James Rickards in Welling@Weeden

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James Rickards in Welling@Weeden
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VOLUME 12

ISSUE 4

listeningin

FEBRUARY 26, 2010





INSIDE

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 and 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

Michael Belkin Capital Management lec- sound a mite

Frontier Markets? tures on at Orwellian, it’s based

Northwestern’s Kellogg in McLean, VA, and

John Kosar

School, among other its website boasts of

Inflation & Fed places. Applying lessons from the realm of roots in the intelligence community. Just

physics to the morass in the capital markets, Jim what is its “practice in threat finance and

Chart Sightings says the Street has been deluding itself about the market intelligence” that you and a part-

well



Dave Rosenberg: nature of financial risk for a generation or two, ner head? A cynic might suggest the first

Lacking Confidence creating a far riskier, and more unstable, market part of that description is redundant and

Albert Edwards: in its scramble for short-term profits. There’s no the second, an oxymoron —

Japan’s Real mystery about the lessons of our mushrooming But I’m sure you know what Oscar Wilde said

Growth Problem 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,

ALL ON WEBSITE





RESEARCH

welling@weeden FEBRUARY 25, 2010 PAGE 1

DISCLOSURES PAGE R EPRINTED W ITH P ERMISSION

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

Authorized Reprint 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-

would help in the geopolitical sphere? So threat cy. Likewise, if countries are thinking of getting

Kathryn M. Welling

finance and market intelligence are basically out of dollars and getting into euros or gold or

Editor and Publisher

welling@weedenco.com 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

for clients of

sion makers in the area something about the

Weeden & Co. LP

of national defense, intentions of nation



Lance Lonergan

security and intelli-

gence.

“As general counsel states. My view is that

these things are not

Co-President, Global Sales

(800) 843-9333 or

Are you saying

of LTCM, I negotiated just market transac-

tions, they take place

(203) 861-7670

lance@weedenco.com geopolitical threats the bailout which in markets, but they

are somehow linked reveal something about

Thomas Orr

Managing Director, Research to stock fluctuations averted an even strategic intentions

(800) 843-9333 or punts on pork bel- and policies of other

tom_orr@weedenco.com

lies? greater disaster countries — which is

You are being way too helpful to the United

Noreen Cadigan

Institutional Research Sales literal. Basically, we at that point. What States. So that’s one

(203) 861-7644

ncadigan@weedenco.com think of the capital

markets as a very rich

strikes me now, way that the two worlds

we watch come togeth-

Jean M. Galvin

Business Manager/Webmaster

source of actual infor-

mation, assuming you

looking back, is how er.

(203) 861-9814

jean_galvin@weedenco.com know how to read it, nothing was changed; There are others?

how to drill down and The other way is that if

Subscriptions:

to segregate informa- no lessons were you’re in the market, if

Pat Quill tion. And there are a you’re a dealer, a mar-

(203) 861-9317 lot of techniques that applied. Even though ket maker, an invest-

pquill@weedenco.com

can be used there to do ment bank, a trader, a

Deirdre Sheehan

(203) 861-7636 that. The basic idea is the lessons hedge fund, etc., obvi-

dsheehan@weedenco.com that nobody transacts

in a vacuum. If you’re

were obvious, ously, you should care

enormously about

Published biweekly

on Friday mornings,

buying anything or

you’re selling anything,

in 1998.” prospects for war

between Iran and

by welling@weeden,

a research division of there has to be a coun- Israel, or about what’s

Weeden & Co. LP.

145 Mason Street terparty at a minimum. going on with Chavez

Greenwich, CT 06830. And there may be a market, though not always. and Venezuela; how does China feel about

Telephone: (203 ) 861-9814

Fax: (203) 618-1752 Sometimes these are over-the-counter markets, Iran?; what is Russia’s interest in the Middle

but even when you see activity in the over-the- East? Those are things that have huge impacts

Copyright Warning and Notice: It counter markets, often the dealer or one of the on commodities prices as well as other prices —

is a violation of market makers is hedging in some traded mar- and we can interpret those as well, for investors.

federal copyright law to repro-

duce all or part of this publica- kets. The point being, when countries and orga- The problem generally is that you have a lot of

tion or its contents nizations are transacting, they leave footprints; brilliant people and a lot of experts on both

by any means. The Copyright

Act imposes liability they leave ripples; they leave signals. If you can sides of the fence, but not too many people who

of up to $150,000 per issue for interpret those signals correctly, you can draw a can really stand on top of the fence and see the

such infringement.

welling@weeden does not lot of inferences about their actions, and that’s big picture.

license or authorize very helpful to policy makers.

redistribution in any form by

clients or anyone else. And that’s what you’ve been trying to do

However, clients may print one For instance? for about three years now?

personal copy and limited

reprint/republication permis- A very clear cut example that a lot of people fol- No, I have worked in the capital markets for 35

sion may be made available low are Chinese activities in the U.S. govern- years, but in terms of taking this particular

upon specific request.

Copyright 2010, K.M. Welling. ment securities market. We saw this throughout approach which I have just described as looking

All rights reserved. 2009. They were shortening up their maturities at the intersection of capital markets and





welling@weeden FEBRUARY 25, 2010 PAGE 2

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geopolitics, I have

been doing that since

2002.



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

clients.

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

Yes.

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

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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

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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 practioners managed

describing financial market risk is a straight to get it so wrong, swearing allegiance to the

line sloping downward from left to right. A notions of efficient markets and bell curve

power curve says that events of any size can 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

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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 comprehend. 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 practioners 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

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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

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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 a see- greater participation and diversification

ing 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

R EPRINTED W ITH P ERMISSION

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

R EPRINTED W ITH P ERMISSION

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

R EPRINTED W ITH P ERMISSION

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

R EPRINTED W ITH P ERMISSION

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 7% inflation. They’re netting out to about zero

that the whole monetarist project ignores veloc- but, in fact, we have an enormous force for

ity 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

R EPRINTED W ITH P ERMISSION

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

R EPRINTED W ITH P ERMISSION

interest to buy insurance, creating a per- Weeden & Co. LP’s

verse wish for the failure of companies or Research Disclosures

countries by those holding CDS. In keeping with Weeden & Co. LP’s

I think there are two solutions. One would be to reputation for absolute integrity in its

dealings with its institutional clients,

require an insurable interest so that if I’m buy- w@w believes that its own reputation

ing insurance, I need to have some interest in for independence and integrity are

the underlying risk being protected against, and essential to its mission. Our readers

must be able to assume that we have

if I’m selling insurance, I should be regulated no hidden agendas; that our facts are

like an insurance company, or at least have ade- thoroughly researched and fairly pre-

quate reserves. sented and that when published our

analyses reflect our best judgments,

The other solution for more liquid markets is not vested pocketbook interests of

transparency. Put the trading of CDS and other our sources, colleagues or ourselves.

derivatives on exchanges, have price reporting, Neither Weeden & Co. LP nor w@w

engage in investment banking; w@w’s

show bids and offers, have a large number of mission is strictly research.

dealers, etc. Now, I don’t think you should need This material is based on data from

insurable interest to sell 10-year note futures on sources we consider to be accurate

the Chicago futures exchanges. I’m fine with and reliable, but it is not guaranteed

as to accuracy and does not purport

that market, because those are very liquid, very to be complete. Opinions and projec-

well-regulated, very transparent, very safe mar- tions found in this report reflect

kets. But the thinner the market, the greater either our opinion (or that of the

named analyst interviewed) as of the

the need for insurable interest. It’s as simple as report date and are subject to change

that. And one final thing, please don’t mistake without notice. When an unaffiliated

CDS prices for valid indicators of a company or interviewee’s opinions and projec-

tions are reported, Weeden & Co. is

government’s credit standing. If you look at the relying on the accuracy and com-

notional value of outstanding CDS relative to pleteness of that individual/firm’s

the underlying bond markets, you find most are own research disclosures and

assumes no liability for same, beyond

terrifically thin. There are a very small number reprinting them in an adjacent box.

of dealers, two or three large international This report is neither intended nor

banks, not that many transactions, and it’s very should it be construed as an offer to

sell or solicitation or basis for any

easy for dealers to put marks where they want contract, for the purchase of any

them, causing collateral to move back and security or financial product. Nor has

forth, and causing profits and losses to arise on any determination been made that

any particular security is suitable for

the books of particular institutions without any client. Nothing contained herein

much linkage to the underlying market. is intended to be, nor should it be

Indeed, if you look at what I would call objective considered, investment advice. This

report does not provide sufficient

metrics of fiscal responsibility, Greece’s debt- information upon which to base an

to-GDP ratio is about half of Japan’s. Their investment decision. You are advised

deficit-to-GDP ratio is not that different from to consult with your broker or other

financial advisors or professionals as

the United States. So why are the U.S. and appropriate to verify pricing and

Japan the benchmarks and Greece is the prob- other information. Weeden & Co. LP ,

lem child? Granted, there are other factors; its affiliates, directors, officers and

associates do not assume any liabili-

there were other things going in Greece. And ty for losses that may result from the

I’m not exonerating them from their own fiscal reliance by any person upon any such

irresponsibility, but to suggest that the CDS information or opinions. Past perfor-

mance of securities or any financial

markets are trustworthy, reliable indicators of instruments is not indicative of future

fiscal distress, in Greece or anywhere, is non- performance. From time to time, this

sense. firm, its affiliates, and/or its individ-

ual officers and/or members of their

families may have a position in the

Well said. Thanks, Jim. 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

or otherwise. Weeden & Co. LP makes

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

a market in numerous securities.

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 Weeden & Co. LP is a member of

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 FINRA, Nasdaq, and SIPC.

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

publication, without express written permission of Welling@Weeden. Past performance is no guarantee of future results.









welling@weeden FEBRUARY 25, 2010 PAGE 14

R EPRINTED W ITH P ERMISSION


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