It seems like a good idea. Create a separate federal agency to monitor systemic risk exposure in financial markets. Require the major players to report trading data to this agency that they withhold from the public, so that a better picture can be drawn. Require this agency, the National Institute of Finance, to issue periodic reports, alerting the rest of us to developments that pose a risk of widespread disruption.
Certainly it’s better than nothing, which happens to be the status quo. (In theory the Fed should be doing this already, but in practice they have no interest.) If we had had such an Institute five years ago, perhaps they would have added their voice to those in the economics and finance professions who said leverage was careening out of control.
But the approach embodied in the bill currently gestating in the Senate Banking Committee is built on a compromise that puts sound risk management, well, at risk. It goes like this:
As we have come to realize, a large part of the instability of global finance resulted from the pyramiding of increasingly complex financial instruments. There was an arms race between quants to develop evermore devious contracts, whose terms would be triggered by intricate combinations of market outcomes. Firms invested heavily in these strategies, and algorithms and instruments were jealously guarded as intellectual property. Trades were conducted in private, with no central registry, much less a public reporting of their terms. The terrible truth we learned in 2008 is that no one could possibly know how the system as a whole would respond to the seismic shocks of bubble-bursting, illiquidity and default. We waited breathlessly, week after week, to see how the unraveling would take place: real-time, real-life enactment was the only way the structural properties would be revealed.
Would an Institute of Finance be able to figure out the stability and dynamics of the system before it collapses? It depends on the information they are able to get. If they have access only to the data that are already publicly available, they’ll be in the same boat that independent analysts are in already. And true enough, many of us were able to see aspects of this crisis in advance, and we sounded the alarms. It is also true, however, that no one saw the entire process (we saw chunks of it), and our voices were drowned out by those who thought our fears were overblown. If the Finance Institute becomes one more such voice in the wilderness, will it make a difference?
But the discussions under way have broached the possibility that Institute staff would receive more reporting data than is currently made public, under a guarantee of confidentiality. This could make their pronouncements more credible and influential. Yet there are two shortcomings. First, it can be assumed that the Institute will not get all the trading details, only some. There will be negotiations with the banks, equity funds and other players, and deals will be cut. Even so, you can be sure that the details of some trades, perhaps the most essential for those who want to analyze the health of the system, will be withheld precisely because they are both profitable and risky, and participants want to milk them to the end. Second, it is the unfathomable complexity of interacting algorithms that is at issue. The players can’t figure it out, and, even with piles of trading data, it is likely that civil servants will be stumped too.
There is a much simpler, more effective solution. Require all contracts to be traded on exchanges, and all their terms to be reported publicly. (Perhaps the identity of the parties could be confidential; this is all.) There would be no intellectual property in financial instruments, and no incentive to devise ultra-complex variations. Algorithms used internally by investors to decide what positions to take would still be proprietary, of course, but these pose few systemic challenges. Contracts would standardize in convenient ways, and the public as a whole would be in a position to assess where the system is heading. You could be your own Institute of Finance.
What is the downside? Less profit opportunity in finance, a more routine, predictable, boring role for the financial sector, and fewer job openings for math jocks on Wall St. That’s probably enough to kill the idea politically, but from a public point of view, this down is all up, up, up.