FINPOLCONSULT | email@example.com
to FINPOLCONSULT, the financial sector development specialist and think tank.
My company offers specialized economic, market and legal-regulatory analysis and advice at the intersection of capital markets, mortgage markets and housing markets. In these areas, my work experience dates back to the early 1990s and I have been one of the pioneers of the profession.
During the Global Financial Crisis and the subsequent Euro crisis general financial sector development, banking regulation, sovereign and subsovereign finance became new and promising business lines. Since 2008 I have been a key independent voice in Germany and Europe on policy design in these areas.
My broader goal is to support the global knowledge base in the financial sector, help to develop more efficient and competitive businesses as well as transparent, stabiity-oriented and socially responsible public policies in this area.
For this commitment, I stand with my name.
Hans-Joachim (Achim) Dübel
If any of the links do not work and you are interested in the material, please e-mail me under firstname.lastname@example.org
Pls also mail if you would like to receive my regular e-mail comments (indicating whether you read German)
June 2016: Publication of our six country Middle Eastern housing finance study is delayed, but will hopefully come this month.
Comments in DWN on the European deposit insurance debate (German), which completely ignores that the bailout interventions of the ECB left foreign investors off the hook for sharing losses of bank assets and - because ECB is usually better collateralized or even de-facto super senior (Cyprus) - thus maximized the losses of the local deposit base. The result in Cyprus, as fmr. Bank of Cyprus CEO Evdokimos Xenophontes shows, has been a tripling of the losses for >100K deposits from 15% (pro-rata) to 45%. But the same loss given default increases are of course present for <100K deposits, which require then proportionally larger government rescues - in the four large banks in Greece alone, the government lost 25 billion Euros. That bill might have been halved if foreign investors would not have been bailed out by the ECB, NB French banking system insider Jean-Claude Trichet (who even bought Greek government bonds at 80 cents/EUR). Conclusion: with a rogue ECB that copies foreign investor bailouts performed by the IMF in emerging markets under the 'lender of last resort' disguise, European deposit insurance based on mutualizing private bank deposits will go nowhere.
March 2016: I don't usually reference Der Spiegel for its Neocon warmongering in Syria. But they got it right here on the economic benefits of bail-in for Cyprus. Bail-in even of senior unsecured credit helped to save government from bankruptcy and thus protect the economy from a huge demand shock, as in Greece. The implementation by Cyprus and in particular the ECB (where questions of conflict of interest of individual staff were raised) was abysmal, indicative of the dire lack of co-ordination of bank resolution policies which we hope to solve with the European Single Resolution Board (SRB). However, with growth kicking in, the Cypriot government will perhaps have a window of opportunity - a la Spain - to correct some of the social imbalances created by the bail-in. PS - if Mr. Pissarides believes that he wouldn't be bailed in as a senior unsecured creditor in a British bank bail-in, he should have a word with his colleagues at the Bank of England, Department of Bank Resolution.
November 2015: Presentation held at the 3rd International Housing Finance Conference in Seoul/Korea on European mortgage consumer protection. I was asked to do a section on mortgage debt restructuring. In terms of principal reduction, the recent Hungarian case, which now Poland, Croatia and Cyprus try to mimick, excels. I am preparing a paper on the subject to be finished ca April 2016.
October 2015 Our savings bank system (Sparkassen) is a political leviathan that in combination with their apex institutions (Landesbanken) has command over huge volumes of public subsidies (to absorb losses from US subprime to global shipbuilding), because of direct access to taxpayers coffers shows cratering governance standards (as exemplified by excessive board staffing and remuneration), and paralyzes any meaningful discussion about German financial sector reforms. A team of young journalists that uses crowd information gathering techniques has started to look into the governance issues, and a recent drastic case of mismanagement in Northrhine-Westphalia on which I commented.
June 2015: Comment on the wisdom of taking the Greek banks and their mostly small depositors as hostages in the escalating fiscal dispute between Berlin, Madrid (mind the Spanish elections in late 2015) and Athens (German). With a little bit of game theory you soon understand that rising ECB lending to Greek banks that result from the current bank run is undermining, rather than helping, fiscal hardliners positions. In February or March 2015 it would have been still easy to stop the Greek bank run with open mouth policies, confirming the obvious, namely that Europe since late 2014 (start of the SSM, enabling of the SRM and promulgation of the bank resolution and recovery directive BRRD) has a more or less complete banking union. This implies that those very Greek deposits under EUR 100K are protected, just as next door in Bulgaria and Cyprus they were, when the banks failed and governments were unable to protect depositors and the Eurozone or the European Union helped out. The Bulgaria case shows that the protection promise holds even in the Grexit case. Moreover, unlike in Cyprus, there are no bail-inable funds left in Greek banks to pay back the ECB. So it is better in the self interest of fiscal hardliners to stop the Greek bank run, thus reduce their exposure and improve their negotiation position, and focus on the fiscal policy items on the agenda.
May 2015: Comment on the potential destabilizing impact that a deepening Bund rout could have on German banks (German). Due to regulatory failure, in particular German regional banks hardly use swaps or bonds to match fund mortgages, and also hold high levels of long-term bonds.
Mortgage originations in the German market due to the dual impact of 'interest binding shopping' by consumers, which has extended the non-callable periods all the way to 15 years on average by May 2015, and the declining rate levels bound for such long periods, show strongly increasing durations. As old 10 year binding periods expire, the overall portfolio swiftly gains in duration. Ballooning durations help to explain why German house prices are rising while the outstanding mortgage debt level hardly does so.
Just consider that a 2% amortizing 15 year fixed rate bond has a McCauley duration of 12%, i.e. a 1% rate increase would wipe out 4 times the capital that a bank has to hold for that mortgage. Unless .. it is match-funded.
Comment on the Bund rout (German), i.e. the tension created by a combination of overvaluation via QE and the lack of liquidity at such price levels. Nobody in Europe can afford rates to shoot up a la Japan 2003 to reach market equlibrium, so expect the bond market weather to remain stormy.
Apologies for the lack of updating in recent months. I have been offline for a while due to heavy workload.
April 2015: Interest rate comment for Dr Klein, the leading German corporate housing finance broker, called 'capital markets on steroids' paraphrasing the effects of ECB quantitative easing (German, p. 10).
In April 2015 I completed and presented in Brussels a study for DG Competition of the EU Commission on Obstacles to Bail-in of Junior Bank Debt Instruments. In the work program I reviewed obstacles intrinsic to both legacy and new style junior bank debt instruments (esp. AT1), as well as related to incompleteness or inaccuracy of the European Resolution & Recovery 'handbook' under development (Good Bank/dead bank; bad bank/asset swap; mandatory liability management). You surely followed some problem cases, like Hypo Alpe Adria/HETA or Bank of Cyprus/Laiki. This work is unpublished for contractual reasons, I may publish an article or summary going forward.
I also do intensive work on creating a multi-seller covered bond facility and redoing the covered bond law in Armenia, financed by the German finance ministry BMF and managed by KfW. Building new financial structure is just as important as tearing obsolete one down, even if you are more of a Mephistopheles character.
October 2014: comment on the severe open banking union problems remaining with the introduction of the SSM in November 2014. These are in particular: an insufficient specification of the early intervention capacity of the SRM, which like FDIC in the US is the only guardian of depositor interests in the system against inflated central bank lending and insider creditor rotation; a politics-driven configuration of the banking fee system; and the far too high minimum deposit insurance protection level of EUR 100K which is inconsistent with the fact that the SRM will not enjoy a full faith and credit fiscal backup (just like the FDIC is technically not backed up by the FFC of the United States, whatever the FDIC website says). Kommentar auf Deutsch.
September 2014: interest rate comment (Deutsch) for Hypoport AG. Hypoport, the Berlin SDAX firm where I have my office, is dominating corporate housing finance brokerage in Germany and the largest B2B broker (fee originators 2 banks/insurers) for retail housing finance in Europe.
Can only publish this now. Through May/June 2014 I dug into Depfa Bank plc's historic fate from German taxpayer perspective (Deutsch) for a private sector client, after the German MoF finally decided to wind the bank down rather than selling it. It turns out that in October 2011 Germany wasted another EUR 2 billion by not restructuring / resolving the bank and haircutting hybrids and subordinated debt in the process under the new Irish Special Resolution Regime. This innovative resolution regime had been spearheaded aptly by an Irish government frustrated by high bailout cost. The German finance minister apparently was not frustrated then as much, and simply applied the same bad bank bailouts agreed on for the Landesbanken (left/right pocked for public investors) under Para 6 Finanzmarktstabilisierungsfondsgesetz to federal bad banks exchanging assets with private banks under Para 8 of the same law. The Commission almost went mad over the deal, but here in Germany very few seem to care.
NBP workshop Recent
trends in the real estate market and its analysis, 2013 Papers
submitted for publication are now published in the Narodowy Bank Polski
Working Paper Series and will be indexed on IDEAS REPEC and SSRN.
August 2014 Contribution of a chapter to The Global Financial Crisis and Housing on Transatlantic Mortgage Boom and Bust. The book has been carefully edited by Susan Wachter, Man Cho and Moon Joong Tcha. Korean Development Institution Series in Policy and Development, Edward Elgar.
July 2014 Short comment (in German) on the decision to make ESM funds retroactively available for bank recapitalization in 'individual cases'. Clearly, the motive is to make room for compensatatory interventions, e.g. benefiting Ireland for the rude disruption of the country's sovereignty in October 2010, when a coalition of politicians from countries with large investors in Anglo Irish Bank senior unsecured debt forced the Irish sovereign to absorb their losses. Is there no better way to solve this de-facto bilateral issue than to change the rules of the ESM and open the ESM up for abuses in other cases? See also the 8 banks 8 countries bank restructuring study covering Anglo Irish Bank. Compare the armtwisting of Ireland with the complete neglect of the Danish decision, also in October 2010, to bail in senior unsecured investors in the case of Amagerbanken.
July 2014 Publication of a Finpolconsult study on mortgage prepayment indemnities in Europe (Vorfaelligkeitsentschaedigungen in Europa) as a follow-up on the implementation challenges of the EU CARRP Directive. The study has a broader discussion of the mortgage product menu and its stability implications as well as German mortgage market issues (in German, Anschreiben). German speakers might be interested in the survey on prepayment indemnities in Germany undertaken by the vzbv consumer group, of course always bearing in mind that it is a lobby group pushing its case (just like the banks). Die Welt has press coverage of my study and a piece produced by IW on the subject. For english studies and material on the subject and European mortgage finance in general see the housing finance page on this website.
I get lots of media requests on performance and restructuring issues of Austrian banks, in particular Hypo Alpe Adria (where the Austrian government found a legal lever to void the Carinthian state guarantees for subordinated debt issued by the bank) and the large Austrian banks Erste Bank and Raiffeisen with their significant CEE exposure. See also my work for EBRD on the CEE mortgage sector, which has been a major generator of problems for Western banks. In an economically and politically fragmented region we need more concertation of investment and lending strategies between public and private banks.
March/April 2014: presentations on creditor participation in European bank restructuring at Bruegel Institute (Finance Breakfast), upon invitation of Nicolas Veron, and CDU Wirtschafsrat, Bundesfachkommission Banken. PPTs as per below entries.
March 2014: publication of a study on Central/Eastern European mortgage and covered bond markets (Realkredit- und Pfandbriefmaerkte in Mittel- und Osteuropa) financed in 2012 by a German covered bond software provider (German). The study benefited from the earlier EBRD study available for download below. Covers also commercial real estate markets and additional countries.
February 2014: brief e-mail comment on the misinterpretations of the German bad bank experience that prevail at the Austrian central bank, re the hefty dispute with the Austrian finance ministry on the method of unwinding the Carinthian Landesbank Hypo Alpe Adria (in German). Or should I say the dispute is between Raiffeisen Bank International and Erste Bank?
February 2014 Paper for the National Bank of Poland on mortgage finance regulation issues in transition countries, summarizes my 2012 EBRD study.
January 2014: Presentation given at DG Competition of the European Commission on creditor participation in European bank restructurings. Slight changes vs. the IFO (and December 2013 Cyprus Price Waterhouse conference) versions, e.g. additional material on Slovenia. Presenting at DG COMP on this subject means of course carrying owls to Athens, so I probably learned more from them than they from me.
December 2013: interview with Gold Magazine on the background of the Cyprus creditor bail-in decisions taken in March 2013. I spent a couple of days on the island and came to conclude that the shortcuts taken in March during the purchase and assumption operations (transfer of Greek operations of Laiki and Bank of Cyprus to Piraeus Bank, transfer of Laiki good assets to Bank of Cyprus) and regarding the transfer of legacy ECB debt ('dark matter', which ominously made it from Laiki in Greece to Bank of Cyprus in Cyprus) have produced serious distortions of the outcomes for bank creditors.
I can only hope that with the de-facto establishment of a European FDIC in the form of the SRM, a move that I asked for in the studies of spring and summer below, this degree of operational deficits will become a thing of the past.
November 2013: presentation given at IFO Institute in Munich on Nov 11 ('Muenchener Seminare') on bank creditor participation in Europe.
October 2013: Study launch "Eight Case Studies on Current Bank Restructurings in Europe", a companion piece to the July 2013 financed by the Center for Financial Studies at the University of Frankfurt (Prof. Jan-Pieter Krahnen). The study widens the country angle from 3 (Greece, Spain, Cyprus) to 8 (in addition Germany, France, Denmark, Netherlands, Ireland) and looks into some of the spectacular cases of this crisis, e.g. Anglo Irish and Dexia. For those of you who are curious why your local bank bailout has become so expensive, learn about at the strangely protective behavior of our governments to even junior bond investors in so many cases and ask yourself how serious Europe will really be in changing her deep bailout policies.
Our press release highlights that it is essentially the small jurisdictions, first and foremost the Netherlands and Denmark, who have adopted clear strategies to increase creditor participation. Ireland was kept from acting. In European bank restructuring policy, small is truly beautiful. I see good reason to demand that European bank supervision and resolution authorities should be headed by representatives from smaller countries, those that have proven that they can do it and are committed to do it.
August 2013: Comment in Handelsblatt on the lack of creditor participation in the Greek bank restructuring program, which has driven up fiscal cost for Greece and increased the risk of future additional sovereign bond haircuts (Deutsch). Back on the envelope I estimate that holders of junior bonds in the four big Greek banks (all distributed via the Channel Islands) will be handed out cash at the tune of EUR 2 billion from the Greek sovereign. Note that once the government is invested in shares with large amounts, as in the Greek case, junior bond holders may lean back and wait for par cash payment. And in the case of dated subordinated securities they will receive coupon payments on top.
Addendum to the July 2013 study publication: In February and March 2013 I was retained by a political party in Bundestag to assess various Cyprus bank restructuring options. A paper was finished in April, available in German language here. It is a precursor exercise to the June/July study covering also Greece and Spain.
IMPORTANT NOTICE: pls visit the new blog of my mentor and friend Klaus Engelen, Banking Union Watch. Klaus is the top senior financial journalist of Germany, a long-term contributor to Handelsblatt and co-editor of The International Economy and the Global Risk Regulator. I cannot fathom how much I owe him for his insights and making contacts within the international public finance community.
July 2013: Study on Creditor Participation in Eurozone Bank Restructurings. This effort has been sponsored by the Green Party in Bundestag and European Parliament. A companion piece is financed by the Center of Financial Studies in Frankfurt and will appear shortly. Neither myself nor certainly the CFS have political party affiliations. But it is good to see that there is interest in such exercises in our parliaments, which have to vote on multi-billion Euro support programs. Yet, high political barriers towards transparency in Europe over banking program cost and their incidence still have to be overcome. So this can only be the starting point of more in-depth empirical reviews.
Some media response: article in der Standard and Sueddeutsche Zeitung on the occasion of the publication of the study (German), and a post in FTs Alphaville blog.
Here is also a presentation that I gave at the Peterson Institute and the IMF's Crisis Management Department on the empirical substance of the bank restructuring study in early June. We had a good time esp over at the IMF.
June 2013: those of you who are interested in Spanish mortgage finance and the subsequent banking crisis may be interested in my ad-hoc presentation given at this years International Housing Finance Course at the Wharton School. I will try to do a more in-depth study on the Spanish crisis, the problem as usual is politics pre-empting access to public funding.
Update October 2013: to the Olivier Blanchard's of this world who demand higher inflation rates and decide to ignore their credit implications. Restructuring can't be avoided for another reason: real debt reduction through inflation only works in a predominantly long-term fixed rate capital market environment. This was the situation when the world entered the high-inflation phase of the 1970s. Today, the most vulnerable consumer, corporate and sovereign balance sheets are funded by variable rate lending, with the United States which still enjoys a global borrowing privilege probably being the only exception of relevance. This means that borrowing cost will jump immediately, as investors will try to avoid being taxed through inflation. Where Blanchard therefore ends is not an implicit, but an explicit expropriation strategy as in order to make his proposal work he needs to hold short-term rates low as well. This is realized in corners, e.g. in consumer finance (example refinancing of Euribor loans through the ECB in Spain), but would be rather an innovation in sovereign finance.
FEATURED: my colleague Sebastian Schich of OECD has once again hit home on the subject of implicit guarantees for banking arising not just from too-big-to-fail systemic risk threat but also from the currently seen practices of bank resolution.