And, while there is no desire to move away from the fundamentals of fair-value accounting, the Committee feels that it is nonetheless essential to consider promptly whether there are viable sound proposals that could limit the destabilizing downward spiral of forced liquidations, writedowns and higher risk and liquidity premia. The Committee is developing specific proposals for consideration in a timely fashion.
My reaction to recommendation #86 is mixed in the extreme!
86. Many investors relied on the rating when making credit decisions. More sophisticated investors were able to make their own assessments to a degree but many less sophisticated investing institutions relied on investment mandates where the rating was the paramount feature. The Committee finds that though rating agencies make their models available to investors, without detailed underlying loan-back data from the banks, additional information on stress testing and the underlying assumptions of the model, it is not possible for investors to verify the accuracy of the ratings models. It would in any case also be beyond the capacity of many investors to validate independently the rating agency models. More detailed loan data needs to be made more readily available and more information on stress testing particularly from a credit perspective will be released by the rating agencies, but for many investors the ratings models will remain a black box. Given this, ratings models should be subject to standards of independent review and external validation (akin to those in Basel II for Internal Ratings-Based Models).
OK … so I like the bit about making more data available. But I don't really care about whether or not it's beyond the capacity of many investors to validate independently the rating agency models … if it's beyond their capacity, they should get competent advice. And I really dislike the idea of subjecting ratings models to independent review and external validation.
Credit ratings are investment opinions, dammit! Take it, leave it, get other independent advice … but don't get the government or agency thereof involved in validating and reviewing investment advice. That's a road to ruin if ever I saw one.
Recommendation #88 is full of helpful little hints for investors to abnegate responsibility for their investments and ensure that credit ratings don't need to be understood as long as all the little boxes are ticked. Recommendation #89 contains such an absolutely priceless phrase that I'm going to quote it without further comment:
For example, the Market Best Practices might suggest that investors, making use of enhanced disclosures suggested elsewhere in this paper:
• Understand vehicles clearly, including the position of rated tranches and cash flows in the structure.
And as we proceed to #91, I'm so highly amused I can barely type:
91. Key issues that need attention at the level of the structured product include:
a. Quality of information provided in offer documents for structured products varies significantly based on the originating firm, country of origination and type of product. Offer documents can range from five pages to more than fifty pages and sometimes are difficult to read.
Awwww … the offer documents are sometimes difficult to read, are they? Awwww. Holy smokes, it should have become apparent by now that what the banks behind the IIF really want is a world of plain vanilla investments that banks can flog for high fees without anybody taking any risk.
All in all, a report more notable for its entertainment value than its contribution to debate.