Rickards Interview by zerohedge

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   VOLUME 12
     ISSUE 4
 FEBRUARY 26, 2010

                      Threat Finance
                      Capital Markets Risk Complex And Supercritical, Says James Rickards
 Listening In         James G. Rickards is a                                                             doesn’t mince words,
Need For Market       modern Renaissance                                                                 you are right. Read on.
                      man of sorts, a lawyer                                                             KMW
 Reforms, Scale       by training and an old
 Limits Urgent        hand in capital mar-                                                                Your recent FT piece
      PA G E 1        kets. With 35 years on                                                              about Wall Street
                      Wall Street, he has been                                                            having a “Piñata
Guest Perspectives    an internationalist all                                                             Party” at Greece’s
Steven Reynolds       of his career, but now                                                              expense caught my
  Buyer Beware        sees globalization as                                                               eye, but then I did a
   Risk Waiting       one of the key destabi-                                                             little research and
                      lizing forces threaten-                                                             discovered you’d be
     To Spring        ing the financial mar-                                                              fun to talk to about
  Richard Koo         kets. In part, that’s                                                               everything from
 Take Japan’s Cue     because he’s also made                                                              derivatives to the
  Paul Kasriel        himself into an expert                                                              nature of risk. But
Hey Big Spender?      in risk analysis and                                                                first things first.
 Real Issue Isn’t     econophysics, which                                                                 What exactly does
   Deficit, But       the former general                                                                  your firm do? Omnis
  Future Oulays       counsel of Long Term                                                                Inc. doesn’t just
    John Kosar        Capital Management lec-                                                             sound a mite
 Inflation & Fed      tures on at                                                                         Orwellian, it’s based
                      Northwestern’s Kellogg                                                              in McLean, VA, and
                      School, among other                                                                 its website boasts of
Chart Sightings       places. Applying lessons from the realm of                roots in the intelligence community. Just
Dave Rosenberg:       physics to the morass in the capital markets, Jim         what is its “practice in threat finance and
Lacking Confidence    says the Street has been deluding itself about the        market intelligence” that you and a part-
Albert Edwards:       nature of financial risk for a generation or two,         ner head? A cynic might suggest the first
  Japan’s Real        creating a far riskier, and more unstable, market         part of that description is redundant and
Growth Problem        in its scramble for short-term profits. There’s no        the second, an oxymoron —
 Michael Belkin       mystery about the lessons of our mushrooming              But I’m sure you know what Oscar Wilde said
Frontier Markets?     experiences with “fat tail” crashes, in Jim’s view.       about cynics. We have a number of specialties in
 Alan Newman:         The crime is that instead of making the obvious           our firm, but the broadest way to think about
Fund Cash Levels      fixes, the government and the Street combined to          what I do personally is to think about two usual-
                      “double down” after LTCM — and are still doing            ly separate worlds. Take the world of geopolitics
Acute Observations    nothing constructive. If you get the idea that Jim,       and defense and national security and diploma-
 Comic Skews          now senior managing director for market intelli-          cy on the one hand, and then take the world of
                      gence at Omnis, Inc., a scientific consulting firm,       capital markets, commodities, stocks, bonds,

                                                          welling@weeden   FEBRUARY 25, 2010 PAGE 1
                                    derivatives, etc., on the other. It’s really the              structure. But just very recently they have
                                    intersection of those two worlds that we are con-             turned that around and now they’re extending
                                    cerned with. In what ways does political insta-               duration. Well, once you are able to get that
                                    bility or political risk affect markets? Then, con-           information, then you can think about what it
                                    versely, what can we learn from markets that                  says about Chinese intentions and Chinese poli-
 Kathryn M. Welling                 would help in the geopolitical sphere? So threat              cy. Likewise, if countries are thinking of getting
 Editor and Publisher
                                    finance and market intelligence are basically                 out of dollars and getting into euros or gold or
                                    about looking at capital markets and taking                   commodities, you can see those activities as
                                    information out of the capital markets to help                well. The acquisitions made by sovereign
  Published exclusively
                                    policy makers and deci-                                                                 wealth funds can tell us
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Co-President, Global Sales
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                                                                  “As general counsel                                       states. My view is that
                                                                                                                            these things are not
   (800) 843-9333 or
     (203) 861-7670
                                    Are you saying
                                                                 of LTCM, I negotiated                                      just market transac-
                                                                                                                            tions, they take place

      Thomas Orr
                                    geopolitical threats            the bailout which                                       in markets, but they
Managing Director, Research         are somehow linked                                                                      reveal something about
     (800) 843-9333                 to stock fluctuations            averted an even                                        strategic intentions
 tom_orr@weedenco.com               or punts on pork bel-                                                                   and policies of other
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                                    You are being way too                                                                   helpful to the United
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                                    literal. Basically, we         at that point. What                                      States. So that’s one

      Jean M. Galvin
                                    think of the capital
                                    markets as a very rich
                                                                     strikes me now,                                        way that the two worlds
                                                                                                                            we watch come togeth-
Business Manager/Webmaster
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                                    mation, assuming you
                                                                  looking back, is how                                      er.
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        Pat Quill                   to segregate informa-            no lessons were                                        you’re in the market, if
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    Deirdre Sheehan
                                    lot of techniques that       applied. Even though                                       ket maker, an invest-
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                                    buying anything or
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                                                                        in 1998.”                                           prospects for war
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reprint/republication permis-                                                                     And that’s what you’ve been trying to do
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                                    For instance?                                                 for about three years now?
Copyright 2010, K.M. Welling.       A very clear cut example that a lot of people fol-            No, I have worked in the capital markets for 35
       All rights reserved.
                                    low are Chinese activities in the U.S. govern-                years, but in terms of taking this particular
      Charles Powell                ment securities market. We saw this throughout                approach which I have just described as looking
      Page 1 Illustration
                                    2009. They were shortening up their maturities                at the intersection of capital markets and

                                                           welling@weeden   FEBRUARY 25, 2010 PAGE 2
geopolitics, I have
been doing that since

Your company only
dates back to 2004,
doesn’t it?
Well, I was doing some
work on this before I
joined Omnis, which
was launched in 2004.
Our Threat Finance
and Market
Intelligence division is
just one of Omnis’
three divisions.
Another is Research
and Development and
the third is Training
and Education. But our
Financial Threat and
Market Intelligence
unit didn’t really start
operations until early
2007, so it’s only a few
years old. In that
sense, you’re right.
                                                       State Department had embassies in, at the time.
                                                       If I remember correctly, in the late 1970s, the
But being a new kid hasn’t prevented you
                                                       State Department was in about 95 countries
from picking up some blue chip clients —
                                                       and Citibank was in 98 countries.
Correct. Many of our clients are various gov-
ernment directorates. Obviously, we don’t dis-
                                                       Even in those simpler times, Walter
close the clients’ names unless we get permis-
                                                       Wriston’s big global push ended up creat-
sion. But among the ones we are allowed to
                                                       ing all sorts of Latin American debt prob-
mention are the Office of the Secretary of
                                                       lems for Citi, as I recall.
Defense, there’s the Department of the Navy,
                                                       There was certainly a learning curve. At any rate,
the Director of National Intelligence, and some
                                                       after 9-11 there was a lot of outreach by national
other components of the national security com-
                                                       security professionals, looking for various
munity. Then, on the private side, we have
                                                       experts in different fields, whether it was cyber
hedge funds, family offices, investment banks
                                                       security, critical infrastructure, counter-terror-
and high net worth individuals among our
                                                       ism, or in my case, capital markets, and basically
                                                       utilizing a lot of private sector resources to
                                                       address national security issues. That was the
The usual suspects.
                                                       time that I became more involved and we have
                                                       taken it from a little, let’s say, volunteer effort,
                                                       after 9-11 into a full blown business, all essential-
Okay. But you’re a lawyer. What does a
                                                       ly growing out of risk analysis.
lawyer — even one whose bio says he was
the principal negotiator of the LTCM
                                                       Wall Street’s attempts to analyze and man-
bailout — know about the capital markets
                                                       age risk were a key part of what went wrong
and geopolitics?
                                                       and led to the credit bust. That was an obvi-
Actually, it feels like I’ve been in the area forev-
                                                       ous lesson we failed to learn from LTCM.
er. Going back, even prior to law school, I got a
                                                       That’s right. Western capital markets came to
masters degree in international economics.
                                                       the brink of collapse in 1998, when hedge fund
Then, I worked at Citibank when I started my
                                                       Long Term Capital Management, with a trillion
career — and one of the reasons I went there was
                                                       dollar web of counterparty risk at all the major
that they had offices in more countries than the

                                                   welling@weeden   FEBRUARY 25, 2010   PAGE 3
banks and brokers of the time, failed. Then Fed                2009] on the subject of risk management and
Chairman Alan Greenspan and Robert Rubin,                      the problems of the models Wall Street has been
who at that juncture was Treasury Secretary,                   using, and I gave testimony about the risks of
called it the worst financial crisis in 50 years.              financial modeling last September, before the
While the amounts involved and the duration of                 House Science Committee’s subcommittee on
that crisis pale next to what we’ve been going                 investigations.
through since 2007, it certainly didn’t feel
minor at the time.                                             I missed those, somehow, amid all the babble.
                                                               Well, most of the problems with VaR are fairly
You can say that again.                                        well known at this point. We are certainly not
I know, I was there. As general counsel of                     the first ones to point them out.
LTCM, I negotiated the bailout which averted
an even greater disaster at that point. What                   Little things, like being based on faulty
strikes me now, looking back, is how nothing                   assumptions — such as the Efficient Market
was changed; no lessons were applied. Even                     Hypothesis, the random walk and that the
though the lessons were obvious, in 1998.                      bell curve applies to markets, you mean?
LTCM used fatally flawed VaR risk models.                      Exactly. VaR would be a fine methodology but
LTCM used too much leverage. LTCM transact-                    for the fact that all three of those assumptions
ed in unregulated over-the-counter derivatives                 are wrong. Markets are not efficient; no amount
instead of exchange-traded derivatives. So risk                of theory tweaking will make them so. Future
models needed to be changed, or abandoned.                     prices are not independent of the past; not a
Leverage had to be slashed. Derivatives had to                 random walk. Risk is not normally distributed.
be traded on exchanges or cleared through                      As the saying goes, “Besides that, Mrs. Lincoln,
clearinghouses. Regulatory oversight needed to                 how was the play?” But what we’re trying to do
be ramped up.                                                  is go beyond that — not just point out the flaws
                                                               in things like value at risk, which again are pret-
But none of that happened.                                     ty well known — but to suggest alternatives.
Even worse, the government did just the oppo-                  There are other analytic methods and other
site. Glass-Steagall was repealed in 1999, so                  techniques that actually do give you an ability to
that banks could become hedge funds. The                       understand risk in much better ways, but most
Commodities Futures Modernization Act of                       people who have criticized VaR really haven’t
2000 permitted the creation of more unregulat-                 taken the next step and proposed alternatives.
ed derivatives. The Basle II Accords and                       So one of the common defenses you hear from
changes in SEC regulations in 2004 permitted                   people continuing to use VaR is something like,
more leverage. The U.S., in effect, stared near-               “Yes, we know it has flaws, but we have to keep
catastrophe in the eye, with LTCM, and decided                 using it until something better comes along.”
to double-down.                                                Now, I don’t necessarily agree with that. It’s
                                                               like continuing to drive a car with no gas in the
The government didn’t exactly decide to                        tank just because you can’t find a gas station.
that on its own, out of the blue. Wall                         You’re not going to get very far.
Street spent a lot of money lobbying to
make it happen.                                                A more timely analogy might be a Toyota
Certainly the power of the lobbyists and special               without accelerator repairs —
interests can’t be discounted. Greenspan                       Maybe. The thing is, we actually do have alter-
deserves a lot of the “credit” for pushing his                 native methods for modeling financial risk—
belief that the markets could self-regulate. In
fairness, he wasn’t alone in that belief. But I                Are they any better, or just different?
don’t think any of this could have happened in                 Better. They are built around a different mathe-
the aftermath of the 1998 crisis, without the                  matical construct, which is very well-known,
comfort provided by Wall Street’s quantitative                 called a “power curve” or a “power law.”
risk models, most notably, VaR, which cast a                   Basically, it’s a different kind of degree distribu-
hypnotic spell, as not-well-understood science                 tion. Any degree distribution is simply a plot-
often does, and assured bankers, investors and                 ting of the frequency of an event relative to the
regulators that all was well, even as the ashes of             severity of the event. The mistaken belief that
LTCM still smoldered around them. Just about                   market risk is “normally distributed” is actually
a year ago, I had a long piece published in the                another corollary to the EMH, which expects
Risk Management Association Journal [March,                    future price movements to be random and so

                      welling@weeden   FEBRUARY 25, 2010   PAGE 4
says that their degree distribution will also be      natural and man-made systems, from power
random, like a coin toss or roll of the dice. This    outages to earthquakes. And power curve analy-
random or “normal” degree distribution is             sis isn’t even new. Economist Vilfredo Pareto
most frequently represented as a bell curve in        observed in 1906 that wealth distributions in
which the large majority of outcomes are              every society conform to a power curve; in
bunched in region of low severity, with progres-      effect, there’s one Bill Gates for every 100 mil-
sively fewer outcomes shown in the high severi-       lion average Americans. Benoit Mandelbrot pio-
ty region. Because the curve tails off steeply,       neered the empirical analysis in the 1960s that
highly extreme events are so rare as to be almost     showed market prices move in power curve pat-
impossible. In other words, on a bell curve, the      terns.
vast majority of events happen in a fairly narrow
band of two or three standard deviations from a       But bell curve or power curve, doesn’t that
normal activity and are equally distributed on        matter mostly to academics?
both sides, and so when you get to extreme            That’s just it. The difference is not merely acad-
events, which should be defined as five or six or     emic. Gaussian, or bell curve, distributions and
more standard deviations, those are so rare as        power law distributions describe two entirely
to be practically if not literally impossible.        different phenomena: Bell curve distributions
Therefore, people assuming a normal distribu-         in this context describe continuous phenomena
tion of risk in the markets tend to discount the      and power laws describe discontinuous but regu-
probability of extreme events happening.              lar phenomena. Which one applies has enormous
                                                      implications when what you’re trying to model is
Despite evidence they happen with disturb-            financial risk. Power laws accurately describe a
ing frequency, resulting in enormous losses.          class of phenomena known as nonlinear dynami-
Exactly. Experience tells us that extreme events      cal systems that exhibit scale invariance —
do happen all the time, and in fact the normal dis-
tribution of market risk has been known to be         Could you state that in plain English?
false at least since the early 1960s, when pub-       In other words, orderly patterns are repeated at
lished studies of time series of prices showed        all scales. What is often taken for randomness at
them not distributed in the shape of a bell curve     a given scale actually produces order (albeit
but in the shape of a power curve — studies that      chaotic, or unpredictably deterministic) across
have been replicated many times since.                scales. Earthquakes, as I mentioned, are an
                                                      example of such systems in nature. Consider
Can you explain what difference that                  the Richter scale’s inverse proportionality of
makes to someone who isn’t a quant?                   the severity and frequency of earthquakes, with
A power curve, one of the most common degree          minor events being common and events rated
distributions in nature, which accurately             seven or higher being quite rare. That’s a power
describes many phenomena, has fewer low               law distribution.
impact events than the bell curve but has far
more high impact events. When graphed on a            Well then how have several generations of
double logarithmic scale, the power law               academics and financial practitioners man-
describing financial market risk is a straight        aged to get it so wrong, swearing allegiance
line sloping downward from left to right. A           to the notions of efficient markets and bell
power curve says that events of any size can          curve risks for more than 50 years?
happen and that extreme events happen more            Now you’re getting into realms of philosophy
frequently than the bell curve suggests. This         and cognitive neuroscience, or at least behav-
corresponds to the market behavior we have            ioral economics. I’ll just point out that the his-
seen in such extreme events as the crash of           tory of science is filled with false paradigms that
1987, LTCM’s collapse, the dot.com bubble’s           gained followers to the detriment of better sci-
bursting in 2000, the housing collapse in 2007        ence. People really did believe the sun revolved
— you get the idea. Statistically, these events       around the earth for 2,000 years and mathe-
should happen once every 1,000 years or so in a       maticians had the equations to prove it. The
bell curve distribution — but are expected much       sociologist, Robert K. Merton, called this the
more frequently in a power curve distribution.        Matthew Effect from a New Testament verse
In short, a power curve describes market reali-       that says, “For to those who have, more will be
ty, while a bell curve does not. What’s more,         given...” In effect, once an intellectual concept
power curves are well-understood by scientists        attracts a critical mass of supporters, it
because they apply to extreme events in many          becomes entrenched, while other concepts are

                                                  welling@weeden   FEBRUARY 25, 2010   PAGE 5
crowded out of the marketplace of ideas.                        Naturally enough —
                                                                All too true. But short-sighted. Suppose geolo-
Still, Wall Street, perhaps more than any                       gists abandoned the Richter Scale, a classic
other economic ecosystem, prizes what                           power curve, as useless, just because it has low
works. What generates profits. And there                        predictive power? We know that 8.0 earth-
was loads of evidence, you point out, that                      quakes are possible and we build cities accord-
the bell curve failed at critical junctures.                    ingly, even if we cannot know when the big one
You do have to wonder. I don’t know whether it                  will strike. Likewise, we can use power curve
was denial or inertia or because people got so                  analysis to make our financial system more
wedded to the elegance of the mathematics                       robust even if we cannot predict financial earth-
they’d done that they hated to leave all that                   quakes. And one of its lessons is that as you
work behind. After all, the Black-Scholes                       increase the scale of the system, the risk of a
options formula is based on bell curve-type                     mega-earthquake goes up exponentially. If you
price movements. The entire derivatives market                  increase the value of derivatives by a factor of
is based on variations of Black-Scholes. So what                10, you may be increasing risk by a factor of
people were doing when presented with the evi-                  10,000 without even knowing it. Unfortunately,
dence was saying, “Yes, there are flaws in effi-                this is not something that Wall Street or
cient markets, there are flaws in developmental                 Washington currently comprehends. That’s why I
distribution, but we’re going to use it anyway                  urged in my Congressional testimony and have
and try to fix the flaws.” In other words, Wall                 said repeatedly in numerous other forums that we
Street decided that the wrong map is better                     should abandon the bell curve once and for all
than no map at all — as long as the math is ele-                and accelerate empirical research into the proper
gant. And that led to calling extreme events a                  risk metrics of event distributions. The bottom
sort of special case, a “fat tail,” which just                  line is that the power curve is a degree distribu-
meant they were happening more frequently                       tion that works. It’s ubiquitous in nature, we
than a bell curve would indicate. So they would                 see it in everything from solar-flares to forest
model risk to show a normal distribution most                   fires to internet backbone failures, to power
of the time, but fat tail events some of the time,              grid failures to the time series of prices in capi-
and then create a new curve that was faded a lit-               tal and commodities markets. Even if the power
tle bit to include these fat tails. Then the Street             curve’s predictive value is low, there is value in
employed a lot of rocket scientists to stress-test              knowing the limits of our knowledge.
for fat tail events based on historical occur-                  Understanding the way risk metastasizes with
rences, such as the ‘87 crash. I call that pinning              scale might be lesson enough. It would offer a
a fat tail on the bell curve and the problem with               proper dose of humility to those trying to super-
it —                                                            size banks and regulators. And once you accept
                                                                the idea of financial risk following the power law
Is that it made investors into donkeys—                         distribution, you can start to draw very different
Yes, exactly. But another reason the Street was                 conclusions about how capital markets actually
loath to throw out the whole notion of normally                 operate. And that’s what we have done. We
distributed risk, and tried to salvage it instead               have embraced that model, we have done addi-
by putting a fat tail on it, is that the alternative,           tional research, we have published papers. And
a power curve, just didn’t look that palatable to               this has given us actually a very good ability to
most practitioners and so comparatively little                  understand markets and stay ahead of the
work has been done in applying power curves to                  curve.
financial markets.
                                                                How ironic is it that all of Wall Street’s
Why is that, considering the vast                               “rocket science” innovations of the last
resources Wall Street pours into every                          20-30 years — which had so much to do
conceivable way of getting an edge?                             with, if not exactly causing the mess we’re
Don’t get me wrong, some excellent research                     in, exacerbating it by dramatically
has been done in the realm of power curves and                  increasing its scale and complexity — were
the capital markets. The thing is, power curves                 based on such deeply flawed theories?
don’t have a lot of predictive value. Since most                Yes. I’ve always thought the problem was that,
financial researchers approach the field precisely              although Wall Street was very active in hiring a
to gain a trading edge, once they discover power                lot of Ph.D.s — astrophysicists, applied mathe-
curves aren’t much use there, they move on.                     maticians and others with very good quantita-
                                                                tive theoretical skills, it didn’t let them use

                       welling@weeden   FEBRUARY 25, 2010   PAGE 6
their heads. What happened was that their Wall        when it’s sitting harmlessly on your desk, and
Street managers said, “Look, here’s how the           the super-critical state, which is when it turns
financial world works and we want you to model        into a nuclear weapon.
it and code it and develop it and write these
equations and programs.” And so they did. But         And supercriticality has relevance in
Wall Street — and all of us — would have been         finance, too, you’re suggesting?
much better off, had they gone to those rocket        Yes, applied to capital markets, the same thing
scientists and asked, “How does the world actu-       is true. In markets, you have numerous hetero-
ally work?” In other words, instead of telling        geneous, autonomous, interdependent agents,
them what to do, they should have listened.           each of whom has a critical threshold with
Because the idea of power law distributions, in       regard to preference for dollars, euros, gold,
particular, comes from physics. It’s the physi-       stocks, bonds, etc. Are those agents and those
cists who have identified the distribution and        critical threshold preferences arrayed in a sta-
done the empirical work on it in a lot of fields.     ble sub-critical or in an unstable super-critical
So Wall Street risk managers would have been          state? It’s through that kind of thought process
better off listening to the physicists instead of     that we take the physics concepts, apply them
telling them what to do.                              to capital markets, and get a better understand-
                                                      ing of risk.
If they could understand them. I noticed in
your Omnis bio that you’ve delivered papers           But it’s not the sort of model that you can
on something you call “econophysics.”                 feed lots of data into and expect it to tell
Yes. Econophysics is basically understanding          you what the markets are going to do?
the economy using tools derived from physics.         Well no, because you’ll never have that much
So it’s exactly what we’re talking about. The         data. And even if you did, the power needed to
field of nonlinear dynamical systems — which          crunch it would exceed all the computing power
encompasses those described by a power curve          in the world. Let me give you another example.
— has recently been enriched by the concept of        Let’s say you have a movie theater and five peo-
self-organized criticality.                           ple suddenly jump out of their seats and run out
                                                      of the theater. Well, what is everyone else going
Go easy on me, please. The only physics               to do? A few Nervous Nellies might run out too,
course I took in college was something                but most are likely to decide those five are wacky
called “Physics for Poets.”                           and sit back to enjoy the movie. But if 50 people
The idea is that actions propagate throughout         ran out, or 100, or 200, there’d come a time when
systems in a critical chain reaction. In the criti-   they’d start a stampede. So the difference
cal state, the probability that an action will        between acting as an autonomous individual and
propagate is roughly balanced by the probability      as part of a herd, that point where behavior
that the original action will dissipate. In the       changes, is called the critical threshold.
subcritical state, the probability of extensive
effects from the initial action is low. But in the    So it’s what Malcolm Gladwell calls “the
supercritical state, a single minor action can        tipping point.”
lead to a catastrophic collapse. A concrete           Correct, tipping point is the popular jargon.
example may help explain this. Let’s just say         But my point is that different people in the the-
you have a 40-pound cube of uranium sitting in        ater have different tipping points. So let’s say
front of you. It would actually be relatively         that five people run out of a theater but the next
harmless. You’d have to eat it for it to make you     lowest tipping point among the audience is 10.
sick. But if you took the same 40 pounds of ura-      In that world, if five people run out, nothing
nium and shaved part of it into a ball about the      else happens. That’s an example where an ini-
size of a softball and made the rest of it into a     tial act dies out.
rod about the size of a baseball bat and then put     But then let’s assume instead that when those
them into a tube and fired them together at           first five run out, there are 10 other people in
high speed and at the right angle, you would          the audience with a tipping point of five and a
create a nuclear explosion. My point is that          hundred people with a tipping point of 12 and
there is more to understanding those dynamics         then 300 people with a tipping point of 50. If
than just having a quantity of uranium. How it        that’s your system, just the five people run out
is shaped, how it interacts, how is it fired, also    will start a chain reaction as tipping points are
go into determining the difference between            hit that will empty the theater. So the second
what’s called the sub-critical state, which is        example shows how embedded preferences may

                                                 welling@weeden   FEBRUARY 25, 2010   PAGE 7
be potentially super-critical in terms of all the               alization. The Italian bourse used to be com-
interactions. Now, instead of a couple of hun-                  pletely isolated from every other stock market.
dred people in a theater, imagine several hun-                  It was a local stock market, run in Milan, domi-
dred million people around the world buying                     nated by local firms and didn’t have much inter-
and selling stocks, bonds, commodities, deriva-                 action with other exchanges. That’s no longer
tives all day long. They all have different prefer-             true, of course, because of globalization and the
ences. You would never be able to get that data.                consolidation of exchanges. We’re to the point
And even if you could, the interactions and the                 that the New York Stock Exchange and
permutations could be so great they could                       Euronext are one big exchange. Finally, adapt-
never be modeled precisely. So one of the                       ability is just a function of— if I’m not locked
things you learn from complexity theory like                    into one country or one system, I can change
this is a lot of humility. There are some things                my behavior based on what I see everyone else
you can’t know because the computational com-                   is doing. What I’m saying is that objectively —
plexity of the problem exceeds our ability to                   not just theoretically but objectively – all those
compute it.                                                     things have been dialed up in the markets.
                                                                What that tells you is that the system is more
Sure. It’s a meteorologist’s standard excuse.                   vulnerable and more risky than it ever has been.
But that doesn’t mean this new paradigm that                    Meanwhile, it is operating on a larger scale than
sees the financial system as a self-organized,                  it ever has —
scale-invariant, nonlinear dynamical system in a
critical state is worthless. What it means is that              And you’re suggesting this is a case where
you can understand it theoretically and you can                 bigger isn’t better?
look for metrics, indications, and warnings that                Yes. While extreme events occur with much
are valuable tools, even if you can’t model it right            greater than normal frequency in nonlinear
down to the last individual actor. You can, for                 critical state systems, these events are never-
instance, analyze the markets in terms of the four              theless limited by the scale of the system itself.
operative aspects of a complex network.                         So if the financial system is a self-organized
                                                                critical system, as both empirical evidence and
Which are?                                                      deductive logic strongly suggest, the single
One is diversity, because your preferences are                  most important question from a risk manage-
going to be different than mine and we’ll both                  ment perspective is: What is the scale of the sys-
differ from the next guy. There also is connect-                tem? Simply put, the larger the scale of the sys-
edness, which is that people have ways of seeing                tem, the greater the potential collapse with
what other people are doing and understanding                   macroeconomic and other real world effects.
what other people are doing. Then there’s
interdependence — what I do affects what you                    So much for the conventional wisdom that
do. It’s not just that we’re connected and seeing               greater participation and diversification
each other, but also that my preferences are                    would take risk out of the system —
going to depend on yours, etc. Finally, there’s                 Right, the result of all this interconnectedness
adaptability. I may change my behavior based                    has been we have scaled up the system. So now
on what I see. So one thing we can do is dial up                when it fails, it fails catastrophically on a much
or dial down those four operative aspects and                   greater scale than we have ever seen before.
draw inferences about how risky or critical the                 There’s no normalized scale similar to the
system actually is.                                             Richter Scale for measuring the size of markets
                                                                or the size of disruptive events within them. But
And that tells you?                                             a few statistical estimates from the McKinsey
Well, what have we seen in the markets for the                  Global Institute make my point: The ratio of
last 20 years, really? More diversity, with the                 world financial assets to world GDP grew from
Chinese and Indians — and I’m not talking                       100% in 1980 to 200% in 1993 to 316% in 2005.
about ethnic or national diversity alone. I’m                   Over the same period, the absolute level of global
talking about the diversity of preferences and                  financial assets increased from $12 trillion to
opinions, partly as a result of globalization. We               $140 trillion. The drivers of this exponential
have more connectedness, because of the inter-                  increase in scale are globalization, derivative
net, email, and the exchanges and price ser-                    products, and leverage. Globalization, we’ve
vices, and all the telecommunications facilities                talked about. Derivatives have grown even faster
that come into being. We also have more inter-                  than the underlying financial assets, owing to
dependence, which is another function of glob-                  improved technology in their structuring, pric-

                       welling@weeden   FEBRUARY 25, 2010   PAGE 8
ing, and trading — and to the fact that the size of    Well, the good news is that once we understand
the derivatives market is not limited by the physi-    the structure and vulnerability of the financial
cal supply of any stock or commodity. It can theo-     system in this way, some solutions and policy rec-
retically achieve any size, since the underlying       ommendations become obvious.
instrument is notional rather than actual. Thus,
the total notional value of all swaps increased        Do tell.
from $106 trillion to $531 trillion between 2002       They fall into three categories: limiting scale, con-
and 2006. The notional value of equity deriva-         trolling cascades and securing informational
tives increased from $2.5 trillion to $11.9 trillion   advantage. A simple example demonstrates the
over the same period while the notional value of       importance of limiting scale: If the U.S. power grid
credit default swaps increased from $2.2 trillion      east of the Mississippi River were at no point con-
to $54.6 trillion.                                     nected to the power grid west of the Mississippi, a
                                                       nationwide power failure would be an extremely
Those numbers are actually incomprehen-                low probability event. Either the “east system” or
sible. And leverage is the third key                   the “west system” could fail catastrophically in a
enabler?                                               cascading manner. But both systems could not fail
It absolutely supports the massive scaling of          simultaneously except for entirely independent
financial markets; margin debt of U.S. brokerage       reasons because there would be no nodes in com-
firms more than doubled from $134.6 billion to         mon to facilitate propagation across systems. In a
$293.2 billion from 2002 to 2007, while the            financial context, what this tells me is that govern-
amount of total assets per dollar of equity at major   ments should consider preventing mergers that
U.S. brokerage firms increased from approxi-           lead to globalized stock and bond exchanges and
mately $20 to $26 in the same period. In addi-         universal banks.
tion, leveraged investors invest in other entities
which use leverage to make still further invest-       You’d roll back the clock on globalization?
ments. This type of layered leverage is impossible     Yes. But I wouldn’t state it as a pejorative. The first
to unwind in a panic. What I am driving at is that     order efficiencies of such mergers are far out-
it’s indisputable that the markets are larger and      weighed by the risks of large-scale failure, especial-
more complex than ever. What this means, in a          ly if those risks are not properly understood and
dynamically complex critical system, is that the       taken into account. Maybe another example will
size of the maximum potential catastrophe is           drive home the relationship between the scale of a
exponentially greater than ever. What’s more,          system and the extent of the greatest catastrophes
because systems described by a power curve, like       possible in that system, which makes limiting scale
the capital markets, allow events of all sizes and     so crucial. Let’s say I have a ship, with a hold of a
because such events can occur at any time — espe-      certain capacity. If I punch a hole in it, it fills
cially when the system is supercritical — I con-       with water and sinks. But now imagine the same
clude that progressively greater financial cata-       vessel but with the addition of two watertight
strophes, like we’ve been experiencing recently,       bulkheads, so its hold is now divided into three
should be expected frequently.                         watertight sections. If I punch the same hole in
                                                       the ship, the same size hole, the same place,
And you have no doubt about it?                        this time only one compartment fills up with
It’s inescapable. The worst outcomes in a dynami-      water and the vessel doesn’t sink; it floats.
cally complex critical state system are not limited    So what is the impact of removing the bulk-
by historical experience. They’re only limited by      heads? Well, I increase the area at risk by a fac-
the scale of the system itself. The financial crisis   tor of three. But I increase the risk infinitely
which began in July 2007 has lasted longer,            because I go from a vessel that doesn’t sink to a
caused greater losses and been more widespread         vessel that’s guaranteed to sink. So I have
both geographically and sectorally than most ana-      tripled the size of my system but I have expo-
lysts predicted or can explain precisely because       nentially increased my risk.
the vastly greater scale of the financial system can   Now, apply the same thing to capital markets.
produce an exponentially greater catastrophe           When we integrate exchanges, erase borders,
than has ever occurred before. This is why the         come up with global players and global posi-
past is not a guide and why the current crisis may     tions and global strategies on a massive scale,
be expected to produce results as severe as the        we have increased the interconnectedness in a
Great Depression of 1929-1941.                         way that’s going to lead to greater and greater
                                                       catastrophes, which is exactly what we’re see-
You’re just full of good cheer.                        ing. Because people are very good at estimating

                                                   welling@weeden   FEBRUARY 25, 2010 PAGE 9
the first order efficiencies, but they seem to be               temporarily.
blind to the second order costs.                                A clearinghouse would also provide informa-
                                                                tional transparency that would allow regulators
You’re saying the game has changed into a                       to facilitate the failure of financial institutions
3-D chess match and we’re still playing                         without producing contagion and systemic risk.
checkers?                                                       Such “creative destruction” is another neces-
Exactly. Which points to the next thing we have                 sary step on the road to financial recovery.
to do, which is control cascades. Let me use
another example to explain what I am getting                    The banks hate the clearinghouse propos-
at. Suppose your town is full of stop signs that                al, for obvious reasons. But they insist it
slow you down on your drive to work every                       won’t work because so many derivatives
morning, but that in the middle of the night                    are bespoke contracts.
someone steals all of them. The next morning,                   The technical objections to clearinghouse
you’d be driving to work thinking, “Hey, this is                implementation based on the non-uniformity of
great. I’m going faster; this is highly efficient.”             contracts can be overcome easily through con-
All would be wonderful — until somebody goes                    sensual contractual modification with price
through an intersection, hits a school bus, and                 adjustments upon joining the clearinghouse —
kills a bunch of kids. That’s where the second                  enforced by the understanding that those who
order costs come in, and you see that the effi-                 refuse to join will be outside the safety net. Only
ciencies of removing the stop signs are out-                    by eliminating zombie institutions and creating
weighed by the costs of accidents. Which is why                 breathing room for healthy institutions with
we have stop signs. Applied to financial mar-                   sound balance sheets can the financial sector
kets, everyone focuses on the efficiencies of                   hope to attract sufficient private capital to
larger scale markets. But they ignore the costs                 replace government capital and thus re-start
of the car crashes happening with more and                      the credit creation process needed to produce
more frequency.                                                 sound economic growth.

So you’re arguing for increased regulation?                     Are there other regulatory changes you
Yes, to control cascades of failure, which is, in               advocate?
part, a matter of circuit breakers and pre-                     I certainly would favor the Volcker Rule and I
rehearsed crisis management so that nascent                     would favor bringing back something like
collapses do not spin into full systemic catastro-              Glass-Steagall. And I’d favor imposing stricter
phes before regulators have the opportunity to                  capital ratios on banks and brokers. I’m not
prevent the spread. The combination of diffuse                  alone. If you saw last Tuesday’s New York Times
credit and layered leverage means it is not feasi-              there was a story headlined, “Elders of Wall
ble to assemble all of the affected parties in a                Street Favor More Regulation, in which Louis
single room to discuss solutions like in the old                Uchitelle interviewed people like John Reed,
days.                                                           Paul Volcker, William Donaldson, George
                                                                Soros, Nicholas Brady and Jack Bogle, all of
What sort of circuit breakers are you talk-                     whom said that restoring some version of Glass-
ing about?                                                      Steagall would be a good thing.
A significant one, which has been discussed for
over a decade but which has still not been fully                Personally, I’d go further. Too big to fail is too
implemented, is a clearinghouse for all over-                   big to exist. They should be broken up. They
the-counter derivatives. Experience with clear-                 are manifestly too big to be managed well.
inghouses and netting systems such as the                       That’s right. People in Wall Street, their lobby-
Government Securities Clearing Corporation                      ists and patrons in Congress, try to say that
shows that gross risk can be reduced 90% or                     Volcker Rule won’t work. That’s nonsense. We
more when converted to net risk through the                     had the Volcker Rule from 1934 to 1999. It
intermediation of a clearinghouse. Bearing in                   worked fine for 65 years. And I remember how
mind that a decrease in scale produces an expo-                 things were in the late 1990s in Wall Street,
nential decrease in risk in a nonlinear system,                 around 1998, ’99 and 2000, when Sandy Weill
the kind of risk reduction that arises in a clear-              and John Reed and Phil Gramm were pushing
inghouse could be the single most important                     for the repeal of Glass-Steagall. There was more
step in the direction of stabilizing the financial              than a bit of arrogance in the air. There was an
system today; much more powerful than bail                      attitude that somehow the people in the 1930s
outs which do not reduce risk but merely bury it                must have been dopes; didn’t know what they

                      welling@weeden   FEBRUARY 25, 2010   PAGE 10
were doing. Or that they overreacted, so the law      Commission emerging.
was inefficient and a thing of the past. Well,        Well, that’s a very good point. We do have this
what people forget is that in the 1930s they had      Financial Crisis Inquiry Commission, the
lived through something very similar to what          FCIC. Phil Angelides is the Chairman of it and
we’re living through now. They had had a boom         you have Keith Hennessey, Brooksley Born and
in the ’20s. They had a severe market crash in        seven other individuals on it. They’re doing the
1929. Then they had the Great Depression,             best they can, but I don’t know if they’re really
which lasted until 1939, but the most acute           going to be as tough as the Pecora Commission
phase of that was in 1930, 1931, and 1932.            was; whether they’re really willing to hold peo-
So by the time you got to 1933 and ’34, when          ple accountable — including the Congress.
Glass-Steagall and the Securities Acts were
passed, people had been traumatized. Those            There’s plenty of blame to go around. But
laws were their solutions to what they had just       as entertaining as public floggings can be,
lived through. How could we be so casual about        isn’t it more important to put the right
discarding them?                                      fixes into the system?
                                                      I agree there’s a lot of blame to go around.
Good question —                                       You’re certainly right about that. But the prob-
But sure enough, we repealed the law and then         lem analytically is that if you say that everyone’s
went through 10 years that kind of looked like        responsible it’s like saying no one’s responsible.
the 1920s, and then we crashed in a way that          It’s like oh, Wall Street was greedy and short-
looks like the Great Depression. We have              sighted and partly corrupt, and there was too
repeated all the same mistakes — and the basic        much cronyism in Fannie Mae and Freddie Mac
causes of our troubles were the same, too.            and not enough accountability, and the
                                                      Congress was too busy pleasing constituents
Too much credit, you mean?                            and promoting housing finance—
Yes. What happened in the 1920s that was so
horrible? Well, banks originated loans — mostly       Not to mention that Congress was bought
in the form of corporate bonds and sovereign          and paid for.
credits back then — which they then packaged          It was all bought and paid for and the rating
up and sold to their customers. They didn’t           agencies were asleep. That’s all true. But then
care if the loans were any good, because they         what do we do, just throw up our hands? Are we
crammed them down their customers’ throats.           unwilling to untangle that mess?
Because of that abuse, in 1934, the Congress
said “Look, you can be a commercial bank and          How do you suggest going about it?
you can take deposits and make loans. Or, you         Let’s liquidate Fannie Mae and Freddie Mac
can be a securities underwriter, and that’s fine.     once and for all and get back to a private hous-
You cannot be both.”                                  ing market. Let’s allow other rating agencies to
But in 1999, we repealed Glass-Steagall; let          come in and compete with S&P and Moody’s
everybody into everyone else’s business, which,       and let’s eliminate the conflict of interest inher-
by the way, is exactly like removing the water-       ent in the issuers of securities paying fees for
tight bulkheads in my boat analogy. So what           ratings. Let’s break up the big banks and let
happened? They originated a bunch of garbage          them choose whether they want to be commer-
loans and they crammed them down the cus-             cial banks or investment banks, but not both,
tomers’ throats — except this time the customers      etc. Those are all hard choices, but we have
are worldwide. European banks and pension             good reasons to believe that they will work. Yet
funds and U.S. pension funds and hedge funds.         I don’t see any of those solutions being serious-
There’s the exact same conflict of interest and the   ly pursued. Sometimes lip service is paid to the
exact same behavior with the exact same result,       need to do something, but no one is doing any-
except that it all collapsed on a larger scale with   thing.
even worse consequences.
So who are the dopes here? The Congress of the        Don’t forget doing something to break the
1930s or the Congress of 1999? I would say that       stranglehold of special interests on mem-
we once again failed to learn the lessons of the      bers of Congress.
past, now have repeated the mistakes and are          Right. But what concerns me most right now is
again having to suffer through the consequences.      that nothing has changed. If anything, there is
                                                      greater concentration in Wall Street and the
With no obvious successors to the Pecora              only thing that is different is that the Fed has

                                                 welling@weeden   FEBRUARY 25, 2010   PAGE 11
printed so much money and the Treasury has                      dropped through the floor. It’s kind of a scary
spent so much money that they have papered                      thing when you print this much money and
over the problem temporarily. They also helped                  can’t get inflation. So one answer is just to keep
paper things over by changing the accounting                    printing, and we’ll get inflation eventually. But
rules. But the toxic assets are still there. The                my view is that the market is dynamically unsta-
market has not cleared. Prices have not hit bot-                ble. Going back to my example with the urani-
tom. Balance sheets are not cleaned up, and                     um, there will come a time when you flip from
lending has not begun. There is no demand for                   a subcritical state in which everyone just
private credit and the consumer is flat on his                  accepts the dollars to a tipping point where peo-
back. So while we may have temporarily halted                   ple are repulsed by the dollar and get out of it as
the slide, we haven’t done anything to solve our                fast as they can and into gold or some other
problems, which means it’s just a matter of time                store of value. That’s why I’d say the better
before one of two things happen: Either the                     alternative would be for the markets to clear at
slide resumes and we finally get to the market                  the bottom we never had last year and for the
bottom that we never hit in 2009, or they keep                  toxic assets to be written off. We should just let
printing money to paper it over, eventually                     things crash and deflate to the point where all
destroying the dollar and undermining the                       this capital that has been misallocated has been
entire economy. Those are the choices, but                      destroyed.
everyone is just kicking the can down the road
right now.                                                      And another Great Depression wouldn’t
                                                                take down the system?
That’s pretty blunt.                                            The markets have to clear. Right now, nobody is
Well, I think it’s true. I mean, what the Fed                   selling anything much. AIG is holding onto
wants is the one thing they’re not going to get:                $500 billion of credit derivatives. Citibank and
Mild inflation. They’re desperately trying to get               JP Morgan and everyone else are holding on.
some inflation going because they’re scared to                  Bank of America is holding onto the mortgage
death of deflation. All of their quantitative eas-              portfolios and private equity funds are holding
ing and special programs with the Treasury and                  on to their stocks, and other funds are holding
the fiscal stimulus are designed to weaken the                  on to the commercial real estate. Nobody’s sell-
dollar. They’re basically trying to scare the mar-              ing anything. People are holding on to their
kets into spending money. But right now, all                    homes. Markets are still essentially frozen,
Americans want to do, naturally, is save money,                 which means that now it’s a waiting game
de-lever, pay down debt. All very sensible things               between the Fed’s efforts to stimulate inflation,
to do on an individual basis. But when you do                   which could get things going again, and the jug-
that, in a world where consumption is 70% of                    gernaut of deflation, which is still there, though
GDP, your GDP is going to collapse. That is                     it has been papered over. As I said before, that’s
reflected in the velocity of money. The whole                   not price stability; that’s a very unstable ten-
notion that you can dial up nominal GDP by                      sion. It’s like an arm-wrestling contest between
increasing the money supply rests on another                    evenly matched opponents. When it starts,
false assumption, which is that velocity is fairly              nothing seems to happen for a long time. Yet
constant. Now, from 1950 to 1980, it actually                   enormous stress is building up. Eventually, one
was fairly constant.                                            opponent collapses and the other guy wins, so
                                                                don’t mistake no action for nothing going on.
But no one who has lived through the last                       So what I see, when I look at PPI and CPI,
couple of years can still believe velocity is                   which are pretty close to zero, isn’t price stabili-
a constant.                                                     ty. What I see is something like 5% to 7% defla-
Well, they can’t say it with a straight face today              tion being countered by something like 5% to
but, it was true for 30 years. The problem is that              7% inflation. They’re netting out to about zero
the whole monetarist project ignores velocity                   but, in fact, we have an enormous force for
and assumes that you can control everything                     deflation, which we see in residential and com-
through the money supply, including nominal                     mercial real estate, and we have enormous force
GDP. The theory is if you dial up the money                     for inflation, which we see in places like the
supply to get nominal GDP up to 4% or 5%,                       Chinese stock market, gold, and other asset
when real GDP is capped at around 3%, you’re                    bubbles. I don’t know which way it’s going to
going to get two or three points of inflation.                  tip, but I know that when it tips, it’s going to go
And right now, the Fed would like that. But                     to one extreme or the other very quickly. And
they’re not succeeding because velocity has                     we might even get both; we might get a bout of

                      welling@weeden   FEBRUARY 25, 2010   PAGE 12
hyperinflation followed by deflation; that’s            other) bonds and pushing out the spread between
what happened in Weimar Germany.                        them and the benchmark. That brings step two,
                                                        which is to call for more margin from the pension
Let’s turn to Greece’s woes. Your FT piece              funds, because the price has moved in favor of the
basically said the country was being set upon           buyer. That margin money gets put into the hedge
by the Street like a piñata at a kid’s party.           funds, which enjoy the cash and paper profits -- and
And implied that credit default swaps make it           20% performance fees — particularly if this hap-
all too easy to game the markets—                       pens around year end. This dynamic of pushing
There are certainly people who disagree, but I          out spreads and calling in margin is the same one
wouldn’t say I’ve gotten hate mail. There are           that took down LTCM in 1998 and AIG in 2008 —
people who say that it’s Greece’s fault; don’t          and is happening again, in Greece.
blame the dealers for something Greece did
wrong; CDS prices are reflective of underlying          Resulting in another bailout?
realities, etc. In fact, that’s what I would call the   Eventually, and then the money flow will be
conventional wisdom on this. But the idea that          reversed. But in the meantime, pension funds earn
CDS dealers just sit there and wait for the             premium, banks earn spreads, hedge funds earn
phone to ring — that someone calls up and says,         fees and everyone’s a winner - except the poor
“Hey, I’m really interested in buying one of            investors in the hedge funds, who pay fat fees on
those credit default swaps, can you make me a           fleeting performance, and the unfortunate inhabi-
market? — is beyond naive.                              tants of the piñata. But all this has very little to do
                                                        with Greece’s fiscal fix. It’s really not much more
Credit default swaps belong to that cate-               than a floating craps game in an alley off Wall
gory of Wall Street product that is sold,               Street.
not bought?
Exactly. And what I wrote is that when you look         But a very lucrative one for the banks.
behind CDS prices, you don’t find an objective          True, but it looks like Goldman is probably fac-
measure of public finances in Greece (which are         ing some materially severe reaction from gov-
a mess, no doubt). What you find instead is             ernment officials in Europe — Germany and
something very different. What happens is that          France in particular. They’re very likely to be
the dealers very aggressively call both sides of        sued by investors because they were lead man-
the trade; they call the pension funds, who are         ager in a number of Greek bond issues at a time
the strong hands who can afford to sell the             when Greece’s off-balance-sheet swap financ-
“insurance” and then sit and wait, and they call        ing, also arranged by Goldman Sachs, was never
the hedge funds, who are the fast money look-           disclosed to prospective investors in the bonds.
ing for a quick pop — and they tell them com-           How on earth are you the lead manager of a
pletely different stories. And of course the firm       bond issue and not tell the buyers that you
in the middle, Goldman Sachs or another large           secretly arranged $1 billion of off-balance-sheet
bank, books a fat spread for its exertions. I           debt for the borrower? That seems like an
mean, we think we know why people might                 open-and-shut case of securities fraud.
want to buy the credit insurance because
Greece is in bad shape. But who on earth would          I’m sure they had legal opinions saying it
want to sell the insurance? You’d have to believe       was perfectly legal.
it was tremendously mispriced. You would have           Well, yes, but that depends on what they had
to believe that the premium is very rich relative       told the lawyers. If you give lawyers a set of
to the risk. In other words, you have to believe        facts, you’ll get a certain opinion. Did the
that the dealers are telling the long-only              lawyers know all the facts? I don’t know. But I
accounts and the institutions, the pension              do know that a lawyer’s opinion is only as good
funds, that this is very good return for them.          as the facts presented to the lawyer. Everyone is
“Don’t worry, in effect, the fix is in. Europe will     entitled to his day in court so I wouldn’t want to
ride to the rescue and Greece will not default,”        prejudge the case. But on the surface, at least,
and that the institutions basically buy that story.     these are very serious issues that probably will
Otherwise, why would they sell credit insurance         take years to play out, between European gov-
on Greece?                                              ernment actions and private lawsuits.

Where does the piñata come in?                          You’ve also written about a major concep-
Once the counterparties have their positions, the       tual flaw in credit default swaps — that
banks start pounding thinly traded Greek (or any        they allow someone without an insurable

                                                    welling@weeden   FEBRUARY 25, 2010   PAGE 13
interest to buy insurance, creating a per-
verse wish for the failure of companies or                                                                                                                                                          Weeden & Co. LP’s
countries by those holding CDS.                                                                                                                                                                     Research Disclosures
I think there are two solutions. One would be to                                                                                                                                                    In keeping with Weeden & Co. LP’s
                                                                                                                                                                                                    reputation for absolute integrity in its
require an insurable interest so that if I’m buy-                                                                                                                                                   dealings with its institutional clients,
ing insurance, I need to have some interest in                                                                                                                                                      w@w believes that its own reputation
the underlying risk being protected against, and                                                                                                                                                    for independence and integrity are
                                                                                                                                                                                                    essential to its mission. Our readers
if I’m selling insurance, I should be regulated                                                                                                                                                     must be able to assume that we have
like an insurance company, or at least have ade-                                                                                                                                                    no hidden agendas; that our facts are
quate reserves.                                                                                                                                                                                     thoroughly researched and fairly pre-
                                                                                                                                                                                                    sented and that when published our
The other solution for more liquid markets is                                                                                                                                                       analyses reflect our best judgments,
transparency. Put the trading of CDS and other                                                                                                                                                      not vested pocketbook interests of
derivatives on exchanges, have price reporting,                                                                                                                                                     our sources, colleagues or ourselves.
                                                                                                                                                                                                    Neither Weeden & Co. LP nor w@w
show bids and offers, have a large number of                                                                                                                                                        engage in investment banking; w@w’s
dealers, etc. Now, I don’t think you should need                                                                                                                                                    mission is strictly research.
insurable interest to sell 10-year note futures on                                                                                                                                                  This material is based on data from
the Chicago futures exchanges. I’m fine with                                                                                                                                                        sources we consider to be accurate
                                                                                                                                                                                                    and reliable, but it is not guaranteed
that market, because those are very liquid, very                                                                                                                                                    as to accuracy and does not purport
well-regulated, very transparent, very safe mar-                                                                                                                                                    to be complete. Opinions and projec-
kets. But the thinner the market, the greater                                                                                                                                                       tions found in this report reflect
                                                                                                                                                                                                    either our opinion (or that of the
the need for insurable interest. It’s as simple as                                                                                                                                                  named analyst interviewed) as of the
that. And one final thing, please don’t mistake                                                                                                                                                     report date and are subject to change
CDS prices for valid indicators of a company or                                                                                                                                                     without notice. When an unaffiliated
                                                                                                                                                                                                    interviewee’s opinions and projec-
government’s credit standing. If you look at the                                                                                                                                                    tions are reported, Weeden & Co. is
notional value of outstanding CDS relative to                                                                                                                                                       relying on the accuracy and com-
the underlying bond markets, you find most are                                                                                                                                                      pleteness of that individual/firm’s
                                                                                                                                                                                                    own research disclosures and
terrifically thin. There are a very small number                                                                                                                                                    assumes no liability for same, beyond
of dealers, two or three large international                                                                                                                                                        reprinting them in an adjacent box.
banks, not that many transactions, and it’s very                                                                                                                                                    This report is neither intended nor
                                                                                                                                                                                                    should it be construed as an offer to
easy for dealers to put marks where they want                                                                                                                                                       sell or solicitation or basis for any
them, causing collateral to move back and                                                                                                                                                           contract, for the purchase of any
forth, and causing profits and losses to arise on                                                                                                                                                   security or financial product. Nor has
                                                                                                                                                                                                    any determination been made that
the books of particular institutions without                                                                                                                                                        any particular security is suitable for
much linkage to the underlying market.                                                                                                                                                              any client. Nothing contained herein
Indeed, if you look at what I would call objective                                                                                                                                                  is intended to be, nor should it be
                                                                                                                                                                                                    considered, investment advice. This
metrics of fiscal responsibility, Greece’s debt-                                                                                                                                                    report does not provide sufficient
to-GDP ratio is about half of Japan’s. Their                                                                                                                                                        information upon which to base an
deficit-to-GDP ratio is not that different from                                                                                                                                                     investment decision. You are advised
                                                                                                                                                                                                    to consult with your broker or other
the United States. So why are the U.S. and                                                                                                                                                          financial advisors or professionals as
Japan the benchmarks and Greece is the prob-                                                                                                                                                        appropriate to verify pricing and
lem child? Granted, there are other factors;                                                                                                                                                        other information. Weeden & Co. LP ,
                                                                                                                                                                                                    its affiliates, directors, officers and
there were other things going in Greece. And                                                                                                                                                        associates do not assume any liabili-
I’m not exonerating them from their own fiscal                                                                                                                                                      ty for losses that may result from the
irresponsibility, but to suggest that the CDS                                                                                                                                                       reliance by any person upon any such
                                                                                                                                                                                                    information or opinions. Past perfor-
markets are trustworthy, reliable indicators of                                                                                                                                                     mance of securities or any financial
fiscal distress, in Greece or anywhere, is non-                                                                                                                                                     instruments is not indicative of future
sense.                                                                                                                                                                                              performance. From time to time, this
                                                                                                                                                                                                    firm, its affiliates, and/or its individ-
                                                                                                                                                                                                    ual officers and/or members of their
Well said. Thanks, Jim.                                                                                                                                                                             families may have a position in the
                                                                                                                                                                                                    subject securities which may be con-
                                                                                                                                                                                                    sistent with or contrary to the rec-
                                                                                                                                                                                                    ommendations contained herein; and
                                                                                                                                                                                                    may make purchases and/or sales of
                                                                                                                                                                                                    those securities in the open market
W@W Interviewee Research Disclosure: James G. Rickards is Senior Managing Director for Market Intelligence at Omnis, Inc. and co-head of the firm’s practice in Threat Finance & Market
Intelligence. He is also a member of the Board of Directors. This interview was initiated by Welling@Weeden and contains the current opinions of the interviewee but not necessarily those of
                                                                                                                                                                                                    or otherwise. Weeden & Co. LP is a
Omnis, Inc. Such opinions are subject to change without notice. This interview and all information and opinions discussed herein is being distributed for informational purposes only and should    member of FINRA, Nasdaq, and SIPC.
not be considered as investment advice or as a recommendation of any particular security, strategy or investment product. Information contained herein has been obtained from sources
believed to be reliable, but is not guaranteed. In addition, forecasts, estimates and certain information contained herein are based upon proprietary research and should not be interpreted as
investment advice, or as an offer or solicitation for the purchase or sale of any financial instrument. No part of this interview may be reproduced in any form, or referred to in any other pub-
lication, without express written permission of Welling@Weeden. Past performance is no guarantee of future results.

                                         welling@weeden          FEBRUARY 25, 2010          PAGE 14

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