Showing posts with label TALF. Show all posts
Showing posts with label TALF. Show all posts

Thursday, June 18, 2009

AAA At +425 Bps Over

A very vivid representation of securitization for the Obama generation. When you see 4 different tranches, at spreads between +50 and +425, and all rated Aaa/AAA/AAA, (not to mention all using 12x taxpayer money as leverage) it would be simply criminal if you do not invest all your client's money in any/all of these completely risk free classes.

Oh, and just in case you are desperate seeking a broker with whom to place your all in TALF order, look no further than Citi. After all...
Citi is uniquely qualified to arrange TALF loans due to its relationships with the Fed, the rating agencies, and TALF investors
– Pricing and proceeds will be driven by underwriting, rating agency process and investors
– Proper underwriting is essential to execution since Fed has discretion to refuse securities [We can't wait to see the Fed refusing some pristine AAA-rated POS]
– Longstanding relationships at rating agencies and intimate knowledge of their models [just in case anyone thought there were no models at all]
– Access to broad array of 100+ TALF investors, critical to driving tightest terms and resulting in best TALF execution track record to date [Alas Citi's rolodex excludes CMBS investors, resulting in exactly 0 interest in yesterday's CMBS TALF auction]


Hat Tip ValueatRisk Sphere: Related Content

Tuesday, May 26, 2009

S&P To Downgrade Most Of 2005-2008 CMBS Classes, Derails TALF For CMBS

The lives of the CMSA and Chris Hoeffel are about to get a whole lot more complicated. In a report issued today by S&P, titled "U.S. CMBS Rating Methodology And Assumptions For Conduit/Fusion Pools" Standard & Poors is issuing a Request For Comments on 'its proposed changes to its methodology and assumptions for rating U.S. commercial mortgage-backed securities." Aside from the RFC, S&P goes into detail what the changes to its rating methodology will be, and the impact from these on CMBS. The latter will immediately cause many headaches for all who rode the CMBS AAA train from 1,200 bps to 600 bps, and potentially start a selling puke shortly. In S&P's own words:
Impact On Ratings

It is likely that the proposed changes, which represent a significant change to the criteria for rating high investment-grade classes, will prompt a considerable amount of downgrades in recently issued (2005-2008 vintage) CMBS. Classes up through the most senior tranches of outstanding deals (so-called "A4s," "dupers," or "super-duper seniors") are likely to be affected. Our preliminary findings indicate that approximately 25%, 60%, and 90% of the most senior tranches (by count) within the 2005, 2006, and 2007 vintages, respectively, may be downgraded. We believe these transactions are characterized by increasingly more aggressive underwriting than prior vintages. Furthermore, recent vintage CMBS, particularly those issued since 2006, were originated during a time of peak rents and values, and as such, may be more affected by the proposed rental declines discussed in this RFC. We are currently evaluating the impact of the potential criteria changes on conduit/fusion CMBS transactions from all vintages. Once we evaluate the potential impact on existing ratings, we expect to issue a follow-up publication to this RFC.
And all this just days after the government had finally drafted what it hoped was the last and final version of its TALF term sheet. Lets rewind: in the May 19th version of TALF, in order the be eligible, CMBS "must not have a rating below the highest investment-grade rating category from any TALF CMBS-Eligibile Rating Agency." Throw in a downgrade of 90% of the 2007 vintage and it's time to go back to the drawing board.

Basically, the impending downgrade would make Super Duper CMBS ineligible for TALF. And as Zero Hedge pointed out this weekend, the collapse in all (especially AAA) CMBS spreads was predicated upon the successful implementation and execution of TALF. Now, as S&P rates about 84% of the CMBS universe, the unintended consequence of a rating agency demonstrating a little character and integrity, stands to throw the entire TALF plan into a tailspin, as even with the most recent amendments, almost all Legacy CMBS issues would become ineligible.

But have no fear: Chris Hoeffel is furiously drafting memoranda as he is squealing how this little development will destroy the universe as we know it. It is a safe bet that the Fed will come back as soon as a week from today and announce TALF 364.7, in which the requirement for a current AAA rating is eliminated altogether. In fact, as I speculated (jokingly), anything rated Default or higher will soon be perfectly eligible collateral for taxpayer funding. Because that's just how good a fiduciary of taxpayer money the Federal Reserve is. Sphere: Related Content

Tuesday, May 19, 2009

Fed Bends Over Backward For CMSA, Will Feed Inflation Capacitor With More Toxic Garbage

As Zero Hedge expected a few short weeks ago, the Fed realized that its TALF revision 364.5 for CMBS was worthless, so today, after many deep thoughts on how to force feed U.S. taxpayers even more toxic garbage, the wise and grizzled Ben Bernanke issued TALF directive 364.6 and decided to extend the acceptance threshold to all past legacy CMBS loans as eligible for TALF. While the original seniority has to be most senior, the following cryptic language was added with regard to current ratings:
Current Ratings: As of the TALF loan closing date, the CMBS must have a credit rating in the highest long-term investment-grade rating category from at least two TALF CMBS-eligible rating agencies and must not have a credit rating below the highest investment-grade rating category from any TALF CMBS-eligible rating agency. Eligible collateral will not include a CMBS that obtains such credit ratings based on the benefit of a third-party guarantee or a CMBS that a TALF CMBS-eligible rating agency has placed on review or watch for downgrade. See the “Frequently Asked Questions for Legacy CMBS” for further information regarding TALF CMBS-eligible rating agencies.
Following up on the FAQ, here is some of the salient additional garbage that will force future generations of Americans to pay off their credit cards to Bank Of China. What the Fed is really saying is provided below each respective FAQ section.
Which nationally recognized statistical rating organizations (NRSROs) are TALF CMBS-eligible rating agencies?
TALF CMBS-eligible rating agencies are DBRS, Inc., Fitch Ratings, Moody’s Investors Service, Realpoint LLC and Standard & Poor’s.
We do not believe in relying on someone who has something even remotely resembling half a brain - agencies such as Egan-Jones who have a verifiable and much better track record than the Big 3 will be forever forbidden from providing their correct insight on stuff and things.
Do CMBS (e.g., Class A-2) that receive principal later than the other most senior CMBS classes (e.g., Class A-1) but are otherwise pari passu with such other senior CMBS, qualify for TALF financing?
Yes, the exclusion of “junior” CMBS in the Terms and Conditions is a reference to subordination for credit support, not to a later position in the time tranche sequence.
Yes, we will gladly accept all crap. In fact, in 2 weeks, when we realize that we could be even more generous with other people's money, we will accept diarrhea, vomit and biohazard as well.

On what basis will the New York Fed decide whether or not to accept a CMBS under the legacy TALF program?
The New York Fed may reject a CMBS based on factors including, but not limited to, the following:

  • The CMBS does not meet the explicit requirements stated in the Terms and Conditions.

  • Unacceptable performance of the mortgage loan pool. CMBS that represent interests in pools with high cumulative losses, a high percentage of delinquent loans, loans in special servicing or loans on servicer watch lists or a high percentage of subordinate-priority loans may be rejected. The New York Fed may consider in its decisions forecasts of pool level losses under various stress scenarios.

  • Unacceptable concentrations. CMBS that represent interests in pools that, alone or considered together with loan pools backing other TALF-financed CMBS, possess one or more concentrations (such as borrower sponsorship, property type and geographic region) considered unacceptable to the New York Fed may be rejected.

The New York Fed will utilize the services of one or more agents in connection with the review of legacy CMBS and the loan pools that back them.

Don't ask, don't tell works well for the military. Going forward we will consult exclusively with PIMCO and BlackRock in determining which asset manager makes billions as the expense of taxpayers... We will start with PIMCO and BlackRock.

Are zero coupon ABSs eligible as collateral for the TALF?
No. Zero coupon ABS are not eligible as TALF collateral.

We need to make sure the "Private Investors" collect at least the 2-3 cash coupon payments that make them whole on their investments, otherwise they will balk if they stand to lose anything.

What happens if an ABS that was eligible for TALF financing is downgraded by an NRSRO?
Nothing happens to existing TALF loans secured by that ABS. However, the ABS may not be used as collateral for any new TALF loans until it regains its status as eligible collateral.

Why would anything have to happen if the piece of crap start being a very smelly piece of crap? After all it is other peoples' money at risk, not PIMROCK's... Since when do we actually care about the taxpayer.

And just so there is no confusion, here is CMSA's immediate response to the most recent TALF lunacy:

Commercial Mortgage Securities Association has regularly and vocally advocated for the inclusion of both legacy and new CMBS eligibility in TALF and the association continues to press forward for the revival of the credit markets and the larger commercial real estate market. CMSA looks forward to its ongoing conversations with the Federal Reserve and with policymakers to ensure that the TALF program and other relief efforts maintain a view toward providing liquidity and facilitating lending in the most efficient and effective manner.

Please, everyone, it is your moral duty to take your wallet out right now and hand over your money to the CMSA... All of it... After all, on a NPV basis, that's exactly what we are all doing.

hat tip Alex

Sphere: Related Content

Monday, May 4, 2009

CMSA Tipping Its Hand Over General Growth Properties

After the CMSA, through the valiant efforts of one Chris Hoeffel, Managing Director at InvestCorp, got what it wanted in the TALF extension for CMBX from 3 to 5 years, but subsequently realized it is insufficient to package all existing loans and lower rated securities, it is now focusing on other, much more relevant aspects of the ongoing crunch in Commercial Real Estate (but don't think they are done with TALF, only a matter of time before the push for the new version is rekindled, see below). Their most recent concern: General Growth Properties and the troubling development of Bankruptcy Remote Entities potentially suffering substantive consolidation, a topic whose dramatic implications Zero Hedge has discussed previously.

The CMSA has apparently read Zero Hedge and is now sweating which buttons to push and reverse the course that GGP has taken, which as I speculated, could be very adverse not just for the bankrupt mall REIT but for the entire industry. Here is a press release the Commercial Mortgage Securities Association has issued:
CMSA Files Amicus Brief on General Growth Properties Bankruptcy

CMSA and the Mortgage Bankers Association on May 1, 2009 filed an amicus brief with the U.S. Bankruptcy Court, Southern District of New York, presenting information on the serious negative implications for commercial real estate finance in the remedies and positions pursued by General Growth Properties in its bankruptcy filings.

CMSA believes that the inclusion of special purpose subsidiaries in General Growth Properties bankruptcy filing in mid-April may threaten the fundamental principles of structured finance and securitization. Borrowers receive favorable loan terms based on lender, investor and rating agency reliance on isolation of the commercial property from the credit exposure of affiliates of the borrower. CMSA believes the strategy pursued by GGP violates this principle and, if upheld, would put into question the reliability of the rule of law in commercial finance.

CMSA strongly believes that the actions sought and positions taken by GGP are not supportable, violate fundamental legal and financial principles, and would be a tremendous blow to an already shaky economy and to federal and private-sector attempts to revive the commercial mortgage-backed securities market.

For a full copy of the joint amicus brief, click here.
And of course, any outcome that is not to the liking of the CMSA, will only provide them with more political leverage to readjust the terms of the TALF programs for Commercial Real Estate one more time. In fact Citi has already opined on this in a Roundtable on Securitized Products:
We believe Friday’s announcement was only an early expansion of TALF 1.0. We believe that the Fed and Treasury are still evaluating expanding TALF to secondary CMBS positions as part of the next phase of TALF expansion. An announcement is likely in the coming weeks.
So yes, looks like more money will be thrown at the problem. After all it is merely cotton with some green ink at this point.

CMSA amicus brief below:


hat tip Alex Sphere: Related Content

Friday, May 1, 2009

TALF v364.5, Now With Enhanced CMBS Dumping Provisions

Below we present the summarized term sheet of the most recent reincarnation of the TALF, compliments of the Federal Reserve.
Securitized Bonds: Created on or after 1/1/09

Underlying Loans: Created on or after 7/1/08

Collateral Type: AAA cusiped & cleared through DTC – required investment grade rating from minimum of 2 rating agencies

Haircut: 15% (85% leverage) for 5 year bonds to 20% (80% leverage) for 10 year bonds

Leverage Terms: Borrower may elect to index against either 3 or 5 year swaps

Spread: 100 bps

Bond Life: No more than 10 years

Prepayment: Par at any time

Early Collateral Prepayment: Flow’s through to pay down

Fed Rights: Throw out loans from prospective trusts (similar to b-piece) – NY Fed has right to engage 3rd party collateral monitors - influence structuring of hypothetical trusts (location-collateral type-etc.)
Amusingly, the Commerical Mortgage Securities Association (CMSA), better know as Chris Hoeffel (quite familiar to Zero Hedge readers) who has yet again reprised his role as the least conflicted person in the world through his positions as both Managing Director of foreign capital backed, CRE asset manager InvestCorp AND president of CMSA, had a canned, ready to print response to the Fed's actions (obviously somewhat priced into the market) which came out nanoseconds after the Fed's announcement and which we present below:
CMSA Applauds Federal Reserve on TALF Announcement

Lending Facility Extended to CMBS with Five-year Term

NEW YORK—May 1, 2009—Commercial Mortgage Securities Association applauds today’s announcement by the Federal Reserve Board to extend the Term Asset-Backed Securities Lending Facility to commercial mortgage-backed securities with an increased five-year term.

TALF is a central part of the U.S. government’s plan to encourage lending by restarting the market for various types of asset-backed securities. TALF recently became operational for consumer ABS with a three-year term for these assets.

The Federal Reserve in its statement today said that, starting in June, TALF loans with five-year maturities will be available for the June funding to finance purchases of CMBS, ABS backed by student loans, and ABS backed by loans guaranteed by the Small Business Administration.

“The inclusion of CMBS as eligible collateral for TALF loans will help prevent defaults on economically viable commercial properties, increase the capacity of current holders of maturing mortgages to make additional loans, and facilitate the sale of distressed properties,” the Federal Reserve said.

The Federal Reserve also indicated that up to $100 billion of TALF loans could have five-year maturities and that the FRB will continue to evaluate that limit.

“Extending TALF to CMBS with five-year terms is critical to providing liquidity and facilitating lending in the commercial mortgage market,” said Christopher Hoeffel, President, Commercial Mortgage Securities Association. “CMSA has strongly advocated for a term of five years to kickstart investor demand,” he said.

“A five-year term is more consistent with the longer-term nature of commercial lending and will provide more flexibility to borrowers as they navigate the current real estate cycle,” he said. “CMSA and its members applaud the government and policymakers for extending TALF to CMBS and extending the term to five years,” Mr. Hoeffel said.

Since late 2008, CMSA has been in regular discussions with policymakers and has outlined the benefits for extending TALF’s financing term to five years. Those discussions followed CMSA’s formal recommendation to the government that the Federal Reserve extend the loan term and that it make legacy commercial assets eligible for TALF.

While today’s announcement by the Federal Reserve extends TALF to newly issued CMBS with a five-year term, CMSA anticipates that policymakers will extend TALF to legacy assets in the weeks ahead, as previously stated.
Maybe Chris, the CMSA, and all those investors who have been buying CMBS hand over fist will soon reevaluate their optimism one they realize that the July 1, 2008 cut off date for eligible loans means that essentially the entire pool of distressed assets is completely ineligible for participation in even this brand new revision. In all honesty, ZH was hoping that the Fed would open the new TALF to all securitizations created concurrently with the advent of the wheel or discovery of fire, and a rating of Default or above would have been perfectly agreeable to Bernanke. The fact that the Fed still has not grasped the true magnitude of the problem is indicative that over the next 2 weeks we should all expect version 364.6 of the TALF once Chris scratches his head and realizes he still can't offload his garbage heap of bankrupt mall loans to taxpayers. For now, unwitting taxpayers are still safe from owning a bankrupt 30 retail outlet mall in the middle of the Yucon, purchased initially at 500% LTV and a DSCR of -10x, a -$1 billion reserve, and with pro forma stats upon conversion to high priced multi apartment units for eskimos, replete with with Arctic explorers-cum-doormen, husky shuttles and frozen igloo statues. Sphere: Related Content

Tuesday, March 24, 2009

The Ridiculous Marks Of Toxic Assets

The Treasury's arbitrary transaction price of 84 for the "pool of residential mortgages" seems to not have been all that arbitrary after all. In fact, as it may turn out, it was gloriously optimistic. A report by Goldman today on the PPIP caught my eye, with one chart in particular, indicating that bank are still marking the bulk of their "assets" at 90-95! Of particular note is Citi's delirious optimism on marks in its assorted asset classes, especially commercial mortgages.

A PPIP transaction at 70 is one thing, one at 95 is very much different, especially when the FMV is in the 30-40s, as the potential equity upside is very limited, while the downside is... well... much less so. Have not had much time to dig into this but present it for consideration and commentary. If banks have expectations for bid levels north of 90 on the bulk of TALF-mediated transactions, this could really end up being a lot of hot air, despite PIMROCK's enthusiastic endorsement of the proposal.

Sphere: Related Content

Sunday, March 22, 2009

The Amazing TALF Bait And Switch

The greatest bait and switch of this generation in all its visual splendor. As a result of the TALF's non-recourse/non-margin nature, a hedge fund X can buy Bank X's MBS Portfolio which is marked on the bank's books at 80 cents on the dollar (but has a market price of 20 cents) for the marked price with a 3% equity check and TALF filling the balance. A day later, Bank X repurchases the portfolio from hedge fund X at the 20 cent market price, and pays HF X a $5 million fee for the "trouble." The way this would be effectuated is that at t+1, the Hedge Fund decides to run a loss model via TREPP of what have you, and, lo and behold, realizes the loan will default in 1 day (assumptions and outcomes can be easily fudged) and threatens to default on the entire TALF portion. The key word here is non-recourse: the HF would not be liable for anything over its first-loss equity component. In the case of a declared portfolio default, the TALF portion would have to be marked at pure market value, and taxpayers would get stuck with as close to a donut as possible. So here is Bank X running back to the rescue, offering to buy back the original portfolio at market price (even a 1 cent premium would make it politically palatable), in this case 20 cents. For the sinister minded, it become immediately evident, why hedge funds, once loaded up on these investments, would have an incentive to push down the value of the entire portfolio complex, especially if they, wink wink, bought protection via CMBX or other derivatives. The recent spike in CMBX spreads (massive buying pressure) may be one indication of just how hedge funds might be positioning themselves.

Once purchased the bank waits for the portfolio to appreciate to 50 cents on the dollar by 2014 (although the appreciation is not necessary and is a best case example of how the bank would fare if the market does pick up). Hedge fund X takes a 75% loss on its nominal equity stake but more than makes up in transaction fees. The TALF portion takes a 75% loss with no recourse and no margin to fall back on.

As a result Bank X takes no writedown now, and in 5 years may book an equity profit of as much as $25 million (net of transaction fees paid to the Hedge Fund X), while Hedge Fund X books a profit of $3.2 million for one day's work...

Lastly the U.S. taxpayer loses $54.3 million on a $77.6 million TALF Investment, or 70% (net of 5 years of interest income).

Note: the maximum TALF size is $1 trillion. Will U.S. taxpayers suffer $700 billion in losses from the TALF? Ask your congressman.


Sphere: Related Content

Thursday, March 19, 2009

Another View On The Public-Private Investment Fund

On occasion, Zero Hedge has discussed the utility of such programs as the TALF and the Public-Private Investment Fund, all core components of the Financial Stability Plan, which, when first presented by Tim Geithner in Feruary, shocked the capital markets with its alleged insufficiency and opacity.

Here we present the view of Gorelick Brothers Capital, a fund investor, who in their most recent market update notes that it has "reviewed over 140 new fund proposals, mostly from hedge funds, private equity and other money managers. These funds have targeted approximately $70 billion in new capital and have been able to raise about $35 billion to date. This tally excludes private equity firms investing chiefly in commercial real estate loans and equity, as well as distressed debt funds focused on corporate bonds and loans. In the face of overwhelming supply, $35 billion of fresh capital has hardly made a dent in the opportunity."

The report is an interesting insider's perspective of what potential role the TALF and PPIF might serve for any pent up capital demand, and how it may make lives for Fund of Funds somewhat easier, although it is not explicitly clear to Zero Hedge if the TALF will indirectly subsidize FOF capital for investments in asset managers who intend to use the PPIF as an investment vehicle.

Sphere: Related Content

Thursday, March 5, 2009

More On TALF's Proposed Overkill

As the chart below indicates non-agency RMBS, CMBS and ABS were running about $240 billion per quarter at the market's peak, which confirms our previous point that at $1 trillion max capacity, the TALF's $1 trillion in purchase power equates to 2.7 years of issuance at the peak 2001-2005 levels, and will likely not be filled any time soon. Furthermore as the TALF appears eligible only for new ABS issuance not ABS securities created before 2009, the rally in pre-2009 ABS is indicative of speculation that the administration will adjust this mistake mid-stream and include older ABS positions in TALF eligibility (one loophole would be taking pre-2009 loans and packaging them currently). Unless there is yet another administration flip-flop on policy, the aggressive run up in older vintage ABS will be yet another governmental front-running mistake committed by most funds and result in rampant selling of these securities which had seen a big higher recently. (hat tip reader Mike)

Sphere: Related Content

Wednesday, March 4, 2009

Could TALF Be The Biggest Disappointment Yet?

Many hopes and dreams reside with what so far has been the best accepted (at least by Wall Street's conventional wisdom) government program - the Term Asset-Backed Securities Loan Facility, aka TALF, aka Prime Broker Of The People, By The People, For The People. But as we have seen before (TARP 1, TARP 2, Tim Geithner) it is usually only a matter of time before those who read (instead of just repeating the talking heads) scratch the surface and sniff between the lines.

An implicit role for the TALF is to provide the role that securitizations used to provide in the good old days (and which also were one of the main factors that lead the global economy to be where it is now), as securitizations facilitate the reselling of leverage by allowing risk tranching (of which Iceland always somehow ended up buying the riskiest class) and further leveraging when it is finally offloaded to the end investor. The TALF launched yesterday in its non expanded version covers $200 billion of loans ($20 billion of TARP funds leveraged 10 times) supporting autos, credit cards, student loans and small business lending. Once the TALF is expanded into its fully unaccordioned state it will have access of up to $1 trillion and will support CMBS, RMBS and ABS corporate loans (through the soon the be downgraded CLOs). The three main benefits to a TALF investor are the following: the program will be non recourse (no risk aside from an initial haircut defined for any specific asset class it is used for), there will be no mark to market, and participants will not be subject to executive compensation limits. TALF has some significant limitations on the surface (and below it, as we will investigate further): the TALF only lets investors back into the AAA market (TALF is not geared at any asset classes below AAA), it does not benefit auto and credit card issuers that have become bank holding companies (due to the direct-from-Fed lower funding costs of on-balance sheet financings), and lastly, the cost of all these incremental loans will have to be funded by the Fed which is already seeking enhanced authority to issue debt and finding ways to create other monetary base expansion mechanisms.

How does the TALF work?

In summary, TALF leverages TARP funds, turning $20 billion of funds into $200 billion purchasing power (or $100 billion leveraged to $1 billion per the revised TALF definition), which as mentioned, is non-recourse and has no-remargining. This means the only risk for investors is the initial haircut, and even that should not be classified as a risk per se (more on this shortly).



The initial problem with the TALF appears its expanded size, which may have been just some more of the Fed's psychology of "picking a really big number." As Bank Of America says, the $1 trillion target size "appears outsized relative to the underlying issuance capacity of the targeted markets suggesting less impact from this program than advertised." Granted, when the TALF was first announced on December 19, it caused a dramatic tightening of AAA spreads in the auto loan, credit card and student loan space, and per the recent update, will also likely benefit the CMBS and CLO AAA spreads. One could argue, and the market would justify, that all benefits from the TALF have already been priced into AAA tranches.



The Treasury's justification for such a focus was the "$1.2 trillion decline in securitized lending" between 2006 and 2008. The figure below demonstrates the changes in level and composition of securitized lending that were being referred to:



Unfortunately for Geithner, who apparently did not read too deeply into the data, the bulk of the $1 trillion decline in securitizations came from home equity lending and non agency RMBS, which reflect the "non-conforming" mortgage market, i.e. the subprime, alt-A and jumbo origination, loans which are the cause for the credit crisis, and which are rated far below the relevant AAA level. The truly unmet market, which the Treasury is addressing is at best 20% of the revised total amount.



Thus, the focus of the TALF appears misplaced. While the original size of $200 billion is applicable to current market needs, pushing for a 5x higher total notional of securitization replacement, even after utter pandering to private participants, is nonsensical, and likely the administration had the unfortunate intent of merely shocking the market into believing that as the program now has a trillion handle, all securitization problems could be resolved. That is patently wrong.

What is in it for the investor?

The TALF will not be demand limited, as it will generate up to 20% virtually risk-free returns to investors, due to low funding levels (roughly 100 bps over LIBOR) and marginal haircuts. The simplest return calculation is taking the net spread on the assets times the leverage, the traditional formula used by all leveraged lenders. Using a prime credit card 3 year loan, this works out to 200 bps over LIBOR less funding costs (i.e. 100 bps) all times 20 (1/ asset specific haircut of 5% as seen in matrix below), resulting in the mentioned 20% return.



Based on that formula the returns would vary between roughly 7% and 20% with essentially no downside risk due to the non-recourse and non-margin nature of the TALF.

Summary

As noted above, there seems to be a gross misperception of the nature of the TALF as a product that has been created to address a "demand for credit" problem. This is wrong, as seen in the returns analysis above from a TALF investor's standpoint: the very attractive returns guarantee there will be no lack of desiring participants to use taxpayers' capital and backstopping to generate up to 20% returns. The problem is that in an overall environment of consumer and commercial deleveraging, using the 2006 peak market conditions as a guide to the program's success ignores that based on the inevitable decline in demand by potential securitizers, overall use of the program relative to peak securitization levels will decline. Therefore the $1 trillion maximum utilization target on the TALF is a pipe dream and merely one more round in the government's arsenal of shocking the market with soundbites and large numbers: its old incarnation of $200 billion would have been perfectly satisfactory, even more so as $80 billion less taxpayer capital (via TARP) would have been put at risk. The success of the program will hinge on merely avoiding more defaults and economic damage that would have been inevitable if credit availability had not been there. And lastly, the stupid shift in the administration's push to encourage demand, which will be there regardless, by removing compensation limits is, of course, another blatant demonstration of the government's misunderstanding of its own programs and the supply/demand market mechanics they create. Sphere: Related Content

Tuesday, March 3, 2009

And The Administration Backpedals Again: Comp Limits Eliminated For TALF Participants

In the latest example of just how half-baked the administration's "economic recovery" ideas are, the Fed and U.S. Treasury just announced that TALF sponsors will not be subject to the same executive compensation limits that all other TARP recipients have to adhere to. As the TALF is essentially a taxpayer backstopped Prime Brokerage service to anyone willing to use it, in which funds and other participants have virtually no downside as any losses over 10% are covered by the government, read taxpayers, it would be idiotic for anyone who has this option not to jump onboard... Especially since now CEOs and traders can again take massive risks in expectation of even more massive compensation, however this time not only with taxpayer TARP money, but also backstopped via the TALF itself. This is another scandal waiting to happen.

As Bloomberg reports:

The change suggests the government doesn’t intend to apply compensation limits beyond firms that receive direct investments from the Treasury’s $700 billion bailout fund. Officials have yet to announce whether such requirements will be imposed on firms participating in a separate effort to remove as much as $1 trillion of distressed assets from banks’ balance sheets.

"Just like salesmen toward the end of the month get kind of worried if they’re not meeting their quota, the Federal Reserve has got to worry,” former Fed monetary-affairs director Vincent Reinhart said. Today’s moves are “an attempt to make the facility more accommodating,” said Reinhart, now a scholar at the American Enterprise Institute in Washington.

The revised terms and conditions of the TALF, posted on the New York Fed’s Web site, omitted a previous section on compensation requirements. The limits were previously instituted because the program is being seeded with funds from the $700 billion financial-stability plan, which has provided capital injections to banks with compensation rules attached.
Seeing how pretty much any security will be eligibile for TALF purchase, this revision in terms, will make rampant risk taking even more pervasive.

The Fed and Treasury “currently anticipate that ABS backed by rental, commercial, and government vehicle fleet leases, and ABS backed by small-ticket equipment, heavy equipment, and agricultural equipment loans and leases will be eligible for the April funding of the TALF,” which is scheduled for April 14, the agencies said. Small-ticket equipment may include office gear such as telephone systems, computers and printers, while heavy equipment includes construction vehicles.
The wholesale government panic to prevent the impending market collapse is becoming ridiculous, and is only just postponing the ultimate crash, while likely making it even more acute when it eventually happens. Sphere: Related Content