Wednesday, September 13, 2017

A US Missile Defense Architecture Solution Against a Rogue North Korean EMP Attack

In my previous blog entry on this subject, “Understanding North Korea’s EMP Threat” (1), I did an overview of the risk of the North Korean threat to use an Electromagnetic Pulse (EMP) weapon against the United States. The magnitude of the EMP threat was reinforced in a FOXNews piece by Hollie McKay who interviewed other experts in the field in her piece, “Millions of American lives could be at stake as NorthKorea threatens to attack power grid” (2).

The original piece also discussed the means of delivery available to the North Koreans and touched on defensive measures that could be undertaken to mitigate the threat. This installment will focus on architectural options to shoot down a warhead on the way to its target.

Reviewing the Basics of Ballistic Missile Defense

Ballistic missile defense is a game of layers; originally, five layers. They are launch detection, boost phase, mid-course phase, re-entry phase and terminal phase. These concepts initially emerged in 1984 during the US Strategic Defense Initiative (SDI) program. The architecture and strategy for US missile defense was codified as the “Imperfect Theory of Strategic Missile Defense”. While any single force element has strengths and limitations, the orchestration of the instruments yields a credible deterrent posture. The warfighting strategy weaved a layered architecture together that created a credible shift in the calculus of nuclear warfare.

In the case of that era, it helped push the process of managing global stability from the brinkmanship of mutual assured destruction to another path that eventually diffused and ended the Cold War. SDI was one of several building blocks of the Reagan era that finally did succeed in ending that war without a shot being fired. This central lesson of why one architects a missile defense system is a matter of national security once again of importance in the present with respect to North Korea.

For present day people who thought this Star Wars stuff was ancient history, without diving too deep into the numbers, lets have a peek at the old bidding.
  • We’re good at watching. Defense begins with knowing when a threat emerges. US launch detection systems are the best in the world, well actually, out of this world; many elements of these systems are space-based and able to detect missile launches anywhere on earth. The North Koreans cannot hide the ascent of an ICBM booster. Furthermore, several other countries also watch the goings in in North Korea obsessively. Early flight profile characterization is also straight forward. There are regular “after the fact” observation reports of North Korea’s test launches released to the public that are based on these observations.
  • The boost phase of a missile’s launch is the most vulnerable portion of its entire flight profile. It’s mostly a volatile pile of explosive fuel encased in a very thin shell; you don’t want beefy metal because every ounce costs in the energy budget to get an object into space. Make a hole in that shell and the thing explodes in a fireball. That’s pretty much what boost phase missile interception is. Limitations. You cannot easily chase a climbing ICBM with another missile. The ICBM is accelerating far too fast to catch up. You have to hit it either from above using a space based weapon or using a light speed energy weapon. Oddly, one of the posits of the precursor to SDI, High Frontier, did have the side effect of exploding nuclear weapons in space to burn missile boosters but that of course causes EMP’s and kind of defeats the purpose of defending against a single North Korean EMP weapon. I never liked that one. Just saying.
  • Mid-course interception is the phase of a missile’s flight when it is in orbit. It’s moving between 14,000 and 17,000 miles per hour at an altitude between 100 and 1,000 miles. Basically, it’s about shooting at objects in space. Today this is the domain of the US Navy’s Aegis cruiser and it gives the United States a credible capability to threaten a potential aggressor attempting to lob an ICBM at us. The Aegis does best as an anti-satellite weapon. The reason for that is that there’s one satellite and it’s usually alone in the sky. ICBM’s being thrown into that air in a rush are typically combinations of the warhead and a debris field. The bottom line is that you have to hit the right piece. That can be a challenge. Regardless, the US can hit things in space and that should worry the North Koreans because there’s a decent chance we’ll hit the right piece.
  • Re-entry engagement is also called high-endo atmospheric interception. The warheard is coming down from space. This is good for shooting at things because the friction of the air strips away the debris field and the target of interest is flying by itself; you only need to try to hit one thing, mostly. This is the domain to the US Terminal High Altitude Area Defense (THAAD) system, a Lockheed-Martin system with an impressive record of successful test launches. If it’s in position in the path of an incoming threat, it will be potent. Positioning is one key. The other is that the warhead actually descend into the high atmosphere. That’s kind of the annoying thing about an EMP weapon; depending on the yield of the warhead, it might not have to descend that far from orbital altitude prior to detonation; a height of 100 miles works for a hydrogen bomb class weapon. North Korea claims to have a hydrogen bomb class weapon. Still, don’t count a THAAD out. It’s known to hit things. It means the US can hit things, maybe even the right thing.
  • The final resort is terminal defense designed to protect a specific target from a warhead coming at it. There are a number of these defensive systems based on both missiles and lasers in service in the world today and they work admirably against tactical rockets, medium range missiles and even against artillery shells. The problem is that these objects are turtles compared to the approach speed of an incoming ICBM warhead. ICBM’s are freaking fast. They don’t really slow down much from their 7 to 9 kilometers per second orbital speeds when they come down. That’s a tough shot. Tough enough that I remember people proposing blowing up nukes to the north of missile fields during the cold war to create curtains of sand that would act like a belt sander cutting a warhead coming tough it to pieces. It wasn’t a very good idea. For one thing, you would blow up one nuclear bomb deliberately and risk a second one salvage detonating; plus, the complaints about the fallout would be horrendous. I jest. There are anti-missile technologies that are more promising and should continue to be developed to tackle threats emerging as nuclear capability proliferates to rogue states.

EMP Weapons: Not Your SIOP’s ICBM

Most nuclear warheads are designed to use kiloton to megaton blast and over pressure yields delivered very accurately, the term is center error probable; effectiveness is measured as Yield-CEP. Basically, they blow things up. These were the ICBM’s of the Cold War’s Single Integrated Operational Plan (SIOP); the force elements of the former Soviet Union’s Correlation of Forces calculus. They along with low yield tactical radiation enhanced warheads known as neutron bombs, need extremely accurate guidance systems to be effective. The North Koreans are nowhere near that precise in their ability to target weapons at ICBM distances.

EMP weapons are a different animal. They fry electrical equipment. EMP bursts are most effective when delivered using high altitude detonations. They do not require tight CEP accuracy. Somewhere over a target the size of a county or even a small state will suffice. Rudimentary missile guidance systems will suffice.

Orbital Weapons

ICBM flight profiles at extreme distances such as between a North Korean launch and an Eastern US target are not optimal. The weapon would be approaching at very low angles of approach by the time it arrives at the target; and more importantly, would have to transit the entire continental US and be subject to intercept for a large portion of its flight path.

It would be far more efficient to use an orbital weapon or a fractional orbit weapon to detonate an EMP weapon at the most effective altitude over the target. Range is unlimited and height over target geometries are easily achieved. You fire them to the south instead of the north meaning they will approach the continental US from the south, a relatively undefended frontier as far as incoming nuclear weapons are concerned.

Previous experiments with orbital and sub-orbital weapons were done by the Soviet Union in the 1960’s. True orbiting weapons were since outlawed by international treaty; however, sub-orbital weapons that do not complete a full orbit are technically legal, even if they are considered highly destabilizing. These so-called Fractional Orbit Bombardment Systems (FOBS) are less accurate than normal ballistic missiles but this is not considered a detriment for an EMP burst which relies mostly on energizing electrical connections sufficiently to overload and destroy components. The ideal detonation altitude is a trade off between the energy density required to fry the target’s wiring and the size of the geographic footprint one desires to affect. FOBS typically fly at low earth orbit satellite altitudes and speeds, roughly between 100 and 1,000 miles altitude at speeds of between 14,000 and 17,000 miles per hour. Development of FOBS weapons was abandoned by agreement between the US and Soviet Union as part of the negotiations for the SALT II Treaty in 1979.

FOBS profile weapon delivery basically stays at mid-course profile of missile flight; maybe a final dip into the high-endo atmospheric range at the end prior to high altitude EMP burst detonation. delves into the world of anti-satellite (ASAT) weapons systems. The interception of objects in low earth orbit (LEO) is not an unknown weapons technology base in this world. The United States, Russia, China and India have all done experiments intercepting LEO’s in the past with varying degrees of success. Acrimony over such experiments in the past had more to do with a successful test creating unwanted debris in space. However, given that a rogue state like North Korea may attempt to use orbital space for attack, these past experiments now become all the more valuable.

The missile defense problem is exacerbated for a FOBS weapon because, unlike orbital interceptions, the defender must solve the firing solution on the zeroth orbit. This means precisely detecting, acquiring, tracking, intercepting, assessing, and — if you miss — reengaging … FAST.

Architecting a Credible Layered Missile Defense for a Zeroth Orbit Intercept

The challenge for the United States is to be able to defend itself against a North Korean EMP missile attack. Let’s design something that will work.

  • First, the angles of attack available to North Korea are limited. The most important constraint is that the flight path of their missile must avoid overflying another country’s territory to the extent possible. This a rules of warfare thing. Overflying airspace is bad. It’s why cruise missiles are cool. They can be programmed to skirt international borders on their way to the target. To attack the US, North Korea has a direct ballistic missile approach across the Pacific and a fractional orbit lane shooting southeast via Guam, over Antarctica and approaching up the Atlantic from the south. The US must defend both approach vectors. It’ll require a little juggling but we have the resources to do so. The SDI optimization for this defensive puzzle involves three adjustments from experimental missile defense testing to transform to an operational credible certainty architecture.
  • The US must be able to maintain continuous real-time surveillance of the missile track regardless of where it is over the globe.
  • The US must be able to generate interception firing solutions as many times as possible along the missile track. Given that anti-missile interceptors are imperfect engagement weapons, I would recommend between five and ten intercept windows along the flight path. For the northern trans-Pacific ballistic path, a 30 to 40 minute transit time means position resources for a shooting window every 3 to 6 minutes. For the southern FOBS path, a 90 minute transit path bearing in mind an interception dead zone over Antarctica indicates shoot windows every 6 to 10 minutes during the first third and last third portions of the fractional orbit. Most of these firing windows will be over water which indicates US Navy Aegis cruisers or, alternatively, cobbled together interceptor ships with the radars, comm towers, pepper box launchers, and control centers on their decks. For the overland portions of the trans-Pacific flight, a mix of land based orbital interceptors (Aegis) and high endo-atmospheric interceptors (THAAD) within the CONUS with shoot windows separated every 60 seconds is not really unreasonable given the dire nature of the threat. It’s not deterrence opposite a rational foe; it’s combat against an irrational one.
  • The US should further be able to launch and guide multiple interceptors per firing cycle. There actually is no reason to rely on a single shot probability of kill per shot window. Tell the weapons manufacturers to optimize the firing solution procedures to shoot three closely spaced interceptors to arrive at the target slightly staggered so each follow on interceptor goes for anything that came out of the debris cloud of the prior engagement just before its arrival. Filling the sky so thick with flak you can walk on it is an air defense artillery technique that works.

The Net Effect is to Improve the Prospects for Global Stability

These architectural adjustments to the original SDI Imperfect Defense design increase the number of engagement encounters that an attacking ICBM must survive in order to reach a target in the United States on its zeroth orbit. Gaming the single shot probability of kill — Pk-ss — by compounding it as high as 30 intercept events en-route raises the cumulative probability that the US defense will prevail even using individually imperfect weapons. The mathematics should approach a confident degree of certainty. The main ground rule difference between this calculation and the one I did in 1984 is there were thousands of objects to deal with back then and only a few to deal with this time around. My present case net assessment? Doable.

More importantly, this approach uses force element components already available to the US Department of Defense. They can be strategically arranged to, as Secretary of Defense Mattis says, “handle the problem” regardless of which attack profile the North Koreans care to try. It means that if the North Koreans attack, the US actually does stand a good chance of defeating their attempt to place an EMP weapon into position to detonate over our homeland; that we’ll be unscathed.

This in turn generates new options to manage our response to a North Korean act of war. We can approach an attack maintaining a position of international leadership as a agent of the cause of global stability; a far better posture that retaliating as an enraged avenger of great national loss.

By being publicly credible that we are actively and forthrightly configuring our defenses to negate North Korea’s bluster, we will close off their irrational options and, in time, guide the North Koreans back to a path of interaction with the global community that is more productive.

I respectfully encourage the United States National Command Authority to consider these observations in the light of North Korea’s continued intransigence.


If a North Korean warhead in flight completes one orbit, it technically becomes a weapon in space that is banned by the Outer Space Treaty of 1967. The second it begins the next orbit, the US should be sending firing solution data to any other country that has an anti-satellite intercept capability to take shots at the thing as it begins to overfly their territories. We should insist that anyone we sell or give a missile defense system to agree to participate in a global shoot down after the zeroth orbit. Such an international cooperative agreement would send a powerful message to the North Koreans that the coalition against them will expand to the entire planet coming down on them roughly 90 minutes after they initiate such an act of war. That quite honestly, the North Koreans should be praying the United States succeeds in shooting their missile down.
About the Author
Dennis Santiago was the military operations research analyst responsible for originally authoring the theory paper on the “Imperfect Defense Theory of Strategic Missile Defense” that came to light during the 1984 US Strategic Defense Initiative Phase One Architecture Study. He also did work in the areas of US power projection, global stability and arms control policy. Since the the end of the Cold War, Mr. Santiago has concentrated his efforts on systemic risk analysis and solutions in the finance and banking sector.

1. “Understanding North Korea’s EMP Threat”,, Picking Nits, Dennis Santiago

2. “Millions of American lives could be at stake as NorthKorea threatens to attack power grid”,, FOXNews, Hollie McKay

Monday, September 4, 2017

Understanding North Korea’s EMP Threat

North Korea just issued a serious threat against the United States of America. 

Image result for us at night captured from space 

Few people outside the world of nuclear warfare military analysis have pondered electromagnetic pulse (EMP) as a strategic weapon.  It’s well understood and mostly dismissed in battle planning because military forces and command systems are specified to be radiation hardened against EMP.   But North Korea is not a conventional or rational foe.  They have telegraphed that they are preparing to engage in an asymmetric attack; not against the US military or government, but against the American people.

Their apparent weapon of choice is a high energy nuclear bomb designed to deliver an EMP burst from high altitude over the United States mainland.

The killing mechanism of such an attack is "elegant"; that’s my Cold War analyst past showing up as an encapsulating term. The EMP burst’s objective is to saturate the US power grid underneath it with energy flowing into the wiring.  The goal is to burn out a portion of the three hundred or so high voltage transformers that link the US together as an industrial age economy.  By burn out, that means causing the melting of the transformer cores rendering them useless.  Repairing such damage is cumbersome. There is only one plant that manufactures these types transformers in the US and it does not even make the biggest ones needed for the US grid backbone.  These have to come from factories in Europe or China and there’s a multi-year backlog for them.

Prior to North Korea's announcement that they have developed a hydrogen bomb designed for EMP use, most experts dismissed the danger arguing that North Korea's weapons were too puny.  This premise has been altered. One should never really underestimate the determination of a fanatical foe.

The eastern seaboard of the United States is presently the most vulnerable part of the country to such an attack.  It is our oldest electrical grid.   It is highly dependent on an interconnecting network of power generation sources supplying electricity to densely populated metropolises.  The long-haul lines are AC current based, a transmission method that makes them more susceptible to EMP.  And, despite many theory papers having been written on it, minimal investments have been made to harden this grid against man made EMP attack or the natural disaster version of the threat, solar coronal mass ejection (CME).  In strategic warfare planning terms, we are both vulnerable and susceptible to attack.

Caught unprepared, it may be possible to cut off major sections of the US mainland from electrical service.  This in turn means all utilities infrastructure breaks down as one of the world’s most electricity dependent regions goes dark for up the better part of a decade.  The human survival carrying capacity of these areas will drop dramatically, potentially catastrophically, resulting in suffering and death far beyond what we see in even the worst natural disasters.  Desperation would consume up to one hundred million people scrambling to survive at qualities of life one-tenth of the present.  Entire metropolitan regions and economic centers may/will collapse.  By the time we emerge, the US would not be the same as we know it today.

Take heart.  All is not lost.  The United States is not defenseless if we must “ride out” a nuclear attack.  Ride out; there’s another Cold War term I had hoped to not have to use again in my lifetime.  But here we are.

As can clearly be seen in the news, the U.S. Department of Defense "all cards on the table" posture has already begun to prepare an “overwhelming military response” option.   In the event that North Korea attacks, we will wipe them out.  Classically, this is the basis of rational credible deterrence.  Unfortunately, North Korea is more of an irrational foe.

To position their warhead for proper effect, their ICBM’s would likely have to fly a controversial fractional orbit bombardment (FOB) profile first developed by the Soviets in the 1960’s.  FOBS were considered dangerously destabilizing; enough that they were ultimately mutually abandoned by the United States and Soviet Union as part of the proposed SALT II Agreement in 1979.  Technically, FOBS weapons are not illegal though.  SALT II was never ratified.  The two countries merely set it aside. Like gun control in America, destabilizing nuclear weapons controls only apply to the abiding. By any stretch of the imagination, North Korea does not abide.

As to shooting the missile down.  Let me teach you something about the trained eye of a nuclear war planner.  Guam.  Guam lies to the south east of the Korean Peninsula.  A fractional orbit bombardment system attack feigning in the direction of Guam sets up an axis of approach to target the US mainland for a high-altitude detonation coming from the south.  North Korean test launches have been observed climbing to high altitudes. What does that tell you?  Defensively, the US has minimal ICBM warning or tracking capabilities for an attack from this direction. If I wanted to maximize the chances to pull off a Pearl Harbor type of attack, it would be the direction I would choose to take the shot.

OK, so tactically, maybe they think they’ve found an advantage. Unfortunate. Time to adapt and overcome. What next?  Clearly, we’re going to have to think about watching their available launch fan.  It’s a good thing we’ve got the best Navy on this planet. Maybe we'll get lucky and intercept the thing; although realistically, a FOBS warhead is not an easy target.  But if we can position a picket line to keep track of the overhead pass timing of these objects, there’s other stuff we can do.

We have procedures in place that we don’t practice very much to manage the exposure of our power grid to coronal mass ejection (CME) events.   These are also potentially devastating energy overload threats to the grid.  NASA watches a deep space network that watches the sun and issues warnings to power companies to curtail or shut down loads on the grid to protect it if needed.   It’s possible, if we put our collective Homeland Security minds to it, to set up a similar system to deliberately black out or decouple the US power grid in the event of an incoming EMP threat.  It’s not perfect because some things will fry regardless.  Little stuff can be replaced easily enough.  Our strategic goal here is to prevent a cascading catastrophic failure of our electrical grid.  If we can do that, we reduce our susceptibility and vulnerability to this rogue foe tremendously.

Investigating, certifying and exercising a near term threat mitigation defensive plan for the US mainland is deeply in our strategic national interest.  We need to be able to openly call the viability of North Korea's bravado into question on the world stage. We need to confound Kim Jong Un's regime to the point that it comes to its senses. We need to demonstrate to others that the United States knows full well how to defend itself when it has to. Doing so creates powerful leverage to rein in rogue states. That's the best path back to global stability.

The bottom line is that this planet does not need to tolerate this behavior by North Korea. The United States of America is in a unique position to bring this to an end strongly and peacefully without any mushrooms having to cloud this planet's skies.

We should consider doing so.

Thursday, May 4, 2017

Foreign Policy: Is the Pacific Rim a better place without a North Korea?

Tension has a way of rising to brinksmanship when it comes to North Korea. When you think about it, the world, and the nations of the Pacific Rim in particular have devoted an enormous amount of energy maintaining a war and conflict posture with respect to North Korea since the 1950’s. There was a time when such tensions were important, even useful, to the world. The 38th parallel was an extension of the Berlin Wall, an echo of a Cold War between the United States and the Soviet Union. Like its European Theater counterpart, it created a wall manned by cousins on both sides of the divide, pawns for a deeper political agenda. Like the other wall, one side flourished in an industrial miracle while the other languished in poverty. Time marches on. The wall dividing NATO and the Warsaw Pact has long since fallen but the wall across the 38th parallel remains.

When Kim Jong-un along with his cronies Premier Pak Pong-ju and Chairman Kim Yong-nam wag their swords, the world reflexively reacts. The tension created by a rogue state with a nuclear weapon in their pants certainly warrants worrisome attention even if the actuality is that government’s most potent weapon is its propaganda’s bark. We fear that the irrational may be willing to commit Armageddon suicide to get what they want. And quite honestly, reacting to it soothes the world’s need to have a villainous foil, a made to order actor for our political theater. On the eastern shores of the Pacific Rim, aging Cold War hawks validate their cognitive biases that the Red Menace is alive and well. On the western edges of the rim, nervous countries assess whether they need to reverse half a century of post-World War II demobilization and field new miniature Star Wars shields and other weapons systems thus incurring new economic and political costs.

It’s great stuff for the global news cycle, straight and alternate reporting inclusive. And it begs the elephant in the room question, “Is North Korea still necessary?” Does this intransigent wall across the 38th parallel need to be there at all? More specifically, does North Korea, the obstinate state, still have strategic utility to the future interests of the Northeast Asia?

Objectively, the answer seems to be no. The industrialized nations of the Pacific Rim region are at this point arguably universally better off bypassing North Korea to expand economic development among them. Among the compelling reasons,

Trans Pacific trade realities between the eastern and western edges of the Pacific Rim are evolving. The Unites States under the leadership of President Donald Trump is considering repatriating industrial infrastructure outsourced to overseas factories in the 90’s and 00’s. These factories will be coming home to a very different manufacturing reality that the one they left in the era before robotic automation and the micro-market customization power of CNC and 3D printed machinery. Robotic factories making components servicing a local to individual focused final packaging service base means less need for container ships transporting disposable goods from different parts of the world. There is an “Internet of Making Things” phase of industrial revolution coming to the United States and ultimately to all industrialized nations.

On mainland Asia, for China’s General Secretary Xi Jinping, it means his country needs to establish stronger bilateral economic trading relations to compensate for the reduction in US Trans Pacific trade in at least three areas of the Pacific Rim; these being, Northeast Asia, Southeast Asia, and Latin America. In Northeast Asia, the biggest industrialized market one can drive to from China is South Korea. Being on better economic terms able to trade goods, services and have a free flow of people between these two nations is strategically advantageous to both as it sets into motion a real basis for a future multinational economy on the Asian mainland.

It’s the kind of positive domino effect the western Pacific Rim could use. East Asia, if you look at it objectively, suffers from lingering echoes of a setting sun; meaning, the aftermaths of wars still color relations among nations. Russian President Vladimir Putin and Japanese Prime Minister Shinzo Abe struggle with unfinished business from the end of World War II in the Kuril Islands. The US and China similarly struggle with Taiwan. Further towards Southeast Asia, nations are still struggling with the aftermaths of various proxy wars from the Cold War fought on their territories. Theirs is a country level form of PTSD further down the road than the live shelling state of affairs the world presently witnesses going on in the Middle East. The point is that East Asia remains dominated by legacy military alliance models; it would be better if replaced by an economic union model. The most intransigent nation in the fray is North Korea. So how do you change that?

Born only at the end of World War II as Soviet and US forces took the Korean peninsula from the Empire of Japan, I am at a loss to name any reason the world’s national, trans-national, economic, or stability interests are aided by North Korea’s continued existence as a proxy war agent a quarter century after the demise of the Union of Soviet Socialist Republics and forty-five years after Richard Nixon opened the door to détente with the People’s Republic of China. It’s an anathema; an albatross. But as a recognized nation state, North Korea exists, persists, and its behavior worsens over time. How to mitigate the behavior of such a thorn?

Here’s a really bold move to ponder. How about threatening to remove nation status from North Korea? Technically, the Korean War is not over, it’s in an extended cease fire. Has anyone thought of reasserting the December 12, 1948 United Nations General Assembly acceptance of the report by the United Nations Temporary Commission on Korea (UNTCOK) that declared the Republic of Korea to be the only lawful government in Korea? This would administratively revoke recognition of the Democratic People’s Republic of Korea as a member state of the United Nations.

To do so would surely require the creation of a new United Nations Commission on Northeast Asia Stability chartered to explore recommendations to harmonize political and economic relations in the Korean Peninsula and surrounding areas. That commission could be stacked by a coalition of Security Council veto powered nations to add emphasis to the impetus to harmonize. Such a body could then call for and coerce a General Assembly affirmation of the 1948 UNTCOK report. From there it becomes a Security Council task to “handle the problem”.

I told you it was a bold thought. It’s aggressive negotiation to be sure. But if push comes to shove, a diplomatic pathway to collapsing a nuclear armed rogue state would certainly be worth it.

Thursday, April 20, 2017

A New Detente: Why Donald Trump and Vladimir Putin Need to Work Together to Stabilize Syria

Image result for us and russia

Planet Earth certainly has its share of global stability problems. One nexus of that problem is in the country of Syria.  Perspective on why this is so is often lost.  The truth of the matter is that the internal issue of Syria itself is inconsequential.  I know that’s a cruel thing to say but it just is when one looks at root cause of the problem.  Syria became a pawn in an oil war between Saudi Arabia and Iran. More specifically, Syria is the geographic point where two competing natural gas pipeline projects, one from the oil fields of the Saudi Arabia and the other Gulf States and one from the oil fields of Iran, must pass to get to the lucrative markets of Western Europe.

It won’t take anyone too much Googling to find out more but here’s the short version.  There are tremendous natural gas fields in the Middle East.  The Iranian pipeline’s plan routes from Iran through Iraq, Syria, and Lebanon before plunging across the Mediterranean to Cyprus before entering the natural gas distribution network through southern Europe.  The Saudi pipeline’s plans route from their gas fields through Saudi Arabia, Jordan, Syria, and Turkey before joining the other gas distribution network further north funneling into the European Union.  Whoever controls the natural gas supply into the EU, clearly will have massive leverage over the global economy for perhaps the next 50 years.   It’s the kind of leverage that can change the very cultural face of the planet replacing one definition of cultural civilization with another. It’s also financially lucrative beyond measure.   Bluntly, riches worth killing for.

What is the actual strategic interest of the Free World?

Here’s my short summary of how I look at Syria in context,

1. Harmonizing cultures.  It is in the interest of the Free World to neutralize the harmful animus between irrational warring parties whenever possible.  This is a critical focus if we are to extend periods of humanity that are peaceful and not wars or dark ages.

2. Regional stability. It is not in the interest of the Free World to allow two factions of a religion who have been quarreling with each other since the end of the Roman Empire to continue to use the northern Fertile Crescent as a proxy battlefield seeking to achieve disruptive influence over the remainder of the planet for either philosophical or economic means.

3. Global economic concerns.  It is further in the interest of the Free World to create conditions for global energy markets that are based on equal access by all suppliers into a fair and equitable supply and demand system.  The world is a more stable place when everyone shares in the interest to enforce equity.

There is a great opportunity to be had in Syria.  Since the breakdown of OPEC, the regional factions of the Middle East have been fighting a cruel proxy war seeking to prevent or delay the construction of each other’s pipelines. Their objectives are straightforward.  Eventually get their pipeline built and make sure that the other side never builds theirs.   The riches at stake are so high that these factions have been able to drag in superpowers as supporting actors to their myopic agendas.  The bottom line to all this is that it’s bullshit.  There’s no reason why this circus should be allowed to continue.  While this may be in the regional power’s interest, this status quo condition is not in the interest of the Free World.

Imposed Stability

While the world hesitates to commit to it, the correct answer for Syria is that a consortium of powers from the remainder of the Free World need to impose peace in Syria as a safe zone protectorate.  They must then inform the two factions of Middle East power that they must both build their pipelines through that safe zone.  It must be made clear that the flow of their natural gas will be contingent on their evolution from being 1,200 year old bickering cousins to finding a constructive basis for peaceful coexistence.  The global consortium must be willing to demand that the regional factions must show steady progress to bury the zealotry of their religious animus and, if unwilling, impose changes to see to it over at least a century of imposed change.  Let’s be realistic, any other solution will result in a return to chaos. Now, pretty much everyone who’s analyzed this part of the world already understands this.  It’s not really that hard to figure it out.  It’s pretty apparent that the tactical task at hand is to disrupt the perpetuation of the status quo; to change the path to something better.

Detente Redux

Sometimes you must face some hard facts.  The United Nations has become nearly useless as a pathway to peace in the Middle East.  It’s become Byzantium; a citadel for rear guard actions designed to perpetuate the hope that each faction might still succeed in achieving its self-interest outcome.   At the UN, the coalition of the unwilling is a force equal to that of the coalition of the wiling.  I do not like force on force conflicts based on positional parity.  It’s trench warfare that can only be fought to a stalemate.  It’s a solution that mostly guarantees that the carnage of the status quo goes on.  The bottom line is, barring some fundamental change to the UN design, it’s a dead end.  It’s vetoes as far as the eye can see.

This brings the interaction the national interests of superpowers option back to forefront of the world stability equation.  In Syria, that means the United States and Russia.  There’s tremendous opportunity here.  Both countries have been seeking parallel solutions to stabilizing the Middle East. I’m of a mind to argue that this parallelism is, at this point, artificial and unnecessary.

The artificial constraint I referred to is the fact that the US and Russia are caught in the web of the regional factions of the Middle East.  The US experience, going back the downfall of the Shah of Iran, has pushed it into the Saudi sphere of influence.  The Russian experience, ironically driven by the same Saudi tactic of collapsing the price of oil aimed at Iran that took out the Shah, has driven them into the Iranian sphere of interest.

Looking back, it should have been clear that the second coming of oil price collapse tactic failed with Iran because years of economic sanctions by the US against Iran had pretty much made them impervious to such an attack.  Such a thing only works if the opponent is vulnerable because they've lavishly overspent. The Shah had, the Ayatollah hadn't.  But the unintended consequence of derailing Vladimir Putin’s plans for the economic recovery of Russia, clearly a bad idea.  Honestly, it was kind of clumsy.

There is no good reason the US or Russia need to accept either’s current entrapment. There’s no reason Syria and or even Iraq should be doomed to remain the Kosovo of the Middle East. It’s possible to do better. But to do that, the overarching players need to work together to change the underlying hill and valley power matrix of the Middle East; that’s a technical term by the way.

The overarching case for a new détente manifests because the national interests of both the US and Russia overlap and intertwine closely.   This is as close to a textbook case as another time when mutual assured destruction as means to prevent World War III made the two countries quarrelsome, but intimate, partners in furthering global stability.  This is a practical matter that should be clear to both Donald Trump and Vladimir Putin.  Syria is an ideal place to establish a set of stable zone impositions.  The country is in tatters. There’s a need to purge Syria of a laundry list of destructive external regional interests. There’s an international interest to make the region a safe space to leverage the next investment in global energy infrastructure.

It'll take some resolve. You don't have to peel back the spin on the news very much to see that there are interests at work who do not want to see this grand coalition of the North come to pass.

The question really boils down to can these two men lead their respective countries to do the right thing together?

Thursday, July 12, 2012

Economic Recovery Means Learning to Export Unemployment

As the 2012 political debates turn inevitably uglier and important national issues become ever more politicized, it's important to ressurect the fact that the national interest does not recede merely becasue trill makes it less visible. -- Dennis Santiago, July 12, 2012.

Originally published October 27, 2011 in the Huffington Post:

One of the sad things about the state of the U.S. economic engine as it sits with the gearbox in neutral is that we seem unable to break so many bad habits.   For decades, we have exported jobs by outsourcing first manufacturing and then services gaining cheap goods by ultimately paying for them with the most precious trade good of all: quality of life.

We became addicted to a disposable economy based on strategic corporate principles like "a 100-percent replacement of the installed base every 10 years" and "just-in-time supply chains seeking the lowest mathematical cost of execution."    The engineering design principles for product development and maintenance have changed from the old hallmark of American-made durability to "buy it, use it, trash it," particularly in consumer goods where designed-in-obsolescence has been elevated to a business strategy.

The old joke about contracts being awarded to the lowest bidder has become our nightmare as it idles companies, their workers, the commercial real estate they sit on, the durable goods they invest in to manufacture things, and the secondary economic accelerators like housing, education and the rest of the infrastructure that defines the vision of the American way of life.

When I talk to bankers about this and ask them why they aren't lending to domestic commercial and industrial borrowers, they tell me they'd love to but there's no demand to borrow.  The bottom line is that U.S. businesses have so little faith in where the economy is headed right now that they don't want to take the risk of new debt.   And why should they if all that will happen is that their good efforts will get outsourced and come back as a cheap replica for half the price that lasts a third as long.  You math folk can work out how the lifetime value of the customer is boosted by that trick.   So the banks sit on excess deposits to lending ratios on their books, waiting for the day business owners believe it's time to put the engine back in gear again.   In the meantime, "Third World America."

This is a mess we made for ourselves, to be sure.  It was fueled by academic theories that valued the unfettered circulation of money far more than the preservation of culture and lifestyle.   And so sits one of the world's most important economies suffering from having mined out the hole of the disposable society to the point that it doesn't make a lot of sense to people anymore.  We spent our piggy banks on garbage, and it's bothering every one of us.  And not just in the United States.  Every other economy on the planet knows full well that since 1945, the world has needed a healthy and viable U.S. economy around which to organize and calibrate their socio-economic strategies.   We unhinge for an extended period of time, and it will have enormous complications for the human race.
But here's the thing.  What was done can be undone.  And personally, I think that the damage isn't that great.  My bet is that repatriating 5 percent of the U.S. manufacturing and services sectors will more than put the U.S. economy back on track, and that will have positive implications worldwide.
But how can it be done?   What American ingenuity can make this happen?  Here are a couple of ideas to ponder that will hopefully spark imagination and innovation.

It's time to shift gears away from the false god of disposability.  We should consider demanding changes in our engineering design and product-support strategy expectations.  What I mean by this is to retrain our industries and designers to emphasize aspects of products that focus on making products more durable and maintainable.  Or to put it another way, American-made quality again.   The jargon that goes along with this are things like "fault tolerance," "doubled mean times between failure," "designed for maintainability" and other techno-babble.   But what it ultimately does is change the balance on the products we use so that instead of buying and trashing three of them every seven years, more of them will be bought once and maintained for five years.   This restarts what used to be a healthy and viable repair-shop industry in this country that got blown away in the last couple of decades.

It's also a very green-conscious strategy, by the way.  The highest carbon emission cost for a manufactured good is the initial production event, so deliberately redesigning a fraction of our consumer products inventory to two carbon hits per decade, down from three to five per decade, is worth taking a look at.

And there's nothing that says cost and quality of production won't continue to improve even within such design guideline changes.   There's a whole new generation of technologies that, if applied creatively, can leverage one American worker to have the output equal to that of several overseas workers, possible even enough to equalize our folk to teams of other folk on a per capita GDP comparison basis.  That sentence means it will make economic sense for companies to choose to manufacture in the United States again.   Can you say improved aggregate quality of life?
Speaking of disruptive technologies that could change the foundations of many service industries away from outsourcing, I point out the parting gift of Steve Jobs.    His girlfriend SIRI may just be the solution we've all been waiting for instead of talking to some overseas call center that can't really help you, anyway.   And she's sassy.   The implications are tremendous.  I'd say tidal.  The question to me is: will we be able to reap it properly?

I'll close with a loud and clear challenge to academia.   One of the things the U.S economy desperately needs is for U.S. schools that teach engineering, business and public policy to begin to devote more research to this line of thinking.   A little disrupting the status quo from time to time is a good thing.  Earn your keep.  Push the edge in new directions.  Never mind occupying Wall Street; we need solutions for Main Street.

On Sensitivity to Market Risk, Susceptibility and Vulnerability

Reprinted with permission.

In this issue of The Institutional Risk Analyst, IRA CEO Dennis Santiago talks about the implications of the revelations about a rogue hedge fund operation at JPMorgan Chase.

It was a bit of a shock to me and many of our readers when the current trouble in JPMorgan’s derivatives desk erupted. Not because the vulnerability to this type of problem in the desks of these big banks was not there – IRA’s stress testing methodology has tracked off-balance sheet exposure as part of our CAMELS analysis regime for years -- but because I had not expected that this particular bank would be the one where this risk would first realize in the market place. In retrospect, that aspect of the letter S in the term CAMELS which stands for “sensitivity to market risk” is in fact uniformly distributed among the participants in derivatives market making and the susceptibility to a future beta event remains for any of them.

The question at this point is not whether the rest of the banks have this risk. The going forward questions are more appropriately, how should banks manage their susceptibility and vulnerability to this class of risk? How should insurers and markets price the risk-reward nature of such exposures? And in what direction should regulators aim the going forward definition of safe and sound practices?

IRA has commented a number of times in the past that we believe that risk and stress testing needs to be done in the context of benchmarking as opposed to the myopia of internally focused analysis. In this case, the need is even more acute given the fact that the banks (a) have trillions upon trillions of notional balances exposed and (b) bank counterparties view these derivatives exposures as material investments. So let us look at a catalog of banks so exposed. As is the case whenever it’s an IRA analysis, we winnow from a census of all the active banks and look at the individual FDIC Certificate holders. In this particular illustration of systemic vulnerability, the unit institutions with assets over $10 billion – the Dodd-Frank stress testing and reporting threshold – that have derivatives operations that reported a fair value estimates of the traded portion of their exposures in the 1st Quarter of 2012 reporting cycle.

Table 1 – Over $10B Asset FDIC Certificate Holders, 1Q2012
JPMORGAN CHASE BANK NA 63,650,436,000 6,735,675,000 70,386,111,000
CITIBANK NATIONAL ASSN 48,584,581,000 3,127,381,000 51,711,962,000
BANK OF AMERICA NA 40,110,943,370 6,229,087,191 46,340,030,561
GOLDMAN SACHS BANK USA 42,270,359,000 483,791,000 42,754,150,000
HSBC BANK USA NATIONAL ASSN 3,777,639,035 624,804,016 4,402,443,051
WELLS FARGO BANK NA 3,085,841,000 603,658,000 3,689,499,000
MORGAN STANLEY BANK NA 2,543,674,000 23,167,000 2,566,841,000
BANK OF NEW YORK MELLON 1,324,329,000 48,569,000 1,372,898,000
STATE STREET BANK&TRUST CO 912,454,345 6,075,991 918,530,336
PNC BANK NATIONAL ASSN 144,085,198 245,974,999 390,060,197
SUNTRUST BANK 212,838,953 54,670,445 267,509,398
NORTHERN TRUST CO 236,579,751 6,063,973 242,643,724
REGIONS BANK 126,481,777 23,191,409 149,673,186
U S BANK NATIONAL ASSN 69,801,437 42,854,555 112,655,992
KEYBANK NATIONAL ASSN 67,703,029 16,040,052 83,743,081
FIFTH THIRD BANK 46,571,169 22,149,571 68,720,740
BRANCH BANKING&TRUST CO 23,132,303 45,959,894 69,092,197
UNION BANK NATIONAL ASSN 40,620,251 10,150,020 50,770,271
RBS CITIZENS NATIONAL ASSN 29,700,353 7,884,815 37,585,168
BOKF NATIONAL ASSN 26,262,687 91,000 26,353,687
CAPITAL ONE NATIONAL ASSN 16,312,132 12,524,821 28,836,953
BMO HARRIS BANK NA 22,921,436 4,375,739 27,297,175
HUNTINGTON NATIONAL BANK 16,632,280 9,623,040 26,255,320
DEUTSCHE BANK TR CO AMERICAS 22,350,000 0 22,350,000
COMERICA BANK 13,346,622 2,384,148 15,730,770
COMPASS BANK 13,950,591 2,307,861 16,258,452
FIRST TENNESSEE BANK NA 12,575,654 7,009,789 19,585,443
MANUFACTURERS&TRADERS TR CO 15,476,745 1,987,079 17,463,824
BANK OF THE WEST 9,671,287 5,306,737 14,978,024
FLAGSTAR BANK FSB 12,541,133 68,954 12,610,087
WEBSTER BANK NATIONAL ASSN 7,557,676 812,904 8,370,580
CITIZENS BANK OF PA 5,909,044 1,659,980 7,569,024
PRIVATEBANK&TRUST CO 6,529,482 426,069 6,955,551
ASSOCIATED BANK NA 3,393,915 1,140,487 4,534,402
FIRST NIAGARA BANK NA 2,414,551 1,942,247 4,356,798
ONEWEST BANK FSB 21,000 4,188,151 4,209,151
ZIONS FIRST NATIONAL BANK 2,533,297 1,007,383 3,540,680
FIRSTMERIT BANK NA 2,498,353 248,033 2,746,386
FROST NATIONAL BANK 1,315,800 90,968 1,406,768
SYNOVUS BANK 1,420,627 337,803 1,758,430
RABOBANK NATIONAL ASSN 1,289,000 141,000 1,430,000
SILICON VALLEY BANK 1,086,802 281,065 1,367,867
FIRST NB OF PENNSYLVANIA 1,398,124 16,282 1,414,406
MORGAN STANLEY PRIVATE BK NA 580,857 436,198 1,017,055
FIRST REPUBLIC BANK 602,163 364,780 966,943
AMEGY BANK NATIONAL ASSN 575,434 129,561 704,995
CALIFORNIA BANK&TRUST 271,851 418,713 690,564
BANK OF HAWAII 538,673 147,407 686,080
COMMERCE BANK 73,942 557,407 631,349
WHITNEY BANK 616,524 0 616,524
ING BANK FSB 4,226 445,031 449,257
STATE FARM BANK FSB 215,171 0 215,171
SIGNATURE BANK 70,000 0 70,000

As can be seen, within this group, there are four large players followed by five medium sized players and then a collection of lesser – but still exposed – participants. All told, fifty three banks in this highly focused peering. Biggest of them in terms of the size of the notional derivatives book is JPMorgan Chase Bank N.A.
What is far more important to understand though is the context of the risk undertaken by JPMorgan versus this peer group. Was it extraordinary? Does analysis of it help us understand where the line of what is systemically unsafe might lie? For that we first turn to leverage. For this we look at the ratio of these institutions’ traded derivatives to the fair value envelope of these instruments as reported in their CALL reports. The resulting number is an indicator of “the amount of scrambling that is likely to have to happen in the event of a glitch in the Matrix”. The larger the total notional balance size combined with the leveraging factor help quantify the potential nightmare of each billion of realized loss. It’s the kind of thing that makes a Tums and Xanax a food group for Chief Risk Officers; maybe for corporate treasurers too.

Table 2 – Derivative Desk Operating Leverage Multiplier Estimates, 1Q2012
JPMORGAN CHASE BANK NA 153,680,000 458.0 14,706,574
CITIBANK NATIONAL ASSN 111,839,000 462.4 6,763,680
BANK OF AMERICA NA 45,531,246 1,017.8 6,120,369
GOLDMAN SACHS BANK USA 32,116,000 1,331.2 363,413
HSBC BANK USA NATIONAL ASSN 15,133,688 290.9 2,147,805
WELLS FARGO BANK NA 44,542,000 82.8 7,287,747
MORGAN STANLEY BANK NA 169,000 15,188.4 1,525
BANK OF NEW YORK MELLON 9,186,000 149.5 324,973
STATE STREET BANK&TRUST CO 7,400,437 124.1 48,953
PNC BANK NATIONAL ASSN 1,958,763 199.1 1,235,211
SUNTRUST BANK 2,155,245 124.1 440,464
NORTHERN TRUST CO 1,253,612 193.6 31,329
REGIONS BANK 988,166 151.5 153,113
U S BANK NATIONAL ASSN 1,558,409 72.3 592,822
KEYBANK NATIONAL ASSN 1,466,130 57.1 280,821
FIFTH THIRD BANK 2,026,473 33.9 653,158
BRANCH BANKING&TRUST CO 1,403,773 49.2 933,785
UNION BANK NATIONAL ASSN 1,944,329 26.1 388,711
RBS CITIZENS NATIONAL ASSN 1,829,382 20.5 383,777
BOKF NATIONAL ASSN 355,222 74.2 1,227
CAPITAL ONE NATIONAL ASSN 716,553 40.2 311,222
BMO HARRIS BANK NA 952,920 28.6 152,753
HUNTINGTON NATIONAL BANK 518,196 50.7 189,928
COMERICA BANK 863,140 18.2 130,817
COMPASS BANK 1,137,550 14.3 161,473
FIRST TENNESSEE BANK NA 263,981 74.2 94,481
BANK OF THE WEST 804,388 18.6 284,996
FLAGSTAR BANK FSB 83,122 151.7 455
CITIZENS BANK OF PA 388,152 19.5 85,127
PRIVATEBANK&TRUST CO 197,914 35.1 12,123
ASSOCIATED BANK NA 144,105 31.5 36,245
FIRST NIAGARA BANK NA 117,873 37.0 52,547
ONEWEST BANK FSB 203 20,734.7 202
ZIONS FIRST NATIONAL BANK 152,286 23.3 43,328
FIRSTMERIT BANK NA 116,959 23.5 10,563
FROST NATIONAL BANK 150,759 9.3 9,749
SYNOVUS BANK 152,092 11.6 29,218
RABOBANK NATIONAL ASSN 70,000 20.4 6,902
SILICON VALLEY BANK 21,521 63.6 4,422
FIRST NB OF PENNSYLVANIA 97,906 14.4 1,127
FIRST REPUBLIC BANK 27,201 35.5 10,262
AMEGY BANK NATIONAL ASSN 30,214 23.3 5,553
CALIFORNIA BANK&TRUST 9,426 73.3 5,715
BANK OF HAWAII 66,923 10.3 14,379
COMMERCE BANK 2,182 289.3 1,926
WHITNEY BANK 25,922 23.8 0
ING BANK FSB 22 20,420.8 22
STATE FARM BANK FSB 15 14,344.7 0
SIGNATURE BANK 115 608.7 0

Notice that there are a variety of strategies with regards to derivatives that begin to be exposed by this relatively simple calculation. There are institutions that clearly pursue very conservative approaches to these instruments and others that make use of them more aggressively. That’s not an unexpected result for anyone that has taken the time to understand that the pathways to operating a financial institution are not at all homogeneous, never have been.

Among the big four houses, there seem to be two schools of thought on this ratio, JPMorgan and Citibank electing to run their desks at one ratio and Bank America and Goldman Sachs operating at another one. It implies that a future beta event of similar magnitude as what beset JP Morgan would impact Citi similarly and the other two would have to scramble twice as hard. These are consequence management planning factors and are in fact most useful for costing how much to put into things like compliance oversight and risk taking authorization in the now so as to mitigate consequences if and when.

As one goes down the food chain the differences in strategy become broader straddling the middle ground of the big four with a few institutions electing higher leverage while most seek a more conservative path. Notable among these are the computed ratios of Well Fargo NA and Morgan Stanley NA which exhibit computational differences in the fair value estimates reported to the FDIC. Morgan Stanley basically says the balance sheet value is next to nothing. They may or may not be right but from a benchmarking standpoint, it is a real artifact in the numbers. A number of other smaller institutions also have this reporting approach.
Wells Fargo NA is notable because it pursues the most conservative leveraging approach even as the bank competes head on against its commercial banking competitors. In relative terms, the Wells Fargo desk would have to make a positioning error maybe five times the magnitude of what happened to JPMorgan to realize the same amount of turmoil. Interestingly, it indicates to someone like me to caution that Wells Fargo be the one most on guard against future complacency. Their competitors have incentives to be more hyper-diligent going forward and in the competitive space of derivative zero sum games, that means something.

Finally let’s look at how much of the real balance sheet is affected by these derivatives. Using the assumption that the traded leverage ratio is a fair indication of leverage in the remainder of the derivatives book, we can perform a CALL report based apples-to-apples estimate of the book value of these instruments. The caveat is that this analytical assumption may or may not be true but confirming this would have to involve performing a proprietary review to increase the fidelity of the calibration. Still, the question of just how much a derivatives desk impacts the overall portfolio of a bank is an important piece of information to have.

Table 3 – Portfolio Analysis of Estimated De-Leveraged Derivatives Value vs. Total Assets
JPMORGAN CHASE BANK NA 1,842,735,000 168,386,574 9.1
CITIBANK NATIONAL ASSN 1,312,764,000 118,602,680 9.0
BANK OF AMERICA NA 1,448,261,695 51,651,615 3.6
GOLDMAN SACHS BANK USA 101,927,000 32,479,413 31.9
HSBC BANK USA NATIONAL ASSN 206,808,958 17,281,493 8.4
WELLS FARGO BANK NA 1,181,817,000 51,829,747 4.4
MORGAN STANLEY BANK NA 67,651,000 170,525 0.3
BANK OF NEW YORK MELLON 229,715,000 9,510,973 4.1
STATE STREET BANK&TRUST CO 183,994,204 7,449,390 4.0
PNC BANK NATIONAL ASSN 287,766,197 3,193,974 1.1
SUNTRUST BANK 172,289,330 2,595,709 1.5
NORTHERN TRUST CO 91,340,913 1,284,941 1.4
REGIONS BANK 124,712,987 1,141,279 0.9
U S BANK NATIONAL ASSN 330,227,426 2,151,231 0.7
KEYBANK NATIONAL ASSN 84,838,858 1,746,951 2.1
FIFTH THIRD BANK 114,402,170 2,679,631 2.3
BRANCH BANKING&TRUST CO 169,026,116 2,337,558 1.4
UNION BANK NATIONAL ASSN 91,575,684 2,333,040 2.5
RBS CITIZENS NATIONAL ASSN 106,242,373 2,213,159 2.1
BOKF NATIONAL ASSN 25,733,983 356,449 1.4
CAPITAL ONE NATIONAL ASSN 133,000,029 1,027,775 0.8
BMO HARRIS BANK NA 94,826,410 1,105,673 1.2
HUNTINGTON NATIONAL BANK 55,584,664 708,124 1.3
DEUTSCHE BANK TR CO AMERICAS 39,839,000 1,755,000 4.4
COMERICA BANK 62,503,279 993,957 1.6
COMPASS BANK 65,360,552 1,299,023 2.0
FIRST TENNESSEE BANK NA 25,439,984 358,462 1.4
MANUFACTURERS&TRADERS TR CO 78,221,757 918,872 1.2
BANK OF THE WEST 62,342,865 1,089,384 1.7
FLAGSTAR BANK FSB 14,030,798 83,577 0.6
WEBSTER BANK NATIONAL ASSN 19,109,508 93,451 0.5
CITIZENS BANK OF PA 33,062,054 473,279 1.4
PRIVATEBANK&TRUST CO 12,587,678 210,037 1.7
ASSOCIATED BANK NA 21,617,331 180,350 0.8
FIRST NIAGARA BANK NA 35,463,055 170,420 0.5
ONEWEST BANK FSB 25,009,840 405 0.0
ZIONS FIRST NATIONAL BANK 17,179,085 195,614 1.1
FIRSTMERIT BANK NA 14,646,838 127,522 0.9
FROST NATIONAL BANK 20,472,031 160,508 0.8
SYNOVUS BANK 26,796,938 181,310 0.7
RABOBANK NATIONAL ASSN 11,646,000 76,902 0.7
SILICON VALLEY BANK 19,608,406 25,943 0.1
FIRST NB OF PENNSYLVANIA 11,525,969 99,033 0.9
FIRST REPUBLIC BANK 29,718,987 37,463 0.1
AMEGY BANK NATIONAL ASSN 12,005,462 35,767 0.3
CALIFORNIA BANK&TRUST 10,933,126 15,141 0.1
BANK OF HAWAII 13,760,753 81,302 0.6
COMMERCE BANK 20,370,170 4,108 0.0
WHITNEY BANK 12,813,700 25,922 0.2
ING BANK FSB 95,828,916 44 0.0
STATE FARM BANK FSB 14,455,112 15 0.0
SIGNATURE BANK 15,280,367 115 0.0

What reveals is a story of concentration risk. Of the fifty-three banks of this peer group, only four have derivatives as a proportion of their total assets exceeding five percent. One of them is JPMorgan Chase NA. Of the remaining three, Citibank NA is similarly sized. Goldman Sachs is its own unique investment banking model. HSBC Bank USA NA is a significantly smaller entity. Notable is that both Bank of America NA and Wells Fargo NA are the asset giants among a group that allocates between two to five percent of the portfolio to these instruments; the remaining banks live in the noise indicating hedging as opposed to investment or market making purposes for this asset class. A possible exception might be those banks that reported near zero fair values.

So in context let’s look again at JPMorgan Chase. It’s definitely the biggest operation dwarfing every other. While the business was run on the higher end of the leverage spectrum, it was not the highest model in operation. In terms of tangible exposure to the balance sheet, it is or was the segment leader. The combination of the three factors is the signature of high susceptibility to event risk and high vulnerability to significant stress in the event that risk manifests. In the end it was a mistake to have ever believed that mass and reputaion were that much protection against this type of risk. It’s a painful lesson to be sure and one that other banks should heed based purely an objective assessment of their own numbers in the context of these types of inconvenient truth benchmarks.

Questions? Comments?

Copyright 2012 - Institutional Risk Analytics - All Rights Reserved

Wednesday, March 16, 2011

FDIC Bank Assessments Change on April 1st as Dodd-Frank Comes to Banking

The Federal Deposit Insurance Corporation (FDIC) is the buck stops here office of U.S. bank regulation. Chairman Sheila Bair and company are checkbook behind the sign on every bank’s door sign guaranteeing that your deposit is FDIC insured. Funding America’s Deposit Insurance Fund (DIF) is done by charging banks an insurance premium. It’s this cash paid by the banks themselves that is supposed to maintain the DIF’s reserve. Come April 1st the rules for how banks get charged will be changing dramatically.

The FDIC approved 2011 Final Rule changes to 12 CFR 327. The rule is effective April 1, 2011, and will be reflected in the June 30, 2011 fund balance and the invoices for assessments due September 30, 2011. The final rule incorporates many policy changes based on the intent of the Dodd-Frank Wall Street Reform and Consumer Protection Act.

The most important change of all is in something called the “base assessment amount”. In the past this number was – and until March 30th is – the domestic deposits held by a bank. But as Dodd-Frank recognizes, banks have become more complex and leveraged. Most importantly, since the demise of Glass-Steagal, many of the larger institutions have incorporated the complexities of investment banking into their business models. The FDIC assessment methodology essentially gave a free ride to these aspects of a bank’s operations. Well come April Fool’s Day, the free ride is over. The “base assessment amount” changes to a new formula. From now on it’s the bank’s total assets minus its tangible common equity (TCE) that determines the base amount. I do note though that it’s actually the Tier 1 Capital that the FDIC will be using at first because despite the popularity of the notion of TCE by Wall Street, the Treasury and the Federal Reserve, no one’s quite sure how to properly calculate a TCE for an FDIC unit certificate holder just yet. We ran the computations both ways using IRA’s methodology for unit level TCE estimation just to confirm that the Tier 1 approximation is, as they say, close enough for government work. It is.

The no more free ride for investment banking policy slant of the 2011 rules is a huge shift. And yes it affects the largest complex banks most. We completed an estimation method – available in our Professional IRA Bank Monitor product – that looks at the change in assessment base and also implements the guidance of the new rule to estimate the DIF premiums. As with all IRA analytics, data is available for all 7,500+ FDIC certificate units plus 4,500+ bank-only components of BHC’s. Just for grins, we back computed “what would it have been” data for prior periods quarterly to 1995. Looking at this new mass of data we saw the following,

• Smaller banks that have traditional unleveraged business operating models generally see little change from the new rules.
• Mid-size and larger banks, over $10 billion assets, generally see an increase in their assessment base.
• Within the largest banks, the ones that are heavily involved in investment banking are most impacted by the new rules.

There’s also an important second point embedded in these new rules. The math for estimating risk category assignment is done using FDIC’s CAMELS scoring system. CAMELS stands for Capital Adequacy, Asset Quality, Management, Earnings, Liquidity, and Sensitivity to Market Risk. It uses privileged data and is sharable only between a bank and its regulator. For those of you that are old Basel II aficionados, think of it as “everything is IRB”.

So what’s the big deal about this?

The “2011 Final Rule” specifically states that the going forward process eliminates “the use of long-term debt issuer ratings for calculating risk-based assessments for large institutions”. The methodologies of the Nationally Recognized Statistical Rating Organizations (NRSRO’s) are no longer part of the process. This reduction in official dependence on rating agencies that failed to detect the last wave of systemic risks is also consistent with the intent of Dodd-Frank.

For our estimator tool, we used IRA’s public data “Shadow” CAMELS methodology we developed in 2009 as part of a contract to support the Securities and Exchange Commission to set up our Risk Category analysis. That contract requires us to compute these shadows for every bank unit and bank holding company in a timely manner every quarter. It turned out to be fortuitous for our look into the FDIC 2011 Assessment Rule. SEC specified we compute “Shadow” CAMELS to 1/10th’s and this allows our tool to pick off a point within the cap/floor limits of the assessment rate range specified in the statute to set up a better 2011 FDIC Initial Base Assessment Rate or IBAR. This refines the remainder of computations that depend on this number. Yes good people. That is math talk for the deep end of the pool. Translation to English = blah-blah-blah.