October 2009 Archives

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'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 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.

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.

The Government should introduce a measure for Ireland similar to the Lisbon Treaty's Citizens' Initiative whereby at least a million EU citizens from several member States could request the EU Commission to bring forward proposals on a particular issue.

Based on the Lisbon model, about ten thousand Irish citizens from, say, six counties could oblige the Cabinet or Dail to consider an issue, or the Government to hold a referendum. Apparently, such a proposal was included in a draft of the 1922 Constitution of the Free State. Citizens' initiatives operate in Switzerland, New Zealand, Estonia and the US. A measure along these lines might help bridge the yawning gap between our politicians and the electorate.

Letter published in the Irish Times on 6th October 2009.

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.

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.