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Dept of Finance and Nama

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The Department of Finance's recent strategy statement indicates that it aims to increase employment, ensure sound finances, raise living standards, address the international debt and restructure the banks. In reality, it will do nothing of the sort as the document also indicates that the Department's role is simply to provide "independent, impartial and well informed advice" (and about time too). This mixing of altruistic goals and practical actions permeates the document.

For example, on Nama it states that the Department will "insist on the highest standards of transparency in the operation of NAMA, on reduction in the costs associated with the operation of NAMA, and that decision-making in NAMA does not delay the restoration of the Irish property market".  Sounds impressive but why didn't it simply state that it will extend Freedom of Information to Nama, cut outrageous fees paid by Nama and stop it trying to rig the market.

Letter published in the Irish Times on 12th May 2012.

As readers of this blog will know, I have been concerned about the accounting method used by Nama and have campaigned for more transparent accounts based on the par value of loans acquired (in excess of €71 billion) and full disclosure of written down/off loans and interest.

My campaign included writing to Nama's board, Minister for Finance, EU Commission (twice) and, more recently, the Comptroller and Auditor General (C&AG) and Public Accounts Committee (PAC). See Nama's Accounts and the Comptroller & Auditor General and linked items.

At its meeting on 1st December 2011, the PAC considered my correspondance and invited Nama and the Department of Finance to respond. In reply the CEO of Nama has advised the PAC that, having considered my suggestion that Nama publish "shadow" proforma accounts including a P&L and Balance Sheet based on the par value of loans, Nama, in consultation with the C&AG, "will provide such additional disclosure in respect of the movement in the par value of Nama's acquired loans in our 2011 Annual Report and Accounts". See Nama's letter dated 4th January 2012 to the PAC.

Hopefully, these disclosures will include "shadow" proforma accounts which will highlight the full extent of writedowns on the loans acquired at a huge discount by Nama. Ultimately, the losses could amount to €50 billion inclusive of this discount and related interest write offs.

The reporting of these losses by Nama would be a reminder (if one is needed) of the greed, recklessnes and incompetence of many of our leading developers, bankers, politicans and public officials and of the virtual total absence of "moral hazard", public enquiry and pursuit of possible wrongdoing.

More positively, the reporting will help increase accountability, transparency and openness and facilitate better oversight by the Dail and PAC of Nama's activities. It will also bring into focus the desirability, for the avoidance of doubt and to make matters crystal clear, of changing Nama's legislation to explicity state that maximising the recovery of original debts, over and above the actual cost of acquiring loans and recovering expenses, is an objective under Section 10 Subsection (2) (c) of the Nama Act.

Updates:

There has been some media coverage following publication of this entry:

Some additional comments:

1. What would be the impact on Nama's accounts?

Suppose Nama acquires a €100m loan for €30m and is repaid €30m after 3 years. Arguably, it has discretion, based on its current accounting method, as to how it allocates the sum received between principal and interest. For example, it could say that it has broken even on the loan, ignore the loss of interest and report breakeven before deducting its overheads.

If shadow accounts are created Nama would have to explicitly account for BOTH the capital loss (€70m) and contracted interest written off of, say, €12m (€100m at 4% for 3 years) making a total loss of €84m in contrast to breakeven. Henceforth, we could see headlines indicating that, while Nama might report breakeven using its accounting method, it will have incurred a massive loss in the shadow accounts. This loss would be a huge wakeup call to all concerned.

2. Will additional disclosure make a real difference?

Hard to say because Nama is really captive to future market and economic conditions. However, the reporting of the huge losses based on shadow accounts will highlight the need for Nama to recover the absolute maximum amounts from borrowers, minimise expenses, manage its assets effectively and "play the market" successfully when disposing of assets over the coming years. This will put pressure on Nama and its clients to perform to the maximum (rather than targeting breakeven) and might, just might, result in a lower eventual loss.

Over the past year, I have expressed deep concern about Nama's accounting methods to Nama's chairman and board, EU Commissioners and the Minister for Finance in a series of letters - see Nama and Creative Accounting for details.

My complaint is that Nama is using an accounting method which effectively "buries" the losses incurred (aka the "discount") on loans acquired from the covered banks.

The furore over the recent "discovery" of €3.6 billion in the national accounts is nothing compared with the "disappearance", I reckon, of about €50 billion (i.e. €50,000,000,000) within Nama's accounts. I understand that the Comptroller and Auditor General is considering the inclusion of this "loss" in Nama's accounts in some shape or fashion.

Against this background, I wrote to the C&AG on 1st November and suggested that, in the interest of openness and transparency, his office should consider producing "shadow" pro-forma annual accounts for Nama showing its acquired loans at par value and indicating the full extent of loan and interest write downs/offs. Here is a copy of my letter to the Comptroller and Auditor General

This proposal would help identify the full extent of the developers' bailout and losses incurred by the covered banks during the bubble years.

Nama's "forgive and forget" approach can be contrasted to the Government's treatment of mortgage holders who through unemployment etc. cannot meet repayments - see Debt Forgiveness Discrimination.

Update:

Having reviewed the full transcript of a meeting of the Dail's Public Accounts Committee with Nama and the C&AG on 26th October 2011, I have written directly to the PAC drawing attention to my letter to the C&AG and related correspondence. This was published at the PAC's meeting on 1st December and forwarded to the Department of Finance and Nama for comment.

Debt Forgiveness Descrimination

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The Minister for State for Finance Brian Hayes has said that writing off €6 billion of debt for tens of thousands mortgagees is unrealistic.  If so, how can his Government justify Nama writing off tens of billions of debt incurred by a thousand or so speculators?

Letter published in Irish Times on 23rd August 2011.

Banking Crisis: Help Us or We Default

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It is almost two months since my last entry. In the interval:

  • We've had a general election in which the Fianna Fail and Green parties were comprehensively rejected by the electorate in favour of a Fine Gael and Labour Coalition.
  • The Moriary Tribunal has reported and concluded that a former Goverment minister had accepted payments from a Irish businessman in return for helping to influence the outcome of a competition to award his company an extremely lucrative mobile phone licence. 
  • After over two years of drip feeding bad news and "kicking the can down the road", we are now approaching the endgame in relation to the banking crisis with the production of further stress test results.

This extended entry reviews the banking crisis and EU/IMF/ECB rescue package under the following headings:

        1. Depth of the Black Hole
        2. Putting the Cost in Context
        3. No Moral Hazard for Golden Circles
        4. Central Bankers were Asleep
        5. Default is Inevitable
        6. Irish Taxpayers Rescuing Foreign Banks
        7. Ourselves Alone or Kind Strangers
        8. Package Deal including CPT.

This entry conclude that in the absence of basic changes to the terms of the rescue package Ireland will be obliged to default. To prevent this outcome, it proposes changes to the package's interest rate, selective restructuring of outstanding bank bonds and temporary concessions on the politically sensitive, Irish corporation profits tax rate.

Saving Ireland

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David McWilliams in the Irish Independent on 8th January 2011 had an excellent piece on how he would save Ireland if he ever became Taoiseach. Here is a summary of his ten-step plan:

    1. Hold a referendum to confirm that the people wish to renounce the debts of Irish banks.
    2. Convert Ireland's bank debt problem into a euroland problem.
    3. Rescind the bank guarantee.
    4. Close Nama.
    5. Impose debt-for-equity swaps onto bank bondholders.
    6. Get the ECB to accept that it is unlikely to be ever repaid the €97 billion injected into the Irish banking system.
    7. In due course, convert the funds owing to the ECB into bank equity.
    8. Make domestic mortgages "non-recourse" and simplify the bankruptcy laws.
    9. Extend the vote to all Irish citizens no matter where they live.
    10. Draw on some of the $800 billion deposited in the IFSC to help rebuild a New Ireland. 

These proposals co-incide with views expressed here, for example, close Nama, reject the bailout, terminate the bank guarantee and use debt-equity swaps to recapitalise the banks.

How to Resolve the Crisis

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The Government should invoke force majeure and immediately introduce legislation to halve the salaries and pensions of all highly-paid people in the public sector and dispense with all special entitlements.

It should signal that it will aggressively contest any attempts to frustrate these actions. They must be fully implemented before the budget to ensure that, unlike previous budget announcements on pay and pension cuts for ministers and senior civil servants, they will not be watered down or reneged on. Such a move, backed by the Opposition, would demonstrate leadership to citizens and financial markets.

From this high moral ground, the government should then negotiate pain-sharing with bondholders alongside the introduction of a bank resolution scheme; nationalise both main banks; pull back on Croke Park Agreement; finalise the four-year plan; secure support for the 2011 budget; and hold a general election. All these things could be done by next spring when Ireland could re-enter the bond market with a much stronger investment case and brighter future.

Lead letter published in the Sunday Business Post on 14th November 2010.

Nama and Creative Accounting

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This entry might appear technical but it involves tens of billions and gets to the heart of Nama's role and activities.

As explained in its second business plan (June 2010), Nama has adapted an accounting method (Amortised Cost - Effective Interest Rate) which is based on expected cash flows rather than contracted cash flows. This has facilitated the "disappearance" of some rolled up interest and enables it to massively write down the value of loans acquired from the covered institutions from the very outset.

Use of this method is misleading and diverges very significantly from that signalled in Nama's original business plan (October 2009) in the following respects:

  1. It excludes rolled-up interest accruing after it acquires loans from the covered institutions. This could amount to €10.9 billion over the eleven years commencing 2010.

    As evidence of this, Nama's original business plan provided for interest income of €9.46 billion in the budget projections (Table 7 on page 12) for the three years commencing 2010 as compared with cash interest income of only €4.5 billion for the same period (Table 6 on page 10). The difference of €4.96 billion is rolled up interest which disappears, thanks to the accounting methodology.

  2. The original business plan indicated in a bullet point accompanying the 11-year cash flow projections that "of the €77 billion nominal value of loans acquired, €62 billion will be repaid by borrowers and that loan defaults or debt restructuring will occur on €15 billion (a rate of 20%)". This implied that Nama would be accounting for these transactions via Profit and Loss accounts. Clearly, this is not happening.

Nama's use of creative accounting effectively buries about €50 billion of losses comprising €40 billion of loan write offs and €10 billion of uncollected rolled up interest. This has two significant implications as follows:

  1. It becomes much easier for Nama to report an illusionary "profit" when wound up. It also made it possible for the Irish authorities to claim that Nama was the best solution to Ireland's banking crisis.

  2. With the stroke of the pen, Nama is effectively forgiving about €50 billion of debts. Where is the "moral hazard" and justice in this when, based on Nama's creative accounting, every billion euro of discount on the loans being acquired is immediately written off to the benefit of borrowers?

    Repeated suggestions by the Minister for Finance and Nama that it will pursue debts to the "greatest possible extent" must be taken with a pinch of salt as they don't even appear in Nama's balance sheet or form part of Nama's core objective.

Against this background, I wrote to Joaquín Almunia, EU Competition Commissioner, on 17th September last. Here is a copy of my letter which explains my issues and concerns in more detail. It also contains proposals to make Nama more transparent and accountable. I will post the Commission's reply if it comprises more than an acknowledgement.

This was my second letter to the Commission - the first one (17th December 2009) which deals mainly with rolled-up interest can be seen here. The Commission's reply was just a lengthy acknowledgement. 

I also wrote an  open letter to Nama's board on this matter. This was done prior to the change in Nama's accounting method which confirms (to me) that Nama is consciously forgiving tens of billions of borrowers' debt by failing to comprehensively account for it in its accounts. The Minister for Finance replied to a copy of the letter and assumed that Nama would also do so - it didn't. I suppose Nama's replied indirectly by changing its accounting method to bury its bale outs!!!

Nama could become toxic dump

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The Government set up Nama to help rescue the banks and get credit flowing. We were assured that it would make a profit for the taxpayer without disrupting or distorting markets or bailing out developers. Nama's short history suggests that it is unlikely to achieve these objectives because it is paying well above market rates for loans; the proportion of performing loans is much lower than projected; banks are transferring fewer good loans; and discounts are far higher than expected due to poor security and documentation.

For these reasons, Nama could become an expensive toxic dump rather than a well-balanced asset recovery vehicle as originally envisaged and it would become part of the problem rather than the hyped solution.

To head off this possibility, the Government should immediately introduce a bank resolution scheme. Once in place, Nama should hand back all its loans to the originating banks and bondholders and let them jointly deal directly with borrowers without involving long-suffering taxpayers.

In contrast to the Government's tip-toe approach, the hand back should be accompanied by focused guarantees, selective defaulting and debt-equity swaps leading to the creation of "good" banks and work-out institutions.

Letter published in the Sunday Business Post on 19th September 2010.

Nama Accounting Methods

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I wish to draw attention to Nama's accounting policies which have attracted little comment but have huge significance for taxpayers as the cost of the banking bale-out rises.

Specifically, Nama has decided to use a methodology which allows it to immediately write off about €40 billion of the €81 billion of loans being purchased from the banks and to ignore related interest, amounting to about €10 billion. This means that, with a stroke of the pen, Nama is forgiving about €50 billion of developer debts and, of course, making it much easier to report an illusionary "profit" when wound up.

Where is the "moral hazard" and justice in this when, based on Nama's creative accounting, every billion euro of discount on the loans being acquired is effectively a billion less to be paid by developers but a billion more to be pumped into the banks (mainly by taxpayers)? Suggestions by Nama that it will pursue debts to the "greatest possible extent" should be taken with a pinch of salt. As they don't even appear in Nama's balance sheet, where is the pressure to collect them?

Nama should be obliged to show the original value of the loans being acquired in its balance sheet and to properly account to taxpayers for bale outs and write offs when all methods of recovery have been exhausted.

Letter published in the Sunday Business Post on 22nd August 2010. For more on this topic, see this Open Letter to Nama's Board and the related blog entry.

Nama Business Plan - 1

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I wish to make the following points about Nama's new business plan:

  1. At best, it is a "concept plan" describing operational arrangements, short-term work plan and structures. It may be a plan but it is not a business one.

  2. Considering that it relates to a loan portfolio of €81 billion, it includes no pro-forma projections and its financial forecasts are confined to a simple 4x4 table containing only nine values summarising Nama's activities for three scenarios over the next ten years! 

  3. The plan indicates that Nama will use the amortised cost method of accounting. This ensures that the true extent of the bale out and foregone interest, exceeding €40 billion, will not appear in its accounts.

  4. Nama says that it will take a neutral view on future property prices, will not engage in speculating hoarding and will wind up in just seven-ten years. This points to a short-term, uncommercial approach and to fire sales, negating a key reason for setting up Nama.

  5. Nama's intention to pursue debtors to the "greatest possible extent" really only refers to recovering the cost of acquiring loans from the banks rather than to the much higher nominal value of the loans owed by developers.

In contrast to its own plan, Nama is seeking extremely detailed business plans from its debtors and its recently published quarterly financial report contain dozens of pages of tables. Clearly, Nama's approach is to disclose as little as possible about future prospects and intentions but endless detail after the horse has bolted. This resembles the "everything is fine" strategies of the banks that it is meant to be rescuing.

Letter published in the Sunday Business Post on 11th July 2010.  For a more detailed assessment of Nama's plan, see Nama's New Business Plan

Nama's New Business Plan

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Nama's latest so-called business plan (dated 30th June 2010) is by no stretch of the imagination a business plan in the accepted sense of the word. At best, it is a "concept plan" describing proposed operational arrangements, short term work plan, organisational and corporate structure along with a review of progress and series of statements relating to accounting matters, proposed operating principles and similar. It may be a plan but it is certainly not a business one.

The plan is remarkably short on numbers for a business plan linked to a loan portfolio of €81 billion. There are no operational or financial projections of any note and no pro-forma projections of any kind. Clearly Nama has learnt from the poor reception given to its first business plan (October 2009) that the fewer the numbers it supplies the better (for it).

Our comments on Nama's first business plan include the following:

In the latest plan, financial projections are confined to a simple 4x4 table containing just nine (yes, nine) values presenting the net present values of Nama's activities over the next ten years for three scenarios i.e. it offers a mere three values per scenario.

Given that Nama will be taking over loans amounting to almost half of Ireland's GDP, its business plan should, at a minimum, have included "scenario-based" P&L statements and balance sheet projections as well as cashflow forecasts for the ten years along with explicit and clear assumptions. These would have given a fuller picture and facilitated analyses which might have helped anticipate problems identical to those being experienced by the banks that Nama is seeking to rescue. For more on this, see my Open Letter to Nama's Board.

Some specific items in the new plan that caught my attention:

  1. It is even less transparent and useful than the initial draft. After the draft was published, I had thought of sending Nama a copy of Free-Plan, a business plan template available for free download from the PlanWare website. It has over 0.25 million registered users covering a huge range of industries etc. If anyone from Nama is reading this, they can download Free-Plan using this link http://www.planware.org/freeplan.zip It would not take much effort to adjust it to suit Nama and would result in vastly improved plan both as regards scope, structure and content.

  2. The new plan indicates that Nama will operate as an "independent commercial entity". However, it also states that its life will be seven-ten years (as determined by the Minister for Finance!). This is much too short a time frame for Nama to realise an optimal return for taxpayers - the chances are that Ireland will still be in the "recovery ward" after the 2008-10 recession and Nama will be selling off properties or doing deals close to the bottom of the cycle.

    Strangely, the plan indicates that "NAMA will not engage in any speculative hoarding of assets. Strategy will be shaped by a neutral view as to future market movements on a portfolio basis". This strategy is completely un-commercial and will ensure that third-parties, rather than taxpayers, will get the greatest benefit from any upswing in the property market as we approach the 2020s.

  3. The plan states that "Nama will pursue all debts owed by debtors to the greatest possible extent" on page 2, 7, 8 and 10. It also says that "debtors will continue to be liable to Nama for full loan balance recovery of €81 billion" but that the recoveries assumed in its NPV projections are based on the amounts that would be recovered if NAMA foreclosed on debtors and underlying assets had to be realised by reference to the long-term economic value of the assets".

    This all means is that Nama's "official" debts only relate to the actual payments made to acquire loans from the covered institutions rather than to the nominal value of these loans. In other words, Nama does not appear to be officially expecting (or demanding) any payment of the haircut on these loans with the result that its debtors could be securing a bale out of up to €40 billion (based on the 50% discount being paid by Nama for the loans). This view is confirmed by looking at the accounting treatment of the loans (€814 million nominal) from EBS and INBS which were taken into Nama's balance sheet (at €371 million) during the first quarter of 2010 (see page 17 and accompanying note in Nama's quarterly financial statements for period ended 31 March 2010).

    This huge "forgiveness" of debtors i.e. bale out for developers, merely merits a note in the accounts. At the very least, Nama should show the nominal value of the loans up front in its balance sheets and clearly indicates write off as they arise.

  4. Nama is adopting an accounting policy (page 18) which "considers expected cash flows, not contractual cash flows, on loans. This means that the Profit & Loss account will reflect what is happening in reality in cashflow terms, rather than taking income to the Profit & Loss account that is not cashflow-based e.g. NAMA will not accrue interest rollup to its Profit & Loss account. It reflects an accounting approach which values the loans by taking the 'actual' initial value plus future expected cashflows less potential impairments."

    However, it also means that Nama will be effectively writing off almost all rolled up (or unpayable) interest arising over the next ten years! Based on the draft business plan (October 2009), we estimated that write offs of rolled-up interest could amount to €11 billion over the ten years to 2020 - see Nama - The "real" Default Rate for more on this.

    The latest business plan indicates that only about 25% of acquired loans will be income producing (as compared with 40% estimated in the October 2009 plan) and suggests that our original estimate for rolled up interest write offs is very conservative.

  5. The discount rate used in the scenario projections in the business plan was 5.5%. This is much too low to cover the risks facing Nama. For example, the October 2009 plan indicated that the NPV (using a 5% discount rate) for its activities over the ten years to 2020 would be €4.8 billion. The base case in the latest plan suggests a lower NPV of €1 billion.

    When account is taken of the plan's expectation that Nama's operating costs will be €1.04 billion lower than originally envisaged, there has been deterioration in Nama's projected profitability of about €5 billion in the space of just nine months. Proof positive that Nama is not risk-free and that a much higher discount rate should be used.

  6. The projected NPV in the new plan for Nama's activities over the ten years is €1 billion (scenario A) as compared with €4.6 billion in the initial plan.

    If, for simplicity, we ignore the the effect of discounting and simply add back the €2.64 billion expenses to the projected NPV in the initial plan we get a value of €7.44 billion representing the total projected contribution to Nama's expenses and "profit" over the ten years. If, for the new plan, we add back the updated forecast of expenses (reduced to €1.6 billion) to scenario A's NPV, we get €2.4 billion. The difference (€5.04 billion) is a indicator of the deterioration in the outlook for Nama's activities in just nine months. If this trend were to continue then Nama is in real trouble.

  7. Given the inadequacy of Nama's published business plan, I wonder does it have a different one for internal use and, if so, is it clearer or different? In either case, surely it should have been published? How acceptable is it for Nama to have two separate plans but keep one hidden? Surely, there should be only one plan. 

Where is the openness and transparency?

Its not there and, worse still, there are clear signs that Nama is striving to bury losses of up to €50 billion (haircut plus interest write offs). In contrast, it is seeking extremely detailed business plans from its debtors and the statuary financial reports covering its first three months operations contain dozens of pages of tables.

Clearly, Nama's strategy is to disclose as little as possible about future prospects and intentions but endless detail after the horse has bolted. This is no way to run an organisation that could end up costing taxpayers tens of billions and resembles the "in denial" strategies of the very same banks that it is meant to be rescuing. 
 

Moral Hazard

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The Honohan Report said there was a ''moral hazard'' involved in the blanket bank guarantee, ''though this argument does not appear to have been made''.

The chairman of Nama and the Financial Regulator have recently suggested that it would not be possible to assist people with distressed mortgages, due to ''moral hazard''.

So where is the moral hazard for the politicians, administrators, bankers, developers and related professionals who created the financial crisis, but continue to hold positions of power, draw huge pensions, operate insolvent businesses and get massive bailouts, courtesy of taxpayers?

Letter published in the Sunday Business Post on 27th June 2010.

Nama's Mission Creep ?

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Recent comments by Nama's Chairman suggest that it is moving the goal posts and is no longer going to do what it was set up to do, namely, to recover as much as possible of the loans transferred to it from the banks.

Instead, it appears that Nama is going to only recover what it is paying for these loans plus its expenses and that it intends to wrap up this process in seven to ten years instead of the original ten to fifteen years.

On this basis, Nama could be writing off, or forgiving, about €30 billion of debts as well as substantial unpaid interest.

Letter published in the Sunday Business Post on 20th June 2010. See also, the Open Letter to Nama's Board which discusses this matter in greater detail.

Open Letter to Nama's Board

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I've sent this Open Letter to Nama's Board expressing concern that Nama appears to be scaling back its original mission at a potentially enormous cost to the taxpayer. Basically, it appears that Nama may be moving the goal posts and engaging in mission creep.

While I fully accept that no plan "survives first contact with the enemy", the Nama concept and its original business plan were prepared following extensive studies commissioned by the Minister for Finance into the loan portfolios of the banks. It appears that these expensive studies all missed the fact that loan documentation was poor, security was not properly charged, debt/equity ratios of many borrowers were ridiculously high, assets were being pledged as security on multiple loans, loans were being restructured or interest only. Also, where were the banks' internal/external auditors, non-executive directors and legal staff/advisers during this carry on? It is very hard to accept that no one had any insights into the real condition of the banks' property-related loan portfolios.

If Nama's mission is to be changed, I think that, in the light of changed circumstances, it must  toughen its approach to securing repayment of the €80 billion of loans being taken onto its books instead of watering down its targets and reducing its life span at great cost to the taxpayer, economy and society.

UPDATE - 1

The Chairman of Nama has, when speaking at the CPA's Annual Conference on 4th June 2010, sought to clarify Nama's core objectives in the following terms:

NAMA's core commercial objective will be to recover for the taxpayer whatever it has paid for the loans in addition to whatever it has invested to enhance property assets underlying those loans. This objective has not been determined by NAMA; it has, in fact, been set for us by the legislature under Section 10 of the NAMA Act. There has been some comment that the consequence of this objective is that NAMA, having recovered its outlay, will then absolve borrowers of their further obligations. This is absolutely not the case. Borrowers, as both I and NAMA's CEO Brendan McDonagh have already said on a number of occasions, will continue to be liable for the debts that they have incurred.

He also says that "NAMA is expected to have a lifespan of seven to ten years and when, in the view of the Minister for Finance, it has made sufficient progress towards achieving its overall objectives, it will be wound up." His full speech is here.

The Chairman spoke of reserving the right to recover arrears if a borrower regains the capacity to repay debts. It may be appropriate for Revenue to follow this route in respect of a tiny proportion of its clients but in Nama's case arrears could amount to half of all borrowings! This highly qualified, weak-kneed approach simply confirms the perception that Nama does not really intend to pursue borrowers for all their debts. It would be interesting to know whether the business plans being prepared by borrowers are intended to explain how all borrowings are going to be repaid or merely enough to enable Nama recover its costs. If the latter, then it is clear that Nama expects to write off huge debts (€30 billion or more) at the expense of the taxpayer. Finally, all the signs are that any economy recovery is going to be extremely slow and consequently Nama, by foreshortening its life by up to eight years, could miss an upswing in the property market at great loss to the taxpayer and gain for its delinquent borrowers.

Notwithstanding the Chairman's clarifications, I still take issue with Nama's core objective as being too limited and too short term as stated in my open letter to the board. 

Section 10 of the Nama Act dealing with the purpose of Nama was mentioned by the Chairman. It refers back to Section 2 which states that the Act's purposes include protection of the taxpayer and contributing to social and economic development.

Maybe, to make things crystal clear, Nama should state that maximising payments of all debts, over and above the cost of acquiring loans and recovering its expenses, is an explicit objective under Section 10 Subsection (2) (c). This would help minimise any misunderstandings amongst taxpayers or Nama's borrowers and ensure that Nama is not wound up by the Minister for Finance as soon as it breaks even or that borrowers' business plans merely target Nama's breakeven point.

Nama is Bailout for Builders

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The headline on page one of last week's Markets stated "€5.5 billion-worth of mortgages now in arrears". This doesn't include the many thousands of mortgage holders with restructured loans or the hundreds of thousands being locked into negative equity amounting to €10-15 billion. Page two of Markets indicates that the Minister for Justice has ruled out a so-called 'Nama for the people' on the grounds that lenders or taxpayers must take the pain if borrowers do not replay their debts.

Contrast this with the treatment of developers and banks. Taxpayers, including those in negative equity, are being forced to assume at least €40 billion of additional debt to pay for their bad loans and decisions. And in a classic case of pass the parcel, Nama will shortly start writing off, effectively forgiving, about €20 billion of developers' debts due their inability to pay. And this takes no account of the massive write-offs directly incurred by the banks.

Where the justice in this when developers can also avail of tax breaks and losses, legal loopholes, ring-fencing, limited liability and expensive advice to duck their debts?

Letter published in the Sunday Business Post on 30th May 2010.

Nama and Freedom of Information

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The call by Alan Dukes, director of Anglo Irish Bank, for Nama to be covered by the Freedom of Information Act should also embrace Anglo given that it could account for about half of all loans going into Nama. This should enable taxpayers to find out about Anglo's bondholders, the cost of winding up and its extraordinary lending decisions.

By my reckoning Nama will, unless it is very lucky or tough-minded, have to write off about €11 billion of unpaid interest on top of loan defaults of least €20 billion over the next ten years. Given the scale of these losses, it is essential that Nama's and Anglo's plans and operations be open to maximum public scrutiny.

Letter published in the Sunday Business Post on 16th May 2010.

Nama's Website

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If you open the home page for Nama and view its source (via View, Source with IE), you should see (near the top) that its meta tag for keywords contains the following:

" ireland, treasury, debt management, bonds, exchequer,
          europe, euro, EU, credit, economic, commercial paper,
          notes, exchange, programme, national, agency, dealing,
          primary, market, short-term, long-tern, currency, sovereign,
          asset,saving certs, saving bank, instalment saving, prize bonds,
          post office saving bank, group saving schemes, fexco, an post, tax, savings"

The keywords towards the end raise some interesting questions! Is Nama going start a savings bank, take over Fexco and An Post etc.?  It would appear that Nama is not simply content with using taxpayers' money to bail out builders and banks, it also wants our leftover savings.

You couldn't make it up!

Nama and the Banking Crisis

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These three letters from me about Nama and the banking crisis were published in the Sunday Business Post over the three Sundays commencing 18th April 2010:

Updated Cost of Crisis

On 22nd March you published a letter from me indicating that the banking crisis could cost taxpayers up to €35 billion. In the light of recent revelations, my "worst" case estimate has been upped to €47 billion. This is additional to related interest payments, social and economic costs and forfeiture of future investment opportunities.

How is this going to be paid for? Surely, it would be unrealistic to expect the cost to be shouldered by the lower paid who, by definition, are having trouble making ends meet. On this basis, the only realistic answer is a new levy on high earners on the grounds that they can still enjoy boom-time lifestyles and probably don't pay full taxes thanks to untaxed pension contributions and tax allowances arising from the ill-fated building binge. I can think of several memorable names for such a levy!

Lead letter published on 18th April 2010.

Haircuts and Scalping

Much attention has focused on the larger than expected haircut on the €81 billion of bank loans going into Nama. However, this haircut amounts to a scalping for taxpayers as it means that developers will walk away from residual debts of €36 billion if Nama merely breaks even over the next decade.

Accordingly, Nama's mission must be to collect as much of the haircut as possible - every unpaid billion euro is in effect a donation by taxpayers to developers' gambling debts and their incompetent banking pals. This means no sweetheart deals or fire sales, and maximum enforcement no matter how long it takes or difficult it proves.

Lead letter published on 25th April 2010.

Phantom Funds

Your front page headline "Phantom funds make up to 66% of INBS income" (25th April) could just as easily refer to Nama. Buried in the financial projections of Nama's draft business plan is evidence that it expects to roll up about €5 billion of interest in its initial three years and there is no indication that any of these phantom funds or "unrealised interest" will ever be paid. Indeed, I estimate that they could amount to €11 billion over ten years to 2020 and would almost equal the projected interest actually paid by borrowers. The Nama plan is silent on this possible write off.

It is interesting to see how the plan, issued with great flourish and used to justify Nama to the electorate and secure Eurostat approval for off-balance sheet borrowing, has been suddenly downgraded to "illustrative"  before a Joint Oireachtas Committee. Of course, the best approach would be to include Nama in the Freedom of Information Act to facilitate access to details of Nama's plans and operations.

Letter published on 2nd May 2010.

Cost of Banking Crisis - Update 1

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The following is an update of our previous estimate of the direct cost of the Irish banking crisis following the announcements on Bail-Out Tuesday (30th March 2010) by the Minister for Finance, Central Bank and Financial Regulator.

Our previous estimate was that the ultimate direct cost could be between €12.2 billion (best case) and €34.2 billion (worst case) with the most likely cost being €23.2 billion.

Our updated estimate is €22.8 billion (best case), €46.5 billion (worst case) and €34.7 billion (most likely). The central finding is that the most likely cost has increased by about 50% and our previous worst case estimate has effectively become the most likely.

The updated most likely cost amounts to three years' income tax receipts - equivalent to about €17,000 per taxpayer, or six months' average earnings.

This table presents the basis of our estimates. They exclude the cost of borrowings, dividend/coupons payments and any profits from share stakes, and they ignore the massive social and economic costs of the crisis.

Ignoring timing differences, crisis-related borrowings could theoretically hit €83 billion comprising cash provided to covered institutions (€38 billion) plus the Nama bonds (€45 billion). This takes account of the fact that any share investments made by the National Pension Reserve Fund are effectively funded by borrowings via the NTMA. Again ignoring timing issues, the annual interest cost could peak at about €3.8 billion before allowing for possible interest, dividend and coupon receipts.This is equivalent to about one-third of annual income tax receipts. At a guess, the net annual interest cost to the taxpayer could exceed €1 billion per annum. 

Cost of Banking Crisis

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Rough calculations suggest that, in the "worst" case, the banking crisis could ultimately cost taxpayers about €35 billion based on €10.8 billion expended to date, €14 billion for further bail outs and partial nationalisations, and a provision of €10 billion to cover Nama losses.

This is equivalent to about three years' income tax receipts, or €17,000 - or six months' average earnings - per taxpayer. Related borrowings would peak at about €79 billion with annual interest of about €3.5 billion either borrowed or paid by taxpayers. It takes no account of broader economic and social consequences.

Given the magnitude of the likely losses, it is truly extraordinary that a full public enquiry is not already well underway. Maybe, this because most of those who created, or failed to prevent, the crisis are still in charge.

Lead letter published in the Sunday Business Post on 22nd March 2010.

Some additional comments:

      1. In a "best" case scenario, triggered by a miraculous resumption of growth, the foregoing cost (€35 billion) might be reduced by two-thirds thanks to Nama achieving better than break even, repayments by some banks and proceeds of bank share sales.

      2. Based on the average of "best" and "worst" cases, the "most likely" direct cost of the banking crisis could be about €24 billion.

For the record, the key assumptions were as follows:

  • €10.8 billion already expended: €3.5 billion to Bank of Ireland and AIB; €3.8 billion to Anglo Irish Bank.
  • €13.4 billion for further bale outs etc.: €6 billion for Anglo; €2 billion for Irish Nationwide and €0.4 billion for EBS; €5 billion in new equity to be shared between Bank of Ireland and AIB.
  • Provision for Nama losses: €10 billion based on 20% of the €54 billion to be paid for loans from the covered institutions.
  • "Best" case provision assumed that all funds (€12.2 billion) to Anglo, Irish Nationwide and EBS are written off; that Nama breaks-even; and that preference and ordinary share investments in AIB and Bank of Ireland are recovered at cost,
  • Peak borrowings comprise cash provided to the covered institutions (€24.2 billion) plus the Nama bonds (€54 billion). This takes account of the fact that any share investments made by the National Pension Reserve Fund are effectively funded by borrowings via the NTMA.
  • Assumed interest rate on these borrowings is 4.5% (current yield on 10-year Government bonds).

The foregoing estimates exclude any possible losses linked to €10 billion provided by the Central Bank to Anglo Irish Bank under Master Loan Repurchase Agreements last March. This is secured against collateral of €14.5 billion provided by Anglo. For more information, see Outsiders Pay for Insiders Greed by David McWilliams in the Sunday Business Post and Anglo's latest fun in the sun by Dr. Constantin Gurdgiev.

 

Nama - Too Many Locals and Insiders?

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Over the past few months, the Minister for Finance and NTMA have announced the membership of Nama's board and its senior management team.

Given that Nama is going to become one of the largest property managers in the world, it is very surprising that so many of these appointments have been drawn from the NTMA which has no prior experience or expertise in managing and running down a vast property portfolio. By way of confirmation, the former CE of NTMA told the Oireachtas Public Accounts Committee in May 2009 that "we have no experience of bank restructuring or the whole new area which is coming our way, and we will be on a very steep learning curve."

For the record, two of the eight members are from the NTMA and two of the four senior management appointments are from the NTMA. This means that one-third of the team leading Nama are NTMA insiders. Of the remainder, only one has extensive property experience, one works for a major multinational, two are former bankers, two are former public servants and two are accountants. Although an additional person with international financial and banking expertise will join the board in May 2010, this will not radically alter the team's range of expertise or experience.

Having previously commented on the need for Nama to have world-class management,  I would have expected to see more property, legal, banking and international expertise on a team managing a €80 billion loan/property portfolio. I would also have expected a somewhat larger board and executive team. This gives rise to a concern that Nama, by accident or design, may be under-resources at top levels and overly dependent on very expensive and footloose external advisers. 

Celtic Tiger pussycats

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When a quarter of Iceland's electorate opposed the payment of €3.8 billion to the UK and Dutch governments arising from its banking crisis, its President refused to sign the relevant bill into law and the matter goes to the people in a referendum.

Meantime, our Government rams Nama down the electorate's throat and bails out banks and developers at a cost of at least €20 billion notwithstanding widespread opposition.

Whereas the Icelandic government resigns, our government clings to power in spite of having presided over the entire crisis.

While Iceland hires a high-powered, international investigator to help investigate possible criminal actions by bankers, our government dithers about even holding an enquiry.

Clearly, the Celtic Tiger has turned the Irish electorate into pussycats.

Letter published in the Irish Times on 15th January 2010.

Management of Nama

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The Board of Nama has been announced but I'm uneasy about its breadth of expertise and experience for several reasons.

Firstly, too many locals (8 out of 9) are members and too many of these previously worked for the establishment (4 out of 8) raising the possibiliy of "board capture". Presumably, they were selected because they "understand" the Irish business culture and political agenda, as well as for their undoubted experience and expertise. I would like to have seen the board include "real outsiders" with direct experience of very large-scale asset management, well-known views on protecting taxpayers and track records of aggressively pursuing large-scale, delinquent loans. These would include some really tough, nasty lawyer-types who cut their teeth on Wall Street and would be more than a match for any of the "locals". Of course, appointments of this type could put the "cat amongst the pigeons" and this isn't what the Minister for Finance is seeking at board level given his role in shaping and running Nama.

Secondly, bearing in mind that Nama will be one of the largest property companies in the world, I would have thought that its board and management should also be world-class. Anything less is equivalent to sending a boy on a man's errant. Bear mind that the three most important factors determining the success of a venture are management, management and management. The equivalents for property are location, location and location - these factors were often ignored during the boom and contributed to the crisis which Nama seeks to address.

Thirdly, the proposed staffing of Nama is only a fraction of that used by the Swedish "bad" bank operation which dealt exclusively with nationalised banks (this may still happen in Ireland) and had a loan portfolio far smaller than Nama's. It appears that Nama's in-house staff of about 100 people will be managing a highly fragmented, complex portfolio worth €77 billion covering 20,000 loans linked to almost 2,000 developers' business plans. As a consequence, Nama will be over dependant on expensive external advisers and will be obliged to over-delegate back to the covered institutions. Such an approach is penny wise and pounds foolish and a clear recipe for cock ups.

Overall, I'd have liked to have seen more people with substantial, relevant, international experience at board level and clearer indications that the management team will be appropriate to the task. Bear in mind that Nama exists because of massive managerial failures at government, regulation, administration, banking and developer levels. We don't want Nama to repeat these errors due to insufficient experience or expertise.

What is Nama ?

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Ireland's Nama (National Asset Management Agency) is not unique. It is also:

  • An African ethnic group of South Africa, Namibia and Botswana.
  • Means "baby names" in the Java language.
  • Old English and Sanskrit for "name".
  • A military camp in Baghdad, Iraq, standing for "Nasty Ass Military Area".
  • Nama demissum is a genus of plants in the family Hydrophyllaceae.
  • An adjective meaning raw (food) or draught (beer) in Japanese.
  • A national language in Namibia.
  • A hero in Altaic folklore who built an ark to save his family from a flood.
  • A verb meaning "to be flexible" in Swahili.
  • A wine used in Greek Orthodox Churches in Holy Communion.
  • A common greeting or salutation in the Indian subcontinent.
  • A collective name for the four mental groups in Buddhism.
  • A pronoun in Croatian.
  • Nama shoyu is a raw, organic, and unpasteurized soy sauce.
  • The meditation, vocal singing of hymns from the sacred scriptures of the Sikhs.
  • Shah nama is an epic poem written by Firdawsi which recounts the early history of Persia.

And the world is full of Namas! Here is a (partial) list of other organisations that use Nama as an acronym:

      1. Nashville American Marketing Association
      2. National Academy of Modern Accountants
      3. National Agri-Marketing Association
      4. National Air-Monitoring Audit
      5. National Alliance for Medication Assisted Recovery
      6. National Alliance of Methadone Advocates
      7. National Anger Management Association
      8. National Association of Mapua Alumni
      9. National Association of Master Appraisers
      10. National Association of Mathematics Advisers
      11. National Automatic Merchandising Association
      12. National Automatic Merchants Association
      13. National Ayurvedic Medical Association
      14. National Mall, Washington
      15. National Merit Awards - Zimbabwe
      16. Nationally Appropriate Mitigation Action - Bali Action Plan
      17. Native American Music Awards
      18. New Amsterdam Musical Association
      19. Newsletter and Magazine for Alumni - Aga Khan University
      20. Nigerian Airspace Management Agency
      21. Nigerian Automotive Media Awards
      22. Node Activation Multiple Access
      23. Non-Agricultural Market Access - WTO
      24. North American Mailing Associates
      25. North American Manipur Association
      26. North American Manx Association
      27. North American Metabolic Academy
      28. North American MICR Association
      29. North American Millers' Association
      30. North American Mobile Association
      31. North American Modeling Association
      32. North American Mushroom Association
      33. North American Mycological Association
      34. Northalsted Area Merchants Association
      35. Northwest Airlines Meteorologist Association
      36. Northwest Arkansas Music Awards
      37. Northwest Atlantic Marine Alliance

Nama and Rolled Up Interest

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According to Nama's plan, budgeted interest income for 2010-12 will total €9.5 billion but its cashflow projections only show interest income of €4.5 billion for this period. Presumably, the difference of €5 billion is rolled up. I reckon that rolled up interest could total €10.9 billion over the ten years to 2020. If this is included in the €62 billion of principal repaid by borrowers then the "real" default rate on loans would be 34% rather than 20% indicated in the plan. This would transform Nama's projected surplus into a trading deficit of at least €5 billion and signify that the bank/building crisis is far more serious than implied by Nama's plan.

Given that Nama will be taking over loans amounting to almost half of Ireland's GDP, its business plan should, at a minimum, have included "scenario-based" P&L statements and balance sheet projections as well as cashflow forecasts for the ten years. These would have given a fuller picture and facilitated analyses which might have helped anticipate problems identical to those being experienced by the banks that Nama is seeking to rescue.

Letter to the Editor published in the Sunday Business Post on 22nd November 2009.

Anglo Irish Bank & Taxpayers

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The seemingly innocuous decision of Anglo Irish Bank to change its year-end from September to December, presumably with the approval of the Minister for Finance and "public interest" board members, is a striking example of the Government's opaqueness and Machiavellian approach to the banking crisis and Nama. This date change means that the State-owned bank can hide the full extent of its problems until 2011.

Meantime, the Government has gifted almost €4 billion of taxpayers' money to the bank for absolutely no return and will probably need to flush a further €4-6 billion down its plug hole. This is additional to the estimated €28.4 billion of loans to be transferred to Nama. The State is knowingly paying over the odds for the privilege of handling these loans to the extent of, maybe, €3-6 billion.

On this basis, Anglo is going to cost the Irish taxpayer anything between €8 and €16 billion. This means that up to 15 months of all income tax collected in the State could be used to pay for the reckless behaviour of Anglo's management and some of its clients.

Nama - Horses, Carts and Stable Doors

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Nama's draft business plan projects a profit of €5.5 billion by 2020 even after overpaying €7 billion for loans and incurring expenses of €2.6 billion. Surely, this forecast undermines the need for Nama. In truth, the plan's projections are undoubtedly "very best case" and other scenarios should have been published using lower repayments and interest income, higher defaults etc. These scenarios would explain why the banks are so enthusiastic about passing all their property loans to Nama.

Letter published in the Sunday Business Post on 1st November 2009.

What is the point of the Dail debating the Nama Bill before Nama has undertaken basic research on its prospective loan portfolio and finalised its business plan and strategies? If Nama's draft plan was used to seek €54,000 from investors, it would be rejected out of hand as an extremely poor document. Given that Nama needs to effectively raise an amount which is a million times larger i.e €54,000,000,000, surely no taxpayers' money should be provided until its plan has been fully researched and approved by the Dail. Only at that point would it be appropriate to resume consideration of the Nama Bill. Thoughts of horses, carts and stable doors come to mind.

Letter published in the Sunday Business Post on 8th November 2009.

Nama - The "real" Default Rate

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Our general criticisms of Nama's draft business plan are presented in Nama - A Flawed Business Plan.

This posting raises basic questions and concerns about the plan's underlying default rate and treatment of rolled up interest. These could have huge implications for the plan's credibility; the likely depth and duration of the banking/building crisis; and the cost of Nama to taxpayers.

In summary, detailed analysis of Nama's cashflow projections suggests that the "real" default rate is either an unrealistically low 6% or a catastrophically high 34% depending on the treatment of rolled up interest arising over the ten years to 2020. This compares with a 20% rate quoted in Nama's plan.

Instead of debating the Nama Bill, the Dail and Seanad should undertake a more indepth review of Nama's business plan. Bottom line: no taxpayers' money or support should be forthcoming until its plan has been fully researched and presented in final form for approval.

Our detailed assessment is presented in the five sections below. They review Nama's projections, highlight concerns, pose questions, explain implications and present general conclusions. 

Nama - A Flawed Business Plan

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Nama's draft business plan is merely a work in progress and no taxpayers' money should be invested until the plan has been fully researched, presented in final form and approved by the Dail.

If the plan was used to seek €54,000 from investors, it would be rejected as an extremely poor document. Given that it is being used to raise a million times more, no taxpayers' money should be invested until the plan has been fully researched, presented in final form and approved by the Dail.

As developer of financial projection software with a user base in over a hundred countries, I'd like to comment on Nama's 10-year projections as follows:

  1. The discount rate used to convert future cashflows to present-day values is 5 percent. This corresponds to the current rate, presumably risk-free, for Government bonds. If a more realistic rate of, say, 15 percent is used to partly counter the plan's rosy assumptions, the projected net cash value drops from €4.8 billion to €3.7 billion for the ten years.

  2. Every business plan, especially one involving an investment of €54 billion of taxpayers' money, should include projected P&L statements and balance sheets as well as cashflow forecasts for each year. This would present the full picture and facilitate ratio analyses which might help anticipate problems similar to those experienced by very same banks that Nama is trying to rescue.

  3. Given the huge uncertainties, projections for less favourable scenarios, based on the plan's own risk assessments, should have been published. These would facilitate the development of defensible strategies and mini-max assessments (to minimise the maximum regret that might be anticipated once the final outcome is known) as well as Monte Carlo simulations to take account of the compounding effect of risk. 

  4. The projections assume modest principal repayments during the initial three years and a surge in repayments during the final seven years. If over half of all borrowers cannot pay any interest during the initial years, what are the chances that property markets will recover sufficiently to facilitate repayment of loans as well as rolled up interest in later years?

  5. The plan forecasts a profit of €5.5 billion by 2020. Surely, this forecast undermines the need for Nama and begs the question as to why the banks' shareholders are not lining up to get a share of the action. In truth, the plan's projections are "very best case" and other scenarios should be published based on lower repayments and interest income, higher defaults, higher debt interest and expenses and a higher discount rate. These would be more realistic and explain why the banks are enthusiastic about Nama.

  6. After market risk, the greatest challenge facing Nama relates to management. To succeed, its resources and expertise must be appropriate to one of the largest property portfolios in the world. This means experience of world-scale asset recovery and portfolio management with minimal reliance on inexperienced local secondments, expensive advisers and delegation of nothing but basic administrative activities back to covered institutions. According to its plan, Nama's inhouse staff of under a hundred people people will be managing a highly fragmented, complex portfolio worth €77 billion covering 20,500 loans linked to almost 2,000 developers' business plans.

  7. The business plan explores six alternative scenarios. Only one of these is linked to Nama's operational performance and the trading environment and indicates that Nama would only break even if a default rate of 31% is used. The other five relate to interest rate trends and indicate that the impacts will be either negligible or highly unlikely. Extraordinarily, no attempt was made to assess the impact of any of the eight risk factors detailed in the business plan.

  8. The plan contains no assessments of likely economic conditions over the next ten years to provide a basis for its projections regarding loan defaults and repayments. Notwithstanding this, the Government has already decided that the long-term outlook justifies paying €7 billion more than the market value of the properties linked to the loans to be repaid over the next decade.

  9. The plan makes no reference whatsoever to the creation and role of Special Purpose Vehicles (SPV) which will be majority private-owned and play a pivital role in the execution of Nama's plans. Does Nama's right hand know what the left one is doing?

Instead of discussing the Nama Bill, the Dail should undertake an indepth review of Nama's business plan. 

Nama's Business Plan

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Nama's business plan was published last night. It is of particular interest as my business specialises in business planning and financial projections. Having seen hundreds of plans and projections, I have learnt to take most projections looking beyond 2-3 years with a pinch of salt.

Nama's plan projects a profit of €5.5 billion by 2020 even after overpaying €7 billion for loans and incurring expenses of €2.6 billion. This is absolutely incredible and laughable if it was not so serious.

Surely, these glowing projections undermine the need for Nama and beg the question as to why the banks' shareholders are not lining up to get a share of the action. In truth, the plan's projections are "best case" and, as a specialist in business planning, I'd advocate a much more conservative set of numbers with lower repayments and interest income, higher defaults, higher debt interest and expenses and a higher discount rate. This scenario would be much more realistic and would explain why the banks are so enthusiastic about Nama.

Having originated the Double/Double/Half Rule (double time, double costs and half revenues), I'll like to see it applied to the Nama projections.

More seriously, an independent review of the plan's projections is essential before any further steps are taken. I'd love to see Justice Clarke of the High Court review the plan in the light of his devastating assessment of the financial projections accompanying the Zoe Group companies' application for examinership.

Politicians' Expense Scandal is Small Fry

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The current outrage about politicians' expenses is well justified and must lead to a complete reform incorporating a vouched system and lower expense rates (e.g. for attending the Dail). The message to politicians is that they should stop arguing, fix it and then move on as there are much bigger fish to fry.

Preoccupation with politicians' expenses and the million euro payment to a former FAS executive should be contrasted with the proposed payment by Nama to the banks. This is 54,000 times greater.

To put this in context, a million euro of €10 notes laid end-to-end would stretch from O'Connell Street to Howth whereas the Nama payment could be wrapped 17 times around the earth at its widest point. Given the magnitude of Nama and the limited information available (we know much more about the Ceann Comhairle's expenses), surely the Dail should spend more time discussing the principles of Nama rather than the minutiae of the bill. An expert-supported, forensic examination of Nama and its proposed pricing methods might help close the stable door before, rather than after, Nama bolts.

Also, compare the FAS furore with the deafening silence and absence of sanctions surrounding current and former ministers, bank directors and senior banking, public sector and regulatory executives for leading the entire economy to the edge of a precipice and then demanding that everyone else pays for their incompetence.

Nama - Three Suggestions

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The following message about Nama was sent on 4th October to all TDs and Senators as a follow up to that sent on 28th August. Several recipients pledged to raise the suggestions in the Dail or at the Committee stage of the Nama Bill. Whether any of them make it into law remains to be seen.

On 28th August, I wrote to you signifying my deep concerns about Nama. In the event that Nama proceeds in its present form, I wish to offer the following suggestions to help enhance public trust and improve its effectiveness:

1. Whistleblowers' Charter

The Nama Bill covers corruption, acting in bad faith, conflicts of interest, lobbying as well as failures to comply with obligations. It also provides for extensive reports, audits and accountability. Provision should also be made for a whistleblowers' charter to cover staff within Nama, covered institutions, debtors, advisers and service providers so as to help ensure that these parties all operate to the highest professional and ethical standards.

2. Reporting on Policy Matters

As the incumbent Minister for Finance will effectively control a €90 billion property empire and as several individuals of different political hues could fill this role over the life of Nama, robust checks and balances are essential to ensure that these ministers cannot use Nama in any manner at variance with its original purpose. To see how easily this can happen, consider Nama's sister body, the National Pension Reserve Fund which was set up to develop an international investment portfolio over a twenty-year horizon. Eureka, at the Minister's direction it now holds €7 billion of Irish bank shares amounting to a third of its total assets. Sections in the Nama Bill preclude its Chairman and CE from discussing policy matters with Oireachtas Committees. As things stand, these committees could be prevented from raising major issues, such as pricing of asset sales, on the grounds that these are policy matters. These sections should be removed and senior management should have unrestricted access to Oireachtas Committees.

3. Management Resources

After market risk, the key variable determining the success of a venture is usually managerial risk. In Nama's case, the former will be addressed largely by the size of the so-called haircut. To address the latter, Nama's senior management team must have extensive direct experience of world-scale asset recovery and portfolio management. Reliance on local secondments, expensive advisers and delegation of anything but basic administrative activities back to covered institutions should be minimised. The proposed staffing of Nama is only a fraction of that used by the Swedish "bad" bank operation which dealt exclusively with nationalised banks and had a loan portfolio far smaller than Nama's. It appears that Nama's inhouse staff of under a hundred people people will be managing a highly fragmented, complex portfolio worth €77 billion and covering 20,500 loans linked to almost 2,000 developers' business plans. Such an approach is penny wise and pounds foolish and is equivalent to sending a boy on a man's errant. Accordingly, the management resources and expertise within Nama must be appropriate to managing one of the largest property portfolios in the world even if this entails much higher operating costs than envisaged to date.

Thank you for reading this. I would welcome feedback or comments but please don't simply reply with a canned response or by enclosing any more general policy documents about Nama.

Who are Government & Nama Trying to Fool?

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Supplementary documentation published by the Department of Finance alongside the Nama Bill about property yields contains some extraordinary statements (starting on page 10):

  • It indicates that property yields (rents as percentage of prices) are higher in Dublin (7.25 percent) than in other major European cities and that Dublin's yield is well above its 20-year average of 5.6 percent.

  • It then states that as "yields move towards their long term average this would indicate an increase in property prices". To re-enforce this view, it expects the exceptionally large difference between property yields in Ireland and key euro interest rates to narrow as a result of rising interest rates or rising property prices!!!

Whilst acknowledging that property prices have fallen by almost 50% in the past few years, the document completely ignores the possibility that the exceptional yields may be anticipating a sharp decline in rents. It not so long ago that the Irish banks offered unprecedented double-figure dividend yields before they were obliged to suspend dividends and their shares collapsed.

Furthermore, the Government could be accused of conspiring with Nama by not implementing legislation to permit downward rent reviews for commercial leases, as has happened already in the residential sector. This has the effect of artificially underpinning high property yields and thereby supporting property prices for the benefit of Nama, the banks and their developer friends. 

Hopefully, the European Commission is taking note of the Government's and Nama's approach to property valuation and their use of taxpayers' hands to catch falling knives.

Questions about Nama

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Four questions about Nama:

  1. Why is the onus on Irish taxpayers to recapitalise the main banks via Nama? These banks could raise substantial capital by selling off non-core investment and insurance activities and holdings in banks in the UK, Poland and the US. 

  2. Why is the Minister preoccupied with the capital requirements of the banks when determining the haircut on loans being transferred to Nama? Surely, this amounts to match-fixing with taxpayers on the losing team.

  3. Will the Minister accept that property values could continue falling for the next few years and might not rise for several years thereafter? This would be a consequence of the overhang created by Nama's portfolio, rising interest rates and ultra-conservative bank lending.

  4. Why doesn't the Government direct the banks to grant share options to mortgage holders experiencing negative equity? This would help compensate them for the failures by the Government, Regulator and banks to exercise judgement and prudential control during the boom which they provoked.

Lead letter published in the Irish Times on 17th September 2009.

Nama's Role in Price Rigging

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The property market is in the doghouse simply because, as dogs on the street know, prices have to fall considerably further to make long-term economic sense based on yields and prospective interest rate increases.

Clearly the Government is not listening as it strives to ensure that Nama will be able to exploit its dominant market position to keep prices artificially high for the benefit of bank shareholders, bondholders and developers. Surely this amounts to price rigging and State subsidisation and is contrary the public interest.

Nama - TDs and Senators

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The following message was sent to all TDs and Senators on 28th August 2009. It was acknowledged by about forty recipents who mainly supplied canned responses with attachments about party policies.

I'm very concerned about the Government's approach to resolving the banking crisis and wish to make the following points to you as a public representative in the hope that you can influence or lobby the Government:

  1. As the economy moves through an unprecedented recession, all possible measure should taken to ensure that credit is readily available for viable projects and credit-worthy borrowers. It is impossible to see how this can be done by a lame-duck banking system which is being pulled in several directions - to lend more, protect shareholder value, ration credit to improve ratios, hoard resources to cover bad debts, and make guarantee and recapitalisation payments to the state. 

  2. While the Minister for Finance views bank nationalisation as the "last resort", he must also appreciate that the main banks continue to operate thanks to the State's guarantees for €400 billion, its €7 billion preference share investment, its plan to purchase €90 billion of their loans and, if needs be, to take equity stakes.

  3. Nama is a huge gamble which exposes taxpayers to a multi-billion euro hit if prices paid for the loans prove to be too high. In these circumstances, the banks would emerge unscathed and their shareholders would make massive gains as the economy recovers. If you think that this couldn't happen, recall that an insurance levy paid for many years to bail out AIB after its ill-fated takeover of ICI. Note: This was incorrect - the levy related to the failure of PMPA.

  4. As the Government has a responsibility to protect the banking system and taxpayers ahead of banking institutions or bankers, it is very hard to understand why it doesn't simply "bite the bullet" and temporarily nationalise the main banks as a central element of Nama's rescue mission. Given that it holds the whip hand, the Government could cut deals with bank stakeholders to ensure that gains and pains are shared more fairly.

Thank you for reading this.

Who will Control Nama

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Based on the draft Nama legislation, the Minister for Finance will effectively control a €90 billion property empire and, given Nama's expected life span, several individuals of different political hues could fill this position over the next decade.

This raises concerns about the robustness of checks and balances to ensure that these ministers don't use Nama for pet projects at variance with its original purpose. Couldn't happen?

Just look at Nama's sister body, the National Pension Reserve Fund which was set up to develop a high-grade, international investment portfolio over a twenty-year horizon. Suddenly, at the direction of the Minister for Finance, it has been stuffed with €7 billion of Irish bank shares amounting to a third of its total assets.

Any requirement that finance ministers account for Nama to the Oireachtas offers absolutely no solace based on that body's track record. Instead, the legislation must include overarching controls to ensure that Nama cannot become a ministerial sweet shop offering goodies like bail-outs, tax-breaks, benchmarking and decentalisation.

Role of Nama

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Why is the Government proposing to use Nama to prevent a decline in property prices at a time when Ireland has the second highest cost of living in the EU?

Surely, it should be encouraging lower prices as these would result in cheaper houses, lower shop prices and more competitive commercial and industrial rents. Instead, taxpayers are expected to underwrite a multi-billion punt on Nama to ensure that property prices don't fall and that the country remains uncompetitive.

Lead letter published in the Irish Times on 26th August 2009.

Nama

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In discussing the need for strong oversight of Nama, Noel Whelan (1st August) mentioned that the draft legislation provides for a special Oireachtas committee to oversee Nama in addition to the Public Accounts Committee.

I wonder how effective these committees will be given that the draft legislation contains clauses (50 and 51) which preclude the Chief Executive Officer and the Chairperson of the board of Nama from (a) questioning or expressing an opinion on the merits of any policy of the Government or a Minister or on the merits of the objectives of such a policy or (b) producing a specified document in which the Chief Executive Officer or the Chairperson questions or expresses an opinion on the merits of any such policy or such objectives.

Surely, these "gagging clauses" will preclude key officials from speaking openly on fundamental issues and effectively nobble comprehensive scrutiny of Nama.

Letter published in Irish Times on 4th August 2009.

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