Reasonable enough. How about for the securitized loans?:

Losses for securities were next estimated by multiplying the outstanding stock of each type of security by the change in the market price of the relevant index over the course of a year. The average price change was obtained by weighting price changes for constituent indices comprised of different vintages and ratings by the issuance in each of these categories.

In other words, this is simply the first method described in the leveraged losses paper by Greenlaw et al. that I have discussed previously.

As the authors note, however:

The fall in market prices may be overshooting potential declines in cash flows over the lifetime of underlying loans.

I suspect that this overshoot is quite considerable. If we apply the 1.25% loss rate for unsecuritized commercial real-estate to CMBS, we reduce the projected loss to $12-billion from $210-billion. If we apply the unsecuritized sub-prime loss rate of 15% to the ABS & ABS CDOs, we reduce these projected losses to $225-billion from $450-billion.

Clearly, my calculations above (which reduce total projected losses from $945-billion to $522-billion) are completely pie-in-the-sky, back of an envelope approximations. That being said, I would like to see more discussion on why securitized loans are projected to have such huge incremental losses over non-securitized loans … preferably, a discussion including actual facts.

There's a very interesting point made on page 19 of the report, with its accompanying figure 1.17:

Some banks have rapidly expanded their balance sheets in recent years, largely by increasing their holdings of highly rated securities that carry low risk weightings for regulatory capital purposes (see Box 1.3 on page 31). Part of the increase in assets reflects banks' trading and investment activities. Investments grew as a share of total assets, and wholesale markets, including securitizations used to finance such assets, grew as a share of total funding (Figure 1.16). Banks that adopted this strategy aggressively became more vulnerable to illiquidity in the wholesale money markets, earnings volatility from marked-to-market assets, and illiquidity in structured finance markets. Equity markets appear to be penalizing those banks that adopted this strategy most aggressively (Figure 1.17).

We may well see a bigger charge - and more differentiated by issuer - for non-government AAA assets in the next Basel agreement! Table 1.2 shows that the market is already making adjustments to the relative level of its haircuts … but in proportions that bely the headlines!

I'm mainly interested in policy implications, however: one, which echoes the new FASB rules on QSPEs, is introduced on page 38:

Stricter rules are needed on the use of off-balance-sheet entities by banks, and disclosure should be improved so that investors can assess the sponsor's risk to the entity. Supervisors may need to strengthen guidelines regarding the circumstances under which risk transfers to off-balance-sheet entities warrant capital relief (see Chapter 2).

The executive summary of the report includes (on pp. xii - xvi) a number of short- and medium-term recommendations for future regulation and conduct. I'll be returning to this topic … eventually!

Update: This report - and the loss estimate - has also been noted on Econbrowser by Prof. Menzie Chinn.