failures. In addition, there should also be a resultant reduction in bank-to-bank
interconnectivity.

As seen, the Basel guidelines are not without their detractors. The guidelines may take out some
capacity for lending within the system. If not this, then the lending will become significantly
more expensive. This can be added to the likelihood of reduced investor appetite. Cosimano et al
(2011) argue that the primary driver for this item will be the likely reduction in dividend for the
short to medium terms while firms evaluate and build up the cash reserves within the required
timeframe. This is somewhat of an unknown still however the argument has merit. The assumed
costs could be as an increase of sixteen basis points.

From a reform perspective the variation in regulation practices across jurisdictions leaves a large
question mark over interpretation and with it the credibility of the regulatory system in peripheral
areas. Institutions in other regions may well gain a competitive advantage in regions where
regulatory compliance is measured more leniently. Again, this will come down to interpretation.
Another aspect when looking at a situation from a bank perspective is the reality that smaller
banks may get forced out of the market. With such scrutiny they may find it hard to access
capital. As referenced previously smaller banks will suffer in profitability due to the cost of
funding, which is baked into the borrowings due to capital adequacy. In the current risk market
banks need to encourage more investment. The reality is they will need to do a lot of additional
business to get profitably back to the required level.

2014 has seen the heightened speculation surrounding the rollout of Basel IV before Basel III has
achieved full implementation Anderson et al (2013). This significantly demonstrates the different