Economics – Page 8 – We Know Zero

State Pension Age and its discontents

10. December 2013 · Write a comment · Categories: Demographics, Economics, Pensions, Prediction, Regulation

When I started writing this blog in April, one of its main purposes was to highlight how poor we are at forecasting things, and suggest that our decision-making would improve if we acknowledged this fact. The best example I could find at the time to illustrate this point were the Office of Budget Responsibility (OBR) Gross Domestic Product (GDP) growth forecasts over the previous 3 years.

Eight months on it therefore feels like we have come full circle with the publication of the December 2013 OBR forecasts in conjunction with the Chancellor’s Autumn Statement. Little appears to have changed in the interim, the coloured lines on the chart below of their various forecasts now joined by the latest one all display similar shapes steadily moving to the right, advising extreme caution in framing any decision based on what the current crop of forecasts suggest.

However, the worse the forecasts are revealed to be, the keener it seems politicians of all the three main parties are to base policy upon them. The Autumn Statement ran to 7,000 words, of which 18 were references to the OBR, with details of their forecasts taking up at least a quarter of the speech. In every area of economic policy, from economic growth to employment to government debt, it seemed that the starting point was what the OBR predicted on the subject. The Shadow Chancellor appears equally convinced that the OBR lends credibility to forecasting, pleading for Labour’s own tax and spending plans to be assessed by them in the run up to the next election.

I am a little mystified by all of this. The updated graph of the OBR’s performance since 2010 does not look any better than it did in April, the lines always go up in the future and so far they have always been wrong. If they turn out to be right (or, more likely, a bit less wrong) this time, then that does not seem to me to tell us anything much about their predictive skill. It takes great skill, as Les Dawson showed, to unerringly hit the wrong notes every time. It just takes average luck to hit them occasionally.

For another bit of crystal ball gazing in his Statement, the Chancellor abandoned the OBR to talk about state pension ages. These were going to go up to 68 by 2046. Now they are going to go up to 68 by the mid 2030s and then to 69 by the late 2040s. There will still be people alive now who were born when the state retirement age (for the “Old Age Pension” as it was then called) was 70. It looks like we are heading back in that direction again.

The State Pension Age (SPA) was introduced in 1908 as 70 years for men and women, when life expectancy at birth was below 55 for both. In 1925 it was reduced to 65, at which time life expectancy at birth had increased to 60.4 for women and 56.5 for men. In 1940, a SPA below life expectancy at birth was introduced for the first time, with women allowed to retire from age 60 despite a life expectancy of 63.5. Men, with a life expectancy of 58.2 years were still expected to continue working until they were 65. Male life expectancy at birth did not exceed SPA until 1948 (source: Human Mortality Database).

In 1995 the transition arrangements to put the SPA for women back up to 65 began, at which stage male life expectancy was 73.9 and female 79.2 years. In 2007 we all started the transition to a new SPA of 68. In 2011 this was speeded up and last week the destination was extended to 69.

Where might it go next? If the OBR had a SPA modeller anything like their GDP modeller it would probably say up, in about another 2 years (just look again at the forecasts in the first graph to see what I mean). Ministers have hit the airwaves to say that the increasing SPA is a good news story, reflecting our increasingly long lives. And the life expectancies bear this out, with the 2011 figures showing life expectancy at birth for males at 78.8 and for females at 82.7, with all pension schemes and insurers building in further big increases to those life expectancies into their assumptions over the decades ahead.

And yet. The ONS statistical bulletin in September on healthy life expectancy at birth tells a different story which is not good news at all. Healthy life expectancies for men and women (ie the maximum age at which respondents would be expected to regard themselves as in good or very good health) at birth are only 63.2 and 64.2 years respectively. If people are going to have to drag themselves to work for 5 or 6 years on average in poor health before reaching SPA under current plans, how much further do we really expect SPA to increase?

Some have questioned the one size fits all nature of SPA, suggesting regional differences be introduced. If that ever happened, would we expect to see the mobile better off becoming SPA tourists, pushing up house prices in currently unfashionable corners of the country just as they have with their second homes in Devon and Cornwall? Perhaps. I certainly find it hard to imagine any state pension system which could keep up with the constantly mutating socioeconomics of the UK’s regions.

Perhaps a better approach would be a SPA calculated by HMRC with your tax code. Or some form of ill health early retirement option might be introduced to the state pension. What seems likely to me is that the pressures on the Government to mitigate the impact of a steadily increasing SPA will become one of the key intergenerational battlegrounds in the years ahead. In the meantime, those lines on the chart are going to get harder and harder for some.

Dollars and Census

22. November 2013 · Write a comment · Categories: Actuarial, Demographics, Economics, Regulation

The latest revelations from Edward Snowden that the US and UK agreed in 2007 to relax the rules governing the mobile phone and fax numbers, emails and IP addresses that the US National Security Agency (NSA) could hold onto (and extending the net to people not the original targets of their surveillance) has increased the pressure on the Government to tighten controls on the activities of the security services. This extension apparently allowed the NSA to venture up to three “hops” away from a person of interest, eg a friend of a friend of a friend on Facebook.

I have an issue with the Guardian analysis here. They say that three hops from a typical Facebook user would rope in 5 million people. However, using actual ratios from the network in their source (43 friends have 3,975 friends of friends have 1,328,361 friends of friends of friends) and the median number of friends of 99 from the original study, would lead to a number closer to 3 million. Still, it is clearly altogether too many people to be treated as guilty by association.

So it might seem like a strange time for me to be advocating that we give the Government more of our data.

The Office for National Statistics (ONS) is currently consulting on the form of the next census and the future of population statistics generally. The two options they have come down to are:

1. Keep the 2021 census pretty much as it was for 2011, although with perhaps slight changes to the questions and a greater push for people to complete them online; or
2. Using administrative data already held by the Government in its various departments to produce an annual estimate of the population in local areas. In addition there would be separate compulsory surveys of 1% and 4% of the population for checking the overall population figures and some of the sub-grouping respectively, and the ‘residents of “communal establishments” such as university halls of residence and military bases’ which are difficult to reach by other means.

In my response to the survey, I suggested that they do both, increase the compulsory surveys each year to 10% of the population and reduce the time between full censuses to 5 years. This is why.

First of all, everybody needs this data to be available. If the Government does not provide it, someone else will. Not by asking you overt questions, but by buying information about your buying preferences or search engine activities or any number of other transactions without your informed consent (eg you ticked agreement to their terms and conditions on their website) and without your knowledge. I would prefer to give my data to the ONS.

The ONS is part of the UK Statistics Authority, which is an independent body at arm’s length from government. It reports directly to Parliament rather than to Government Ministers and has a strong track record of challenging the Government’s misuse of statistics. With the exception of requests received for personal information (which are filtered off to become Subject Access Requests under the Data Protection Act), they have provided copies of all information disclosed by the ONS under the Freedom of Information Act on their website. In my view the ONS has demonstrated that it is a safe custodian of our data. They are everything the NSA is not: overt, apolitical and committed to the appropriate use of statistics.

But there are problems with the current data, which brings me onto my second point. Ten years is too long to wait for updated information. As the ONS points out in its consultation document, because of the ten year gap between censuses, the population growth resulting from expansion of the European Union in 2004 was not fully understood until 2012. There were other problems with the population data everyone had been working with before 2011, 30,000 fewer people in their 90s than expected for instance, which had serious implications for all involved in services to the elderly and those constructing mortality tables too.

So we do need more frequent census information. Five years seems about right to me, provided the annual updates can be made more rigorous. I think the ONS are right to suggest that they need to be compulsory to achieve this, but 5% of the population does not seem a large enough sample to be confident about this to me. I would prefer to see 10% completing annual surveys. This would allow 50% of the population to be covered over every 5 year census period, or 40% if the requirement was dropped in census year. There are many recent examples (see Schonberger and Cukier below) to suggest that the gains in accuracy due to increased coverage would be far greater than the losses due to the ‘messiness’ of incomplete responses.

There is a lot in the consultation document about the relative costs of the different options, but nothing about the commercial value of the data being collected. Indeed the reduction of the consultation to these two, to my mind, inadequate options seems to be very greatly influenced by the question of costs and the current cuts in budgets seen throughout the public sector. This seems to me to be very short-sighted.

However, I think this displays a failure of imagination. According to Viktor Mayer-Schonberger and Kenneth Cukier in their book Big Data, data is set to be the greatest source of wealth and economic growth looking forward. Many others agree. By taking a fully accountable and carefully controlled approach to licensing the data in its care, the ONS should be able to finance its own activities, even at the level I am suggesting, at the very least.

The ONS is very nervous about becoming more intrusive in its collection methods, citing the 35% increase in cost of the 2011 census in achieving the same level of response. It also refers to the response rates to its voluntary surveys which have dropped from around 80% 30 years ago to around 60% today. The main reasons for this in my view are the incessant requests from companies’ marketing departments masquerading as surveys on everything from phone usage to our views on banking to the relentless demands for feedback on every online purchase making us all subject to survey fatigue. This makes it all the more necessary that an organisation which is not trying to sell you anything and which is scrupulous about the protection of your data should be attempting to increase its scope and maintaining its position as the go to place for statistical data rather than falling behind its commercial rivals.

So let’s not fall into the trap of conflating all official data with the mountains of bitty fragments collected by our intelligence agencies from their shady sources. That has nothing to do with the proper, accountable collection of information to allow government and governed alike access to what they need to make better decisions.

So take part in the consultation, it matters. And when the time comes give the ONS your data. You know it makes census.

There are things going on that we don’t know

23. October 2013 · Write a comment · Categories: Actuarial, Economics, Pensions

It looks very strange from the outside looking in.

INEOS, the 3rd largest independent global chemical company is seeking to recruit highly motivated technicians, the advert read, posted only 3 weeks ago on 30 September.

These posts are based at our sites at Grangemouth, INEOS’ largest asset which includes Scotland’s only crude oil refinery and Finnart on Loch Long. This is an exciting time to join us: we are fully committed to our business in Scotland and are looking to develop our technology business globally.

…Successful candidates will receive an extremely competitive salary including shift allowance and benefits package including a competitive pension scheme.

Cut to yesterday when the chairman of INEOS Grangemouth announced that the workers had to accept the company’s survival plan or the plant would close, as they were losing £150 million a year and had a pensions deficit of £200 million. Today Unite said around 680 of the site’s 1,370-strong workforce had rejected the company’s proposals, which include a pay freeze for 2014-16, removal of a bonus up to 2016, a reduced shift allowance and replacement of the final salary pension scheme with a money purchase scheme. INEOS responded by confirming the closure of the petrochemical operation at Grangemouth.

It was in 2008 that INEOS originally took the decision to close the company’s final salary pension scheme to new employees due to the costs associated with its continued operation. Following a strike organised by Unite, the company relented following various interventions including by the then President of the Faculty of Actuaries, Stewart Ritchie, keeping the scheme open to new employees in exchange for a 2% employee contribution. Unite made, and then withdrew, a claim that INEOS had asset-stripped the Grangemouth refinery business which had been spun off from BP in 2006. It also claimed that workers at Grangemouth were paid £6,000 less than workers at other similar facilities. One estimate was that the average salary at Grangemouth was £40,000 per year at the time.

Assuming the average has increased to, say, £50,000, that would represent a total wage bill now of around £70 million a year, based on a total workforce of around 1,400. The proposals on increases and bonuses would therefore look inadequate to make much impact on losses of £150 million a year. The pension changes may be more significant (the company estimates pension costs are currently 65% of salaries, although a large part of this is likely to be payments on the deficit which would be likely to remain after any restructure).

However, things are not what they seem. The £150 million pa quoted by the company is negative cashflows rather than losses. The company’s is investing £150 million more than the profits it makes each year at Grangemouth. The refinery is expected to make a profit in 2013.

Atleast it was. INEOS had warned that unless the survival plan were accepted, it would close half of the plant in four years’ time. The action to permanently close the petrochemical plant and not to reopen the refinery while they felt there was still a “threat of strike action” therefore represents a pre-emptive strike by the company, after Unite had agreed to call off strike action last week. The three day stoppage in 2008 was said to have cost the UK economy at least £100 million.

And the strangeness does not stop there. There is another dispute going on alongside the economic one. Unite originally threatened industrial action in July over the suspension of Stevie Deans, a Unite official allegedly involved in the selection of a Labour parliamentary candidate in Falkirk, who was subsequently reinstated and cleared by the Labour Party’s internal investigation. Dean is currently being investigated by an undisclosed third party on behalf of INEOS for allegedly using his position to recruit staff to the constituency party, with the investigation due to conclude on Friday. It is not clear where the announcements today leave this investigation.

If the petrochemical plant is to go into insolvency, possibly followed by the closure of the rest of the site, the next question for the workers after the loss of their salaries will be what is to happen to their pensions if INEOS sell up. To paraphrase Lynyrd Skynyrd, there are definitely things going on that we don’t know here.

RM = QE?

21. October 2013 · Write a comment · Categories: Economics, Regulation

A couple of days ago I received my statement from Royal Mail plc, confirming my allocation of 227 shares at the offer price of £3.30 each, therefore costing me £749.10. At the time of writing the share price is at £5.14 (although it was at £5.31 a few hours ago), equivalent to a value for my 227 shares of £1,166.78.

So I am sitting on a paper profit of over £400, and the Government is under fire for undervaluing Royal Mail, from everyone from the trades’ unions, to the Labour Party, to the Commons Business Select Committee to even some stockbrokers and to 51% of the general public. In response, Vince Cable, the Business Secretary, has suggested that everyone calms down a bit and waits to see what the price is in a couple of months.

But what if the issue was not mis-priced at all? What if the short-term profits were intended all along?
Remember that this is a Government still in the business of quantitative easing (QE). A process described by the Bank of England thus:

…the asset purchase programme is not about giving money to banks. Rather, the policy is designed to circumvent the banking system. The Bank of England electronically creates new money and uses it to purchase gilts from private investors such as pension funds and insurance companies. These investors typically do not want to hold on to this money, because it yields a low return. So they tend to use it to purchase other assets, such as corporate bonds and shares. That lowers longer-term borrowing costs and encourages the issuance of new equities and bonds to stimulate spending and keep inflation on track to meet the government’s target.

However, the critics of QE have become increasingly loud. It is untested, no one is quite sure what the long term consequences will be of the amounts that have been invested in this way and many of the short term benefits appear to have been benefitting the wrong people once the initial emergency receded. Perhaps partly as a result of these criticisms, there has been no new QE since July 2012.

Alternatives have increasingly been tossed around between economists and other commentators. One of which is the notion of helicopter money. Drop it from the skies, cut out the banks, and the effects will be more immediate, its supporters say.

If the target of QE is investors, and the aim of the policy is to make them invest in corporate bonds and shares rather than gilts, in order to encourage companies to raise more money in the markets to fund expansion, could the paper profit of £1.7 billion (compared to the £375 billion of QE so far) be a micro-experiment in a different type of QE?

There is other evidence to support this. At the end of 2011, Spencer Dale, the Bank’s chief economist, gave a speech about flaws in the QE approach:

I have considerable sympathy for the argument that the MPC’s asset purchase programme provides relatively limited direct support to SMEs (ie small and medium sized businesses). It will provide indirect support by stimulating spending and activity in our economy. But most SMEs are heavily dependent on bank credit and so not able to benefit directly from the increased demand for corporate debt and equity triggered by our asset purchases. But therein lies the problem. The majority of SMEs do not issue marketable securities that the MPC could purchase…..Instead, we need to find ways to incentivise the banks to lend more to SMEs.

So would a few hundred pounds each help SMEs? Well, some of the owners will have applied for shares and benefitted directly, as they are likely to be in the more financially aware section of the public. This may also explain the decision to set a minimum stake of £750 in the Royal Mail offer. Others may benefit from any increase in consumer spending that results from people spending their winnings. The longer term stimulus effect the Bank is trying to produce will depend more on the actions of the institutional investors who bought 70% of the offering.

One of the other criticisms of QE is the impact on interest rates, although the size of the impact is difficult to determine and those who complain about the implications on annuity rates, for instance, tend to ignore the stoking up of asset prices it is also likely to have achieved. However Charlie Bean, one of the Bank’s deputy governors, gave some support to this criticism in May 2012:

A long period of abnormal monetary policy strains social support for a central bank’s actions. Changes in policy always have distributional consequences, shifting income from savers to borrowers or vice versa. That is an unavoidable by-product, rather than the aim, of policy. Society usually accepts such consequences because they are transitory, and what one loses on the swings today, one may gain on the roundabouts tomorrow. But the sustained period of very low interest rates has, quite reasonably, prompted complaints from savers who feel they are bearing an unfair burden.

So any vehicle for putting money in people’s hands without affecting interest rates would, we assume, at least get a fair hearing at the Bank.

When QE appears to have run out of steam, and the “Help to Buy” home ownership schemes are causing increasing unease about the property bubble they seem almost certain to create, should we expect to see further privatisations on the Royal Mail model if the recovery stalls? It wouldn’t surprise me in the least.

The Phoenix has landed

14. October 2013 · Write a comment · Categories: Birmingham, Cartoons, Economics, Regulation

Mention the Phoenix Four in Birmingham and you are likely to get a strong reaction. Most people knew someone who worked at MG Rover’s Longbridge plant, and many local families supplied workers for generation after generation. A huge rally brought tens of thousands onto the streets in 2000 when BMW put MG Rover up for sale, protesting against what had appeared at the time to be the most likely outcome of Alchemy Partners buying it and turning it into a low volume car manufacturer with only 2,000-3,000 of the 6,500 jobs there remaining. So there was jubilation when the ‘Phoenix Four’ group of businessmen (John Towers, John Edwards, Peter Beale and Nick Stephenson) stepped in to take the business off BMW’s hands for £10 with a further £500 million accompanying the business from BMW to sweeten the deal. By 2005 all the jobs had been lost.

A Government inquiry into Phoenix Venture Holdings (PVH – the Four’s company) reported in 2009 that The Four had managed to extract £42 million in salaries and pensions by this time. The inquiry spent 4 years and £16 million getting to grips with the convoluted machinations by which this was achieved. No criminal charges resulted. The Four were not even disqualified from being company directors. Instead, in 2011, they belatedly agreed voluntarily not to serve as directors for 3 (Edwards), 5 (Towers and Stephenson) and 6 (Beale) years respectively.

In January last year, the Executive Counsel to the Financial Reporting Council (FRC) finally turned to the advice The Four had been receiving during the whole saga, from Deloitte and specifically their head of UK corporate practice Maghsoud Einollahi, alleging that their conduct fell short of the standards reasonably expected of them in relation to Project Platinum (the project to put a deal together) and Project Aircraft (the specific deal to transfer MG Rover Group’s (MGRG’s) accumulated tax losses to a subsidiary of PVH). The tribunal ruled on these allegations last month. It makes entertaining reading unless you happen to be a former MG Rover employee.

One of the issues was that Deloitte had muddied the waters about who they were representing (MGRG or PVH) in order to mask a massive conflict of interest. As the tribunal states:

If the identity of the client is not known it is not possible to identify and consider whether there is any conflict existing or potential. That is the real importance of identifying the client. Here the client was known to the Respondents (ie Deloitte and Einollahi) a substantial time before the final existence of a letter of engagement and nothing was done about it.

The Phoenix Four were always the client. Deloitte were at all times acting on their behalf. We know too that the Respondents were represented at an MG Rover Group Limited Board Meeting and made a presentation to the Board thus suggesting that they were acting for MG Rover and not the Phoenix Four.

But my favourite bit is the extract of Einollahi’s testimony on who his client was:

Q: (reading his previous testimony) “…you did not think you had a client…”
A: (Pause) I think that is fair, that I didn’t believe I contractually had a client.
Q: Exactly
A: But
Q: And the problem is the one that I have alluded to already, that you would be holding yourself out to third parties as acting for, in this case, the group (ie MG Rover)
A: (Nods)

Following this Pinteresque dialogue, the tribunal moved on to Deloitte’s fee of £7.5 million. Part of the defence case had been that £7.5 million was not a very large fee within the context of Deloitte’s annual fee income, that contingency fees (ie which were paid only if a given result was achieved) were common and that clients were not prepared to accept different arrangements. The tribunal was not impressed:

It seems to us that Mr Einollahi would charge a contingency fee of a size he thought that he would be paid by the client without considering whether it was appropriate or not. Again when he gave evidence he was cross-examined and we refer to one question and answer.
Q: …you did not like to negotiate fees downward?
A: I didn’t – I didn’t act for people who wanted to negotiate my fees downward. I didn’t need to.

The tribunal concluded:

He wanted that fee of £7.5 million and realised that his best prospects of achieving that fee were by a deal between the Phoenix Four and HBOS rather than between MGRG and First National Finance or MGRG and HBOS

Project Aircraft, the scheme involving moving around MG Rover tax losses, had been attempted before under the title Project Salt/Slag and rejected by the Inland Revenue. Aircraft succeeded where Slag failed largely because the Revenue believed this time that MG Rover would benefit from the profits generated by the scheme.

Mr Towers said “frankly, for us, what mattered was there was a possibility here of creating cash, additional cash for the group and most particularly, for the cash-consuming part of the group which was the car company”. Mr Beale’s evidence was to the effect that MGRG benefited from the transaction because “it gave the group additional cash reserves which it could lend to MG Rover as and when required”. The Inspectors (from the Government inquiry) said at Chapter XI paragraph 17 “in practice, much of the money which the group generated from Project Aircraft was used to fund a payment to the Guernsey Trust”. (The beneficiaries of which included Messrs Beale, Edwards, Stephenson and Towers.) The Inspectors continued “immediately before Barclays Bank made its £121 million loan (which also paid off a previous loan and some other creditors), PVH had credit balances on its bank accounts totalling £2,184,083. The loan increased the credit balances to £14,736,629, enabling the company on 26 June 2002, without having received any money from any outside source in the interim, to pay £7,905,125 to the Guernsey trust (as well as paying £2,261,875 to Deloitte in respect of fees for Project Aircraft). No payment was made by PVH to MGRG at this stage, or in fact at any time before November 2003.

The tribunal continued:

Mr Einollahi undoubtedly played a significant part in Project Aircraft. He must have been aware, and admits that he was so aware, that the Phoenix Four were on holiday in Portugal in 2001 and while on holiday agreed between themselves to pay themselves very substantial bonuses. They in fact paid themselves collectively about £7 million after the conclusion of the Project Aircraft transaction. These sums came essentially from assets of MGRG and were used to make these very substantial payments to the Phoenix Four. They received the whole of the proceeds and MGRG received none.

In conclusion, the tribunal said:

They (ie Deloitte and Einollahi) placed their own interests ahead of that of the public and compromised their own objectivity. This was a flagrant disregard of the professional standards expected and required and was in each individual case, and of its own, serious misconduct.

The Executive Counsel, who had made the complaints, asked for a severe reprimand and a fine of between £15 million and £20 million. They also requested that Einollahi be excluded from membership of the Institute of Chartered Accountants in England and wales (ICAEW) for 6 months and fined an amount based on an assessment of his financial resources. Deloitte suggested instead that the fine should only be £1 million and Einollahi should not be fined at all.

At this point, in my view, the tribunal lost its way a little. They decided on a severe reprimand and a fine of £14 million for Deloitte. This was calculated as follows:

We have assessed the financial gain from the fees attributable to both Project Platinum and Project Aircraft with a deduction for the total amount of recorded costs against these projects. We have added interest at 1% over base rate to deny Deloitte any financial gain from the misconduct.

This raises an interesting question about what calculations other firms might make in the future about the chances of ending up in a tribunal like this and the likely consequences against the rewards of the deals themselves. If worst case scenario is that they won’t make a profit, I remain unconvinced that this will prove much of a deterrent.

They added:

We have borne very much in mind that Deloitte is not insured against the imposition of a fine and has undertaken to indemnify Mr Einollahi against any fine imposed upon him.

It is heartwarming to see them looking after their errant employee in this way, but their insurance arrangements should be of no interest to anyone.

Einollahi himself was excluded for 3 years rather than the 6 months requested by the Counsel, but only because he was not prepared to voluntarily relinquish his practising certificate. He also refused to cooperate with the assessment of his financial resources, leading to the tribunal to put a bit of a finger in the air and opt for a fine of £250,000.

So what now? The tribunal made much of the public interest in the hearings:

It was particularly important in the case of both Project Platinum and Project Aircraft that the public interest be considered because of the concern of inter alia the Government, employees, other employers, particularly in the West Midlands, creditors and the general public about the continuation of large scale car manufacturing in the West Midlands.

The importance of considering the public interest is further emphasised because both the Projects resulted in very large sums of money that might have been utilised for the benefit of the MG Rover Group in the running of its business instead, being used for the benefit of individuals, including the Phoenix Four.

But what is the public interest? My assumption would have been that it must primarily be about the portion of the general public which was most damaged by all this, namely the MG Rover workers who lost their jobs and their communities. The local MP, Richard Burden, agrees. The Trust Fund for former MG Rover workers, which John Towers had at one point said would have over £50 million in it, was finally wound up earlier this year when the £23,000 actually available was donated by the workers to a local hospice.

The £14.25 million awarded in fines would normally go to the Consultative Committee of Accounting Bodies (CCAB), an umbrella group for several professional bodies, which pays the costs of FRC disciplinary cases. However in this case the costs of the proceedings of just under £4 million have already been charged to Deloitte on top. Is the case for meeting the costs of future disciplined accountants really greater than the public interest in making some contribution to the communities that the FRC’s members have facilitated into the ground?

There will be some time to make this decision in. Depressingly, Deloitte and Einollahi filed formal notice on 1 October that they are appealing the decision, as indeed they have contested everything that wasn’t nailed down throughout the process. Their joint statement read as follows:

“We recognise the general desire to move on from this case but do not agree with the main conclusions of the tribunal which we feel could create significant uncertainty for individual members and member firms of the ICAEW.”

After all, if it ever became accepted that consultants had any responsibility to the most vulnerable people affected by their less-than-professional manoeuvrings, where might it end? There is no time limit on the tribunal member hearing the appeal to make a decision on whether an appeal can go forward.

Enough is enough. Deloitte should do the right thing and drop their appeal now.

Faced with Philip Booth’s free market fanaticism, I’d rather be Frank

07. October 2013 · Write a comment · Categories: Economics, Regulation, Risk

This was a letter sent to The Actuary on 12 September, but which they chose to publish neither in the magazine nor on the website.

Dear Sir

In response to the interview with Philip Booth in the September issue, I would just like to point out that the banks did not know during the 2007 financial crisis that they would be bailed out. The day before Alistair Darling announced a £500 billion rescue package in October 2008, shares in RBS fell by almost 40 per cent to a 15-year low, HBOS fell by over 40 per cent, Lloyds TSB dropped by 13 per cent and Barclays by 9 per cent precisely because a bailout was not assumed.

As regards how prudently financial institutions behaved before the changes in insurance regulation in the 1970s and 1980s, I would prefer to listen to the views of someone who was actually there. Frank Redington, in his submission to the Institute of Actuaries in 1981 entitled The Flock and the Sheep and Other Essays, says:

“We have no means now of telling how the profession would have emerged from what would have been the only real test of its collective character which it has had to endure in the last 100 years. When the curtain fell in 1939 the profession was not cutting a very brave figure. Valuation bases were too weak, the rate of bonus was some £5 too high and new business was being sold on prospects which were not achieved until 18 years later. A few reputable offices had their backs to the wall.

“The outcome, if the war had not interrupted the story, would probably have taught us a valuable lesson. As it is we have to conclude regretfully that the profession had not – and, I am sure, has not – learned how to live with its salemen’s promises. To put it another way, we are driving a powerful car but have not yet proved our ability to handle the brakes.”

Regulation was inevitable. The problem which remains is that financial institutions in many cases are too complicated in their current form to regulate effectively. As Robert Reich, former US Secretary of Labor, puts it when arguing for the need to split Wall Street banks, they are “too big to fail, too big to jail, too big to curtail”!

Yours faithfully
Nick Foster

Boomers versus Y and Z

10. September 2013 · Write a comment · Categories: Economics

When the GCSE results came out the other week I had a special reason to be interested as my daughter Polly was one of the anxious students waiting for them. As it turned out, she did very well, but I ended up listening to news coverage of the event which perhaps ordinarily I would have missed.

And how obnoxious it was! Despite a reassuring increase in students taking the more difficult subjects, and pass rates at all grades statistically no different from the previous year (nearly every media outlet seemed to report a drop, once again the direction deemed more important than the amount). Unless the numbers go up every year, apparently, none of us are happy.

When the steam (or hot air at least) had run out of these criticisms, people of my age seemed to be queuing up to appear on radio stations to tell today’s students that what they lacked was something called “grit”. We need to introduce a GCSE in Grit, they cried.

Grit. Really? This is the generation which has not had the grit to adequately tackle any issue which threatened the immediate earnings of the already rich and powerful, like climate change for instance, or a just tax system, either globally or even nationally.

But they are right in a way, because a generational war has been declared and the sooner today’s students wake up to this the better. We are not all in it together. The labels of “baby boomer” or Generation X, Y and Z are there to put us into economic camps (definitions vary, but I, at 50, am somewhere on the boomer-X boundary apparently, my children are Y and Z, or both Z, depending on the point someone is trying to squeeze out of the data). When they stumble out into the job market, today’s students risk having insufficient qualifications (because even when the numbers do all go up, employers cry “grade inflation” and pull up the drawbridge even further) for anything but a McJob, on zero hours contracts, or nothing at all, subject to youth curfews, ASBOs and acoustic dispersal devices. If they are lucky enough to be graduates they will have, in addition, a loan of at least £40,000 to repay. If they want to rent somewhere to live, they will be victim to an insufficiently regulated private rental market. If they want to buy, they are highly vulnerable to a property bubble being inflated for all its worth by George Osborne. It would be hard not to conclude that the rest of society had declared war on them while they were preparing for their gritless exams.

Meanwhile, the sense of entitlement amongst the boomers is frequently drowning out any other voices. Low interest rates are bad because they “attack” pensioners’ savings, and make annuities more expensive for those about to become pensioners. However this is just special pleading for one generational group. Low interest rates are good for making the Government’s money go further, and for spending on other priorities than the boomers.

Similarly high inflation is bad news if you’re a pensioner, and if your pension, as most are where the pensioner had a choice, is not inflation-linked. However, provided it is accompanied by earnings and economic growth, ultimately it is how a deficit burden, both private and public, is going to be shrunk most effectively.

The last thing Ys and Zs need is another 50-something lecturing them on what to do, but my plea would be that they don’t let these arguments be lost by default. The battle lines have been drawn. And I know which side I’m on.

Land mines and bank bailouts

28. August 2013 · Write a comment · Categories: Cartoons, Economics, Prediction, Regulation, Risk

A man is sentenced to 7 years in prison for selling bomb detectors which had no hope of detecting bombs. The contrast with the fate of those who have continued to sell complex mathematical models to both large financial institutions and their regulators over 20 years, which have no hope of protecting them from massive losses at the precise point when they are required, is illuminating.

The devices made by Gary Bolton were simply boxes with handles and antennae. The “black boxes” used by banks and insurers to determine their worst loss in a 1 in 200 probability scenario (the Value at Risk or “VaR” approach) are instead filled with mathematical models primed with rather a lot of assumptions.

The prosecution said Gary Bolton sold his boxes for up to £10,000 each, claiming they could detect explosives. Towers Watson’s RiskAgility (the dominant model in the UK insurance market) by contrast is difficult to price, as it is “bespoke” for each client. However, according to Insurance ERM magazine in October 2011, for Igloo, their other financial modelling platform, “software solutions range from £50,000 to £500,000 but there is no upper limit as you can keep adding to your solution”.

Gary Bolton’s prosecutors claimed that “soldiers, police officers, customs officers and many others put their trust in a device which worked no better than random chance”. Similar things could be said about bankers during 2008 about a device which worked worse the further the financial variables being modelled strayed from the normal distribution.

As he passed sentence, Judge Richard Hone QC described the equipment as “useless” and “dross” and said Bolton had damaged the reputation of British trade abroad. By contrast, despite a brief consideration of alternatives to the VaR approach by the Basel Committee on Banking Supervision in 2012, it remains firmly in place as the statutory measure of solvency for both banks and insurers.

The court was told Bolton knew the devices – which were also alleged to be able to detect drugs, tobacco, ivory and cash – did not work, but continued to supply them to be sold to overseas businesses. In Value at Risk: Any Lessons from the Crash of Long-Term Capital Management (LTCM)? Mete Feridun of Loughborough University in Spring 2005 set out to analyse the failure of the Long Term Capital Management (LTCM) hedge fund in 1998 from a risk management perspective, aiming at deriving implications for the managers of financial institutions and for the regulating authorities. This study concluded that the LTCM’s failure could be attributed primarily to its VaR system, which failed to estimate the fund’s potential risk exposure correctly. Many other studies agreed.

“You were determined to bolster the illusion that the devices worked and you knew there was a spurious science to produce that end,” Judge Hone said to Bolton. This brings to mind the actions of Philippe Jorion, Professor of Finance at the Graduate School of Management at the University of California at Irvine, who, by the winter of 2009 was already proclaiming that “VaR itself was not the culprit, however. Rather it was the way this risk management tool was employed.” He also helpfully pointed out that LTCM were very profitable in 2005 and 2006. He and others have been muddying the waters ever since.

“They had a random detection rate. They were useless.” concluded Judge Hone. Whereas VaR had a protective effect only within what were regarded as “possible” market environments, ie something similar to what had been seen before during relatively calm market conditions. In fact, VaR became less helpful the more people adopted it, as everyone using it ended up with similar trading positions, which they then attempted to exit at the same time. This meant that buyers could not be found when they were needed and the positions of the hapless VaR customers tanked even further.

Gary Bolton’s jurors concluded that, if you sell people a box that tells them they are safe when they are not, it is morally reprehensible. I think I agree with them.

Earthquakes and Equities

10. August 2013 · Write a comment · Categories: Economics, Prediction

Plotting the frequency of earthquakes higher than a given magnitude on a logarithmic scale gives a straightish line that suggests we might expect a 9.2 earthquake every 100 years or so somewhere in the world and a 9.3 or 9.4 every 200 years or so (the Tohoku earthquake which led to the Fukushima disaster was 9.0). Such a distribution is known as a power-law distribution, which gives more room for action at the extreme ends than the more familiar bell-shaped normal distribution, which gives much lower probabilities for extreme events.

Similarly, plotting the annual frequency of one day falls in the FTSE All Share index higher than a given percentage on a logarithmic scale also (as you can see below) gives a straightish line, indicating that equity movements may also follow a power-law distribution, rather than the normal distribution (or log normal, where the logarithms are assumed to have a normal distribution) they are often modelled with.
However the similarity ends there, because of course earthquakes normally do most of their damage in one place and on the one day, rather than in the subsequent aftershocks (although there have been exceptions to this: in The Signal and the Noise, Nate Silver cites a series of earthquakes on the Missouri-Tennessee border between December 1811 and February 1812 of magnitude 8.2, 8.2, 8.1 and 8.3 respectively). On the other hand, large equity market falls often form part of a sustained trend (eg the FTSE All Share lost 49% of its value between 11 June 2007 and 2 March 2009) with regional if not global impacts, which is why insurers and other financial institutions which regularly carry out stress testing on their financial positions tend to concern themselves with longer term falls in markets, often focusing on annual movements.

How you measure it obviously depends on the data you have. My dataset on earthquakes spans nearly 50 years, whereas my dataset for one day equity falls only starts on 31 December 1984, which was the earliest date from which I could easily get daily closing prices. However, as the Institute of Actuaries’ Benchmarking Stochastic Models Working Party report on Modelling Extreme Market Events pointed out in 2008, the worst one-year stock market loss in UK recorded history was from the end of November 1973 to the end of November 1974, when the UK market (measured on a total return basis) fell by 54%. So, if you were using 50 years of one year falls rather than 28.5 years of one day falls, a fall of 54% then became a 1 in 50 year event, but it would become a 1 in 1,000 year event if you had the whole millennium of data.

On the other hand, if your dataset is 38 years or less (like mine) it doesn’t include a 54% annual fall at all. Does this mean that you should try and get the largest dataset you can when deciding on where your risks are? After all, Big Data is what you need. The more data you base your assumptions on the better, right?

Well not necessarily. As we can already see from the November 1973 example, a lot of data where nothing very much happens may swamp the data from the important moments in a dataset. For instance, if I exclude the 12 biggest one day movements (positive and negative) from my 28.5 year dataset, I get a FTSE All Share closing price on the 18 July 2013 of 4,494 rather than 3,513, ie 28% higher.

Also, using more data only makes sense if that data is all describing the same thing. But what if the market has fundamentally changed in the last 5 years? What if the market is changing all the time and no two time periods are really comparable? If you believe this you should probably only use the most recent data, because the annual frequency of one day falls of all percentages appears to be on the rise. For one day falls of at least 2%, the annual frequency from the last 5 years is over twice that for the whole 28.5 year dataset (see graph above). For one day falls of at least 5%, the last 5 years have three times the annual frequency of the whole dataset. The number of instances of one day falls over 5.3% drop off sharply so it becomes more difficult to draw comparisons at the extreme end, but the slope of the 5 year data does appear to be significantly less steep than for the other datasets, ie expected frequencies of one day falls at the higher levels would also be considerably higher based on the most recent data.

Do the last 5 years represent a permanent change to markets or are they an anomaly? There are continual changes to the ways markets operate which might suggest that the markets we have now may be different in some fundamental way. One such change is the growth of the use of models that take an average return figure and an assumption about volatility and from there construct a whole probability distribution (disturbingly frequently the normal or log normal distribution) of returns to guide decisions. Use of these models has led to much more confidence in predictions than in past times (after all, the print outs from these models don’t look like the fingers in the air they actually are) and much riskier behaviour as a result (particularly, as Pablo Triana shows in his book Lecturing Birds on Flying, when traders are not using the models institutional investors assume they are in determining asset prices). Riskier behaviour with respect to how much capital to set aside and how much can be safely borrowed for instance, all due to too much confidence in our models and the Big Data they work off.

Because that is what has really changed. Ultimately markets are just places where we human beings buy and sell things, and we probably haven’t evolved all that much since the first piece of flint or obsidian was traded in the stone age. But our misplaced confidence in our ability to model and predict the behaviour of markets is very much a modern phenomenon.

Just turning the handle on your Big Data will not tell you how big the risks you know about are. And of course it will tell you nothing at all about the risks you don’t yet know about. So venture carefully in the financial landscape. A lot of that map you have in front of you is make-believe.

Needles and Pins 31 July 2013

31. July 2013 · Write a comment · Categories: Actuarial, Cartoons, Demographics, Economics, Pensions, Prediction

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