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This is part 2 of Reggie Middleton on the government's Public-Private Investment
Plan. You can find part 1 here: Reggie
Middleton's Overview of the Public-Private Investment Program
Public-Private Investment Program
Impact on Lending
The program's aim to ensure that banks kick start lending is most likely overly
optimistic. The program's core premise that the banks are reluctant to lend
due to a overhang of legacy assets is based on a false assumption. The many
reasons banks are unwilling to lend - not withstanding a dearth of capital
- include fast deteriorating economic conditions, poor credit quality of borrowers,
increased risk aversion, and the tumbling prices of underlying assets. Banks
will continue to remain cautions unless, and until, the real economy stabilizes
or risk acting against the best interest of their shareholders (and their bonus
programs), defeating the very (stated) purpose of the program. Any program
which focuses only on securities without focusing on fundamentals that affect
the underlying assets (economic fundamentals) would fall short of its intended
purpose. Common sense from my perspective, but I've always been sort of different
so maybe I see things in,,, differently...
Lack of liquidity
The second basic premise of the plan's success lingers upon adequate participation
from private investors. Even based on the assumption of maximum leverage granted
by FDIC to everybody for everything that can possibly be purchased by anybody in
the program (6:1) private investors would have to come up with $68 bn of funds
(in this investor scary environment) to achieve the $500 bn target of legacy
assets and $136 bn to purchase the full stated $1,000 bn of legacy assets promised
to be leveraged into by the government. If the Fed's valuation committee is
just slightly more conservative in its valuation estimates and uses lower (but
more realistic, at least on average) leverage (ex. 4:1) granted to everybody for everything that can
possibly be purchased by anybody in the program, then private investors
would need to raise $188 bn to achieve the target goal of $500 bn and $375
bn to achieve target of $1,000 bn. Lest we show our short term memory propensity,
do not forget that there are $2 trillion+ of these assets out there, not $1,000bn!
So even with the government program maxed out to the fullest, we are still
touching only 50% of the asset pool, as the underlyings to these assets are
still in rapid descent.

Let me put this into perspective for you. The entire hedge fund industry is
currently only about $1.5 trillion in assets under management (with many of
those assets still fleeing as the lockups expire and the exit gates that were
thrown up last year to prevent a run on the fund start to open). Garnering
such an enormous amount of capital from private investors would require a significant
amount of time and persuasion that could significantly delay the process and
further depress the asset prices and the economy along with it. That is assuming
it can be done at all - after looking at and digesting the numbers above appear
to be increasingly unlikely. Despite all of these very real facts, the broad
market participated in the biggest rally ever, in the history of exchange traded
stocks in the US. What's next, see the graph here: Bear
Market Rallies Shake Out Weak Hands!
| (In Billions) |
$500 |
|
$1,000 |
| |
Legacy
Loan
Program |
Legacy
Securities
Program |
Total |
Legacy
Loan
Program |
Legacy
Securities
Program |
Total |
| $250 |
$250 |
$500 |
$500 |
$500 |
$1,000 |
Min Pvt
contribution |
Leverage |
6: 1 |
4: 1 |
|
6: 1 |
4: 1 |
|
| to make the plan |
FIDC / Federal Reserve |
$214 |
$200 |
$414 |
$429 |
$400 |
$829 |
| work |
Treasury |
$18 |
|
$18 |
$36 |
|
$36 |
| |
Private Investor |
$18 |
$50 |
$68 |
$36 |
$100 |
$136 |
| |
|
Max Pvt
contribution |
Leverage |
1: 1 |
1: 1 |
|
1: 1 |
1: 1 |
|
| to make the plan |
FIDC / Federal Reserve |
$125 |
$125 |
$250 |
$250 |
$250 |
$500 |
| work |
Treasury |
$63 |
|
$63 |
$125 |
|
$125 |
| |
Private Investor |
$63 |
$125 |
$188 |
$125 |
$250 |
$375 |
Risk and Reward in the PPIP!

Now, to be fair to Geithner, et. al., he (they) never declared the PPIP to
be a be all and end all. What he did state was that this was a method of facilitating
price discovery. It was to be bundled with a variety of other tactics, from
quantitative easing to forcing capital down the throats of banks that fail
government mandated stress tests. Well, looking at everything as a package,
it does tend to make sense. The caveat is that although I definitely see the
logic in the whole plan, the market seems to have misconstrued what I see as
somehow being positive for extant bank common and preferred shareholders -
NOT!!!! It may very well end up being a positive for the banking system, but
I wouldn't even buy a bank stock with YOUR money!. Now, on to the biggest potential
problem with the plan...
Possible loopholes
The plan specifically provides for the exclusion of SIVs (off balance sheet
Structured Investment Vehicles of banks) from investing in the bank's legacy
assets through PPIP by excluding affiliates
of banks participating in distressed assets. So technically a bank cannot
set up an SIV with a more than 10% stake and overbid for those assets.
However there is no such mechanism as such to prevent private investors to
engage in collusion and overbid for securities, risking tax payers' money since
both the parties stand to gain in such an event (out of this three party affair).
"Private Investors may not participate in
any PPIF that purchases assets from sellers that are affiliates of such investors
or that represent 10% or more of the aggregate private capital in the PPIF."
| Seller Bank A |
|
Seller Bank B |
| Face value |
100.0 |
Input |
Face value |
100.0 |
Input |
| Price determined by auction |
80.0 |
Input |
Price determined by auction |
90.0 |
Input |
| Current fair value in books, cents to dollar % |
60.0% |
Input |
Current fair value in books, cents to dollar % |
80.0% |
Input |
| Debt-Equity ratio |
6.0 |
Input |
Debt-Equity ratio |
6.0 |
Input |
| Debt FDIC Guaranty |
68.6 |
|
Debt FDIC Guaranty |
77.1 |
|
| Equity by private investor, Bank B |
5.7 |
|
Equity by private investor, Bank A |
6.4 |
|
| Equity by treasury |
5.7 |
|
Equity by treasury |
6.4 |
|
| Interest on FDIC Debt |
4.0% |
Input |
Interest on FDIC Debt |
4.0% |
Input |
| Fair value, cents to dollar %, actual at EOP |
25.0% |
Input |
Fair value, cents to dollar %, actual at EOP |
30.0% |
Input |
| As seller of Legacy Assets to PPIP |
| |
Bank A |
Bank B |
Gain on
sale to
PPIP |
20.0 |
10.0 |
| |
| Bank B (assuming it has purchased Legacy asset of Bank
A) |
| |
Value at EOP |
Gian (loss) |
Interest on FDIC debt |
Gain to equity investor |
Gain / loss to Private investor* |
%
return |
Gain / loss to Tax Payer |
75%
discount
on FV |
|
$25.0 |
($55.0) |
$2.7 |
($57.7) |
($5.7) |
(100.0)% |
($52.3) |
| |
| Bank A (assuming it has purchased Legacy asset of Bank
B) |
| |
Value at EOP |
Gian (loss) |
Interest on FDIC debt |
Gain to equity investor |
Gain / loss to Private investor* |
%
return |
Gain / loss to Tax Payer |
| 70% discount on FV |
|
$30.0 |
($60.0) |
$3.1 |
($63.1) |
($6.4) |
(100.0)% |
($56.9) |
| |
| Net Gain (Loss) Bank |
|
| |
Bank A |
Bank B |
Taxpayer |
| As seller of Legacy Asset |
$20.0 |
$10.0 |
|
<--As long as bid value is greater than economic value
banks stand to gain as seller |
| As Investor |
($6.4) |
($5.7) |
|
<--Maximum loss as pvt investor is only to the extent
of equity |
| Net Gain (Loss) Bank A |
$13.6 |
$4.3 |
($109.2) |
<--Maximum loss to tax payer virtually unlimited. Banks
stand to gain both from sale of legacy asset and as investor. |
In the model above (which you can download for free for your own use: PPIP
full model, with collusion and implied leverage 2009-03-26 01:00:41 202.00
Kb) we have assumed that Bank A and Bank B both participate in the PPIP
program. Current fair value of Bank A's asset are at 60 cents on the dollar
while Bank B's assets are at 80 cents on the dollar. However during the auction
Bank A's and Bank B's assets are sold at 80 and 90 cents on the dollar, respectively.
Bank A purchases Bank A's asset with equity investment of $6.4 while Bank
B purchases Bank A's asset with equity investment of $5.4. At the end of
period the actual value for these assets of Bank A and Bank B (originator)
were 40 cents and 60 cents on the dollar, respectively.
Although both the banks lost 100% of their respective equity under the PPIP
they were considerably better off (and I do mean considerably) selling each
other their legacy assets, (effectively, selling them to the Treasury) with
tax payers taking the ultimate hit. This should be safeguarded against. No
need to worry, unless bank management takes out this blogger in the near future,
I and my team will have our eyes out for such shenanigans. I can't guarantee
I will catch it, but I wouldn't bet against me, either!
The Implied 14x Leverage Effect
Jeff S. posted
the following comment on BoomBustBlog:
Am I mistaken in that the "Treasury Equity" is being funded by the remaining
TARP balance? If so, is this not a deceptive title in that this "Equity" is
really no different than the additional PPIP funds, and therefore, should
be classified as "Debt?" And if so, does this not make the leverage ratio
14:1 (84/6) and not the stated 6:1?
Me thinks we are being lied to again. But I could be wrong.
Please advise...
In response:
There are 2 parts of the plan - the Legacy Loan Program and the Legacy Securities
Program.
The Legacy Loan Program would purchase legacy loans through the Fed
Guaranty (limited to leverage of 6:1) and the balance would be contributed
equally between Treasury and Private Investor.
As a result under the assumption of maximum leverage (6:1 D/E) the effective
Debt/Equity for the participant is 13:1, or leverage of 14.0x. We have highlighted
the same in the structure, although probably not in the most lucid way, and
we believe that Fed has provided sufficient information on the same without
the intent of misleading the investment community,
| Debt / Equity* |
Contribution by FDIC |
Contribution by Treasury |
Contribution by Pvt Investor |
Every $100 Dollar Invested |
Effective D / E for Pvt Investor |
Effective Leverage |
| Contribution by FDIC |
Contribution by Treasury |
Contribution by Pvt Investor |
| 6: 1 |
6.0 |
0.50 |
0.50 |
86 |
7 |
7 |
13x |
14x |
| 5: 1 |
5.0 |
0.50 |
0.50 |
83 |
8 |
8 |
11x |
12x |
| 4: 1 |
4.0 |
0.50 |
0.50 |
80 |
10 |
10 |
9x |
10x |
| 3: 1 |
3.0 |
0.50 |
0.50 |
75 |
13 |
13 |
7x |
8x |
| 2: 1 |
2.0 |
0.50 |
0.50 |
67 |
17 |
17 |
5x |
6x |
| 1: 1 |
1.0 |
0.50 |
0.50 |
50 |
25 |
25 |
3x |
4x |
|