In what may become a defense mechanism brought on by the IndyMac Bank failure and "run" lines reminiscent of the stock market crash of 1929, local small bank Luther Burbank Savings of Northern California has gone on a reputation management campaign in local print media. The campaign has a simple message--we are solvent and in good shape therefore don't be afraid to deposit money with us.

"Statement of Condition"

This is an advertisement comprised of a letter to customers touting the "exceptional year 2007 was for the bank with deposit growth of 24%. The statement also addresses the bank's 25th Anniversary and how "relationships developed. . . are among our most rewarding results."

Assets

This section of the add gives a accounting line item breakdown as follows:

1. Cash & Securities: $14,569,000

2. Loans Receivable: $2,968,032,000

3. Other Assets: $69,430,000

Bottom Line= $3,052,031,000

Liabilities & Capital

Deposits: $2,129,633,000

FHLB Advances: $642,811,000

Other Liabilities: $21,126,000

Capital: $258,461,000

Bottom Line= $3,052,031,000

Note-Disclaimer :The ad features in tiny print the disclaimer as follows: "This unaudited statement is prepared in accordance with generally accepted accounting principles."

Analysis

Does this disclaimer really mean that they can twist the numbers in any fashion legally to make them look more solvent? Is this institution fooling itself? Fooling consumers? Or is this a form of advertisement we will see moving forward for every banking institution?

In my opinion this type of advertisement, in the face of the Enrons and cooked books business culture we have suffered through in the past, is nothing more than meaningless fluff.

Why fluff? Because for this ad to have ANY validity they should have two independent accounting firms, with no PRIOR contract work with Luther Burbank, conduct separate audits for transparent and objective information. That would be the only believable scenario in my opinion

Synthetic CDO Issuance Down Sharply in First Quarter

Wow! Really? Apparently CreditSights, whom I have heard good things about, put out a report saying this. The money quote? Here it is...

The Cash flow CDOs that are being launched increasingly appear to be designed to help banks clean up their balance sheets rather than attempts to arbitrage the agency ratings.

And then there was this other gem in the post, quoting the report...

“Any widening, it was claimed, would rapidly be exploited by a wave of CDO issuance. The most important driver of this stabilisation was synthetic CDOs - specifically the idea that bespoke single-tranche deals could be placed with investors without the need to fill the entire capital structure and this protection selling would push spreads lower.”“Such arguments have been demolished by the events in the past 12 months with both synthetic and cash flow CDO issuance falling like a rock owing to a slew of economic, ratings, and funding concerns.”

So why is CreditSights (CreditHindSights, in this instance) releasing such a report, detailing what everyone with a minimal attention span and the ability to read a newspaper would be able to figure out for themselves? Oh, right ...

The full report is available for purchase.

(link omitted)

I don't think a firm needs to sell a report telling people interested in reading finance research that people aren't buying CDOs like they used to, anymore.

Maybe their next report will analyze Bear Stearns most recent 10-K and detail some warning signs they see as troubling...

The Foundation

As we begin our journey to build our very own investment bank, I'm going to make a few statements that people "in the know" will find both surprising and, in hindsight, very obvious. The topic, as the title states, is technology. Now, here are the statements:

1. A major contributing factor to the way banks did business, especially in the businesses that contributed the most to banks' current  problems, was their lack of technology.
2. Credit default swaps, in all their glory, had most of their issues rooted in technological inadequacies at various institutions.
3. A large portion of the cost structures at investment banks are due to a lack of technological heft.

I know, these seem outrageous. However, as anyone who has worked at a few different firms will tell you, there is a massive difference between a firm with good technology and bad technology. Let me tell you a simple anecdote: When very senior executives at a firm called down to the managers in charge of securitized products, they asked for the current marks and a summary of the various exposures "on the books." It took about ten people three days to cull through all the various positions, put marks on them, model them, and put a concrete value on them. There wasn't time to break down exposures by anything but the most trivial categories. Now, why this end product was acceptable is a different issue, but it should be clear that an effort of this magnitude shouldn't be necessary to answer questions so totally basic in the context of running a multi-billion-dollar (although now with fewer billions) financial institution. A corollary: If it takes you several days to enumerate the positions your area has, you don't know what it is yourself.

Now, when I speak of technology, I'm really speaking of the specialized systems and solutions used to tackle business issues, and not really the "desktop support" kind of technology. The systems that manage risk and positions, handle accounting, maintain an integrated analytics platform, deliver research and other products internally and externally, manage the human resource functions of the firm, and otherwise grease the wheels of capitalism.

The Blueprint

Our technology plan will have a few different components...

Structural Frame 1: Whether our theoretical investment bank is a startup or an established entity, the technology at the core will be home grown.

Structural Notes: Hiring consultants to stitch together purchased solutions and legacy systems is unacceptable. Technology, in order to be most effective, needs to be responsive. When a trading desk needs to run its business, and the system provided is insufficient, then it's an unacceptable solution, and things will be done manually. Remember synthetic CDOs? Remember the ABX and credit default swaps on sub-prime bonds? Would it surprise you to know that at many major investment banks there was a manual component involved with every single contract and trade? The systems weren't able to handle these instruments, and these businesses scaled up at a rate that was untenable. Also, there were no analytics available for these products. Businesses bought third party solutions for modeling and analytics, but those didn't integrate or scale, so all the marks and risk numbers used to compute capital needs and P&L were merely estimates as these businesses were growing the most.

Let that sink in. Is it any wonder the senior managers didn't know, before it was too late, what the actual exposures were? Had these firms built an integrated set of systems instead of buying a patchwork of specialized programs to solve the most current problem, these issues would not have been nearly as bad. I won't even tell, in detail, the story about how, years ago, the system for trading credit default swaps at one bank was so difficult to use that they only created one identifier for GM and GMAC, not distinguishing between the two at all. But, when they were both on the brink of being downgraded to junk, but GMAC was de-coupled from GM, I wonder what kind of fun it was to rummage through 5- to 8-year-old confirms trying to match thousands and thousands of trades with the exact entity? Costly? Absolutely. Avoidable? Double absolutely.

On another note, an investment bank need not be innovative, but if it isn't, then it should be able to mimic innovations quickly. Reporting to management, having an accurate record of transactions and various changes to the firm's balance sheet, the ability to run various analyses on various products, and other, more basic, reporting functions (not even mentioning compliance and regulatory functionality) are all things that should be implementable once something new hits, and the only way to make these kinds of incremental changes is to build, not buy. A business as complex as an investment bank shouldn't be reliant on outside parties to build software vital to their business--both from a cost standpoint and from a delay-until-completion standpoint. Further, the procurement process takes months!

Structural Frame 2: The technology part of the organization will not be a monolithic standalone beauracracy.

Structural Notes: Simply put, technology (the people or business unit) needs to be vested in the process of making a business more profitable. Rather than taking on the normal support role mentality of, "If I say 'yes' then I might be wrong and held accountable, so I will say 'no.'" The best way to do this is to not have technology be its own portion of the organization. Allowing technology to have a seperate seat at the table--or, worse, report into some catchall support person--only contributes to creating a centralized process for technology decisions. Centralizing technology decisions for many businesses with different needs creates unnecessary layering and wedges a huge management structure between the people doing the actual work and the people who are using the product and paying for it.

The final plan, I believe, would be to have as many technology people as possible integrated into the physical workspace of the people that utilize their work. Have investment banking developers sitting amongst investment bankers. Have the developers that build trading applications sitting with traders. The reporting structure should be a matrix of sorts--senior technology managers should report into a business whose technology needs are distinct from other businesses (atomic, perhaps is a better word) as well as a more senior technology person. In essence, people working in technology would be ingrained with the thought that they are there to help--the business unit would be setup as the client and the technology super-structure would be more for managing the processes. Obviously when the business is viewed as the client, technology managers are incentivized to get the businesses what they want, and when the people (both doing the work and in charge of liaising with the clients/business) are integrated (and can see the working environment of their clients and usage of their products) a lot of inefficiency and "lost in translation" moments are avoided. Senior managers really need to think of their business as including technology instead of interacting with it. This is highly important and is much more likely with a structure like I've proposed. Also, the closeness will just yield some more technologically savvy people and even encourage people to move between the two "worlds."

Structural Frame 3: The people who are hired for technology roles will be of a high calibur and will be under a compensation regime and in an environment that sets big technology companies to shame.

Structural Notes: This shouldn't be a hard line of reasoning to follow, but in general the difference between firms that "get it" and firms that don't is how they recruit. Having an engineering background, I was recruited for I.T. from a very good school for that sort of thing by a few banks. Those banks have a high correlation to both still being around and surviving the mortgage mess with the smallest scathing in their peer group. I know several people who have told me that some other firms, one that haven't been so lucky, have absolutely ridiculous and incredibly stupid policies for recruiting technology people. Most notably, one Manhattan firm recruits from local state schools almost exclusively--this is done so that the students they recruit can work part time during their senior year of college. No school in the top fifty or so participates. If one had to draw a grid, and rank various factors as to how important they are, the program I have just mentioned is the most ridiculous, stupid, and demonstrating a complete lack of critical thinking skills (or, for that matter, basic grasp of the business and reality) of the programs I have heard of or encountered. The people responsible for it have all moved on and the firm has suffered greatly from it's underinvestment in technology.

So, to recruit good people you need a draw. To be honest, most graduates don't fully grasp the concept of upside or career path--especially not ones in I.T. This makes it simple to get them, just offer a bigger number for the compensation in the first year. While this would work, it should be clear that this won't help make them much more productive than the average technology drone in an investment bank. Giving technology employees a compensation structure that matches the businesses they are supporting is, in my view, a great solution. Obviously there would be more stability, but there should be a linking of incentives to the business and an interconnectedness in how they think about how technology and the problems facing the business. They should also have an incentive to be proactive and try to advocate solutions to problems they see instead of waiting for others to focus on them--this contributes greatly to becoming a nimble organization.

As for work environment, whenever possible, for groups not truly linked to a single business, like infrastructure groups and the web development team, my focus would be on building a start up-like atmosphere. The marginal cost of things like free coffee, free food, and some extra square footage for odd amenities is insignificant in relation to the quality of the work produced by the people snatched from places like Microsoft and Google versus a lower calibur of student culled from whatever lower-tier school(s) happens to be nearby. When you know your competition and what they offer that you do not, it's very easy to compete: just offer what they offer. For things that aren't as timely and linked to a knowing how a certain business runs, there is no problem in creating a lifestyle and work ethic that is free-form as long as it meets goals and needs of the firm. (Note: This isn't my unique idea. A certain investment bank with a strong brand does this sort of thing already... but I did think of it before I knew that!)

Structural Frame 4: Technology, especially experminetal or new technologies, should be used to try to create, or even drive, value.

Structural Notes: This is more a philosophy than an actual directive, but it's important to taking a firm's strategy on technology to the "next level." There is a massive body of knowledge within a firm that is lost everyday due to a lack of effort. Usually the solution is to put humans somewhere and have them manually type in numbers or perform mundane tasks to get this working smoothly. Not in our investment bank! Let me furnish you with an example. The corporate bond market works in an unusual way: traders send around "runs" or lists of bonds with quotes of where they are willing to buy and sell bonds via Bloomberg's messaging system--they are generally free form text. Why do they do it this way? It's quick and easy. The firm I worked at didn't make any effort to collect these pricing levels and store them somewhere. However, for publishing strategy reports, helping the desk find trade ideas based on historical relationships, calculating risk metrics, and any other number of things, this data would have been vital. Technology can easily help to store, warehouse, and serve these sorts of datasets (readily available from the market but unstructured) and help the organization as a whole improve its efficiency. This is just one example, but it serves to illustrate a point that is extremely common in an investment bank--lots of things require information that no one keeps but was readily available. Technology can drive value for lots of internal things by helping to solve problems like this. And, honestly, there are too many things that are out of one's control not to have an organized and structured solution to the simple things that can be fixed.

Another note on technology, however, is that as the Web innovates social behaviors and collaboration those technologies should be actively examined as potential solutions to problems an investment bank would face. For example, lots and lots of information is needed when talking to a client. Getting good market "color" that everyone can see, and that is available, consistent, and easy to find is important. Perhaps a series of blogs could be used to ensure the delivery of this content is made as efficient as possible. One way I added value at my firm was by knowing as many people as possible. When liquidity started becoming an issue, the people I spoke to on the desk that funded banks in the LIBOR-based funding market explained what was the situation and we were able to assess if we thought this warrented a change in our positions or business in general. If that desk had a blog where they posted color throughout the day and the firm had an easy way to deliver this information to all of its employees, perhaps this could have helped people develop a more specific view on the market and notice some irregularities leading to the current crisis. Could Wikis be used effectively? I'm sure that they could. If it was institutionalized to have an up-to-date knowledge base within the firm, and it was made a priority to keep those things updated, nuances and details on complex transactions could be documented. People could avoid falling into the same traps or having to research the same issues other alsready have. These are just a few examples of how new technology innovations can be used to create value where it would otherwise be impossible.

Structural Frame 5: Every employee should be very comfortable with technology and make a large effort to integrate it into their work.

Structural Notes: I hate to sound like a snob, but in general, if you can't figure out things like email and basic spreadsheets, you don't have a lot of room left to grow. People should learn new technologies as they are available and make an effort to work more effectively. If this isn't a priority of almost everyone in the firm, then building new systems and integrating things into their daily "workflow" is useless. Part of pushing the envelope on how new things are used means that people will have to learn how to use them. I've seen too many people, uncomfortable with a new system, resort to keeping their risk positions and other vital data the firm should know in a spreadsheet. Unacceptable. Now, not everyone has to "ooohhh" and "aaahhhh" over new features and technological platforms, but everyone should be asking themselves how they can use some new technology product to make more money, pitch more transactions, better monitor the firm's risk, develop a better strategy for investing, or whatever their job entails. I don't think this is hard, but I do think it's important. And, with technology employees sitting with business people and understanding how they work day-to-day, the resources to figure out these sorts of things will be much more readily available than at most other firms. (See how the "structural frames" all interplay?)

The Final Inspection

As one can see, I value the little things that help people get 10-15% more productivity out of their daily routine--that's the edge most firm's need to excel in what they are focusing on. However, most firms poorly thought out systems and infrastructure issues, especially when it comes to technology, adds a hugely cost-ineffective layer of one-fix-at-a-time solutions that have added up. Why have a system where traders can input their own trades as they do them? Give them a paper record and hire a person, with full benefits and being paid an amount commensurate with living in New York City, to type them in. Oh, and now that the business has grown to three times to trading volume in six months, let's hire four more people. Why have a system that allows a capital markets person to view real-time quotes in their sector or updates those quotes into a spreadsheet or preentation? Just have a bunch of analysts do it by hand. Why would you want a system that can model securitizations and CDOs and run the numbers effectively? We can have someone do it in a spreadsheet, that's "close enough." Although it doesn't capture the nuanced risk factors, I'm sure defaults will never get high enough to worry about. These are the kind of solutions that, from the start, one should be thinking about. From the first instant it's possible to fix these, they should be fixed. I think the five parts of the framework I've laid out will make a good plan to folow when building the technology part of our investment bank!

1. Fannie and Freddie essentially securitize mortgage loans. This is complicated, but here's the story in their own words:

Mortgage lenders ... deliver pools of mortgage loans to us in exchange for Fannie Mae MBS backed by these loans. After receiving the loans ... we place them in a trust that is established for the sole purpose of holding the loans separate and apart from our assets... Upon creation of the trust, we deliver to the lender (or its designee) Fannie Mae MBS that are backed by the pool of mortgage loans in the trust and that represent a beneficial ownership interest in each of the loans. We guarantee to each MBS trust that we will supplement amounts received by the MBS trust as required to permit timely payment of principal and interest on the related Fannie Mae MBS. We retain a portion of the interest payment as the fee for providing our guaranty. Then, on behalf of the trust, we make monthly distributions to the Fannie Mae MBS certificateholders from the principal and interest payments and other collections on the underlying mortgage loans.

(emphasis mine).

The essential point here is that Fannie and Freddie take on the entire risk of the mortgage defaulting in exchange for an ongoing fee (generally 50 bps per annum). The fee they charge for this type of transaction is small, generally less than 1/2 of 1/32nd of one percent of the principal balance of the loans they are guarenteeing. Also, Fannie and Freddie retain any risk of hedging their exposure. Part of this is meant to imply that the fees they collect offset the losses they expect to endure, but there's also a lot of expense to hedging these exposures. I won't pretend to understand all the complexities of this process, but they have to manage duration risk and interest rate risk (note that in mortgages, these are linked, but not exactly the same thing: lots of factors, including interest rates, affect a borrower's decision to prepay their mortgage and changes in interest rates affect the future cashflows from fees). This is more art than science as it is very dependent on odd accounting rules and complex models--models that are a best guess at an uncertain future. Read their risk management section (and keep in mind that O.A.S. models are just lots of iterations run over another set of models... so, two layers of models... and we know how good those have performed) or this OFHEO report, specifically the sections on risk (Model Risk especially). The report I just linked to goes into, in depth, the various risk, accounting, and hedging issues at "the Enterprises."

2. Fannie and Freddie are one of the largest, if not the largest, buyers of mortgage product. They buy their own mortgages (ones they have seen securitized) and hedge their massive portfolios. They issue bonds at extremely cheap levels to fund these activities. One former treasury official seems to think that this huge funding advantage seems to have translated into a bit of reckless purchasing on the part of the agencies. They even tout this--going back to the Fannie filings, we learn the following:

The U.S. Congress chartered Fannie Mae and certain other GSEs to help ensure stability and liquidity within the secondary mortgage market. In addition, we believe our activities and those of other GSEs help lower the costs of borrowing in the mortgage market, which makes housing more affordable and increases homeownership, especially for low- to moderate-income families.

(emphasis mine).

How noble! They lower the cost of a morgtgage by, well, buying lots of them and lowering rates. Why do they buy so much? so they can lower rates. Easy to understand, right? The reason they do this is to help increase home ownership. Interesting, then, that their business volume in 2007 had 11% investor properties or second/vacation home (see table 41, here). Also interesting, then, that 32% of their business was lending for cash-out refinancings (same table)--those don't seem to be helping home ownership, and actually reflect a higher risk segment of mortgage loans. So, Fannie and Freddie own a huge amount of their own product, which is notoriously difficult to hedge, have bought a lot of product fore the sake of buying, and seem to have a portfolio composition that is slightly different from it's purpose... Well, holdon. It gets even better!

3. Fannie and Freddie were the largest buyers of sub-prime mortgage bonds and commercial mortgage-backed securities. Look at any securitization, look at the AAA-rated portions, and if there is a class that is all loans considered "conforming balance" or have amounts that generally conform to the agencies' maximum loan size limits, then you know those were purchased by an agency. At the end of 2007 Freddie owned $100 billion of these sub-prime securities (according to OFHEO, page 43, pdf) where 21% of loans were 60+ days delinquent. Fannie Mae has about 13% of it's portfolio, which was an average of $725 billion during 2007 (from their filings), or $94 billion. Now, if regulators understood these products, they would understand that securitizations are structured in a way that Fannie and Freddie could be at risk for a decline in value of their own securities that occurs from the performance of the other assets--the ones that have nothing to do with their goals and charter. I would even challenge anyone who thinks that congress would agree with the programs that Fannie and Freddie use to support their mission ... I've been on calls with people discussing how Fannie and Freddie merely need to be able to claim something passed the most cursory of tests to take on a $1+ billion loan. Providing the opportunity to afford housing to credit worthy indivisuals has nothing to do with buying CMBS and sub-prime RMBS.

What does all this point to? Seemingly a massive amount of "mission creep" for the agencies that lead them to be over-levered, in increasingly risky products, and in an accounting and hedging nightmare.

Libertarian Legacy? Ron Paul's Campaign Manager, 49, Dies Uninsured, Of Pneumonia, Leaving family $400,000 Debt

The Huffington Post is cited almost daily for it's political insights. And is highly regarded as a voice in the alternative press circuit.

But somehow this article chooses to mock the lack of an insurance policy.

Clearly Ron Paul as president would be bad for the Fed, and all our current financial institutions, certainly bad for them if they want to continue as they are.

If counting big money is your thing, then you might not miss this campaign manager. What a shame the article is reduced to having elements of mockery.

And frankly, on face value, being 49 and dyeing of pneomonia is a little suspect.

The article leaves us feeling that we are safer without Ron Pauls policies, with the financial institutions as they are. That is, the campaign manager  would have been better off with his faith in the Insurance companies.

The report also shows that one in every 501 U.S. households received a foreclosure filing during the month.

“June was the second straight month with more than a quarter million properties nationwide receiving foreclosure filings,” said James J. Saccacio, chief executive officer of RealtyTrac. “Foreclosure activity slipped 3 percent lower from the previous month, but the year-over-year increase of more than 50 percent indicates we have not yet reached the top of this foreclosure cycle. Bank repossessions, or REOs, continue to increase at a much faster pace than default notices or auction notices. REOs in June were up 171 percent from a year ago, while default notices were up 38 percent and auction notices were up 22 percent over the same time period.”

Nevada, California and Arizona continued to document the three highest state foreclosure rates in June.  Florida, Michigan, Ohio, Colorado, Georgia, Indiana and Utah were other states that made the top ten.

For the third month in a row, California and Florida cities accounted for nine out of the top 10 metropolitan foreclosure rates among the 230 metropolitan areas tracked in the report.

RealtyTrac noted that "Foreclosure filings were reported on 8,713 Nevada properties during the month, up nearly 85 percent from June 2007, and one in every 122 Nevada households received a foreclosure filing — more than four times the national average."

"One in every 192 California properties received a foreclosure filing in June, the nation’s second highest state foreclosure rate and 2.6 times the national average."

"One in every 201 Arizona properties received a foreclosure filing during the month, the nation’s third highest state foreclosure rate and nearly 2.5 times the national average. Foreclosure filings were reported on 12,950 Arizona properties, down less than 1 percent from the previous month but still up nearly 127 percent from June 2007."

"Foreclosure filings were reported on 68,666 California properties in June, down nearly 5 percent from the previous month but still up nearly 77 percent from June 2007. California’s total was highest among the states for the 18th consecutive month."

"Florida continued to register the nation’s second highest foreclosure total, with foreclosure filings reported on 40,351 properties in June — an increase of nearly 8 percent from the previous month and an increase of nearly 92 percent from June 2007. One in every 211 Florida properties received a foreclosure filing during the month, the nation’s fourth highest state foreclosure rate and 2.4 times the national average."

"Foreclosure filings were reported on 13,194 Ohio properties in June, the nation’s third highest state foreclosure total. Ohio’s foreclosure activity increased 7 percent from the previous month and 11 percent from June 2007. The state’s foreclosure rate ranked No. 6 among the 50 states. Other states in the top 10 for total properties with filings were Arizona, Michigan, Texas, Georgia, Nevada, Illinois and New York."

"Seven California metro areas were in the top 10, and the top three rates were in California: Stockton, with one in every 72 households receiving a foreclosure filing; Merced, withone in every 77 households receiving a foreclosure filing; and Modesto, with one in every 86 households receiving a foreclosure filing. Other California metro areas in the top 10 were Riverside-San Bernardino at No. 5; Vallejo-Fairfield at No. 7; Bakersfield at No. 8; and Salinas-Monterey at No. 10."

"The top metro foreclosure rate in Florida was once again posted by Cape Coral-Fort Myers, where one in every 91 households received a foreclosure filing — fourth highest among the nation’s metro foreclosure rates. The foreclosure rate in Fort Lauderdale, Fla., ranked No. 9. LasVegas continued to be the only city outside of California and Florida with a foreclosure rate ranking among the top 10. One in every 99 Las Vegas households received a foreclosure filing in June, more than five times the national average and No. 6 among the metro areas."

"Metro areas with foreclosure rates among the top 20 included Phoenix at No. 12, Detroit at No. 13, Miami at No. 15 and San Diego at No. 17"

RealtyTrac does not expect foreclosure activity to ease up until 2009.

Among the key findings of the latest report from Radar Logic:

• The broad housing slump continued as consumers showed persistent lack of confidence and difficulty in financing home purchases.
• April 2008 continued to exhibit price per square foot (PPSF) weakness compared to last year in almost all markets. One MSA showed net year-over-year PPSF appreciation, one was neutral, and 23 declined.
• The Manhattan Condo market showed a 3.6% increase in PPSF year-over-year coupled with an increase in recent transactions despite a modest decline of 0.7% in month-over-month prices.
• Charlotte’s increase of 1.5% in year-over-year PPSF moved its rank among the 25 MSAs to number 1. This represents an increase over the 0.1% year-over-year PPSF appreciation last month.
• Columbus showed year-over-year PPSF appreciation of 0.2% for April 2008, which is an increase from last month’s year-over-year decline of 4.3%.
• New York declined 3.0% year-over-year in April 2008, its second decline in Radar Logic’s published history (beginning in 2000).
• Sacramento, the lowest-ranking MSA, showed a 31.7% decline from April 2007, which is consistent with last month’s decline of 30.6%.

 The ten biggest declines in per-square-foot values from last year were in these markets:

Sacramento (-31.7%)

Las Vegas (-29.9%),

San Diego (-28.1%)

Phoenix (-25.6%).

Los Angeles/Orange County (-23.4%).

Miami (-22.4%).

St. Louis (-19.8%).

San Francisco (-19.7%).

Tampa (-16.6%).

Detroit (-16.1%).

You can read the full Radar Logic report here.

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If you are just looking for any list of the largest banks, then you can find a list here  - Largest banks list. If you are looking for a more detailed list with figures and statistics then your best bet is Google or any of the finance websites such as ft.com or Yahoo finance. These sites may have the type of information you are after.

You could also just go to any major search engine and do a search for 'largest banks list'. You might find a list of sites which feature such a list. Of course you will still have to do a little bit of research before you can find what you are looking for. 

If nothing comes up try Google Answers or Yahoo Answers. Ask the question and someone will answer it. Forums are also great for research too.

• Risk management and organization surrounding risk management
• Business mixes and core competencies
• Management structure and other nuances of configuring management roles
• Proprietary trading / risk taking
• Technology
• Operations and support roles
• Ownership / corporate structure and other things (owned by a bank or not, for example)
• Deciding on what, if any, presence in consumer markets should exist
• Compensation
• Culture and approach to H.R. and other people issues
• Reviews and performance management
• Anything else that comes to mind

I think that feedback on other areas or how to group these would be interesting to receive. The first one of these issues I think should be tackled is technology. It's a topic I have thought a lot about and is extremely important in figuring out how day-to-day operations occur. I hope to have this up shortly. I have lots of skeletons of these entries written about, and more thoughts, so hopefully this series will have a lot of meat to it soon.

The firm's "Distressed Real Estate Initiative" will involve at least 16 core lawyers in ten offices throughout the country, including those in Mid-Atlantic and Western locations hardest hit by the housing bust and the mortgage crisis, including Los Angeles and Las Vegas.

The purpose of the section, according to the firm, will be "to provide representation in acquisition, restructuring and bankruptcy matters."

 "In this period of turmoil in the financial markets and economic uncertainty, new real estate opportunities and challenges present themselves," said Michael Sklaroff, chair of Ballard's Real Estate Department. "We stand ready to serve clients with respect to existing positions and also in assisting them in acquisitions and debt and equity investments in troubled projects."

Ballard Spahr Andrews & Ingersoll was founded in 1886 and now employs more than 550 lawyers in twelve offices located throughout the mid-Atlantic corridor and the western United States.

When there is blood in the water, the sharks will appear.

In addition, the company will be required to pay more than $5 million in back assessments the company failed to pay.

Gregoire also announced the state is seeking to revoke Countrywide’s license to do business in Washington for its alleged illegal activity.

Joining Gregoire at today’s announcement was Deb Bortner, director of consumer services at the Washington state Department of Financial Institutions (DFI), and James Kelly, president of the Urban League of Metropolitan Seattle.

“The allegation that Countrywide preyed on minority borrowers is extremely troubling to me,” Gregoire said. “And I hope to learn eventually just how much this may have contributed to foreclosures in our state. The allegation offers evidence that Countrywide engaged in a pattern to target minority groups and engage in predatory practices.”

“That’s why we intend to bring the full weight of the state on Countrywide to rewrite home loans for minority borrowers who may have been misled into signing predatory mortgages,” the governor noted. “My job is to protect hard-working Washingtonians, and protect them we will.”

DFI is required to examine every home-lender licensed in the state of Washington. The agency conducted its fair lending examination of Countrywide last year. At that time, DFI looked at roughly 600 individual loan files and uncovered evidence that Countrywide engaged in discriminatory lending that targeted Washington’s minority communities. The agency also found significant underreporting of loans during its investigation.

“The Urban League is seeing far too many families caught up in the mortgage crisis who are being steered into bad loans,” stated James Kelly. “Today’s announcement from the governor is consistent with her message of protecting Washingtonians from national mortgage instability.”

DFI sent Countrywide a statement of charges on June 23, notifying the company of the fine and the back assessments the state plans to pursue.  Washington says that the investigation continues.

We have written on the disproportionate impact that the mortgage meltdown and housing crisis has had on minorities.

Washington's action against Countrywide comes on the heels of lawsuits for fraud, deception, and unfair trade practices filed against Countrywide by the states of Illinois, California, and Florida.

The Florida lawsuit claims that Countrywide put borrowers into mortgages they couldn't afford or loans with rates and penalties that were misleading.

As in the Illinois and California actions, Countrywide CEO Executive Angelo Mozilo was also named as a defendant.

Here you can read the complaint filed Broward County Circuit Court in Attorney General, Department of Legal Affairs, State of Florida v. Countywide Financial Corp., Countrywide Home Loans Inc., and Angelo Mozilo.

Here you can read our earlier reports on the Illinois and California lawsuits against Countrywide.

In filing the lawsuit, Florida Attorney General William "Bill" McCollum said that “It is unthinkable that a company would try to take advantage of someone’s dream of homeownership. Florida homeowners who are trying to protect their homes from foreclosures shouldn’t have to worry about their mortgage brokers or lenders unfairly profiting at their expense.”

"Similar to other mortgage lenders, Countrywide attempted to generate large numbers of mortgage loans for resale on the secondary mortgage market. In doing so, the company purportedly originated loans with little concern about whether the borrower could afford and maintain payments on these loans. In the process, the company allegedly eased or ignored its own underwriting standards and encouraged borrowers to enter into “teaser” rates while concealing or misrepresenting that much larger payments would become due."

According to Marc Taps of Legal Services of North Florida, "Our legal services programs throughout the state have seen a large number of clients who are now in default on mortgages written by Countrywide. It appears to us Countrywide did no due diligence and accepted applications which were patently fraudulent and reflected no ability on the part of the borrowers to make the required payments. We cannot help but conclude that the most financially unsophisticated segment of the population was targeted by the brokers who knew Countrywide would write these mortgages.”

The lawsuit also claims that Countrywide hid any potentially negative effects of “teaser” loans, including rising rates, prepayment penalties and negative amortization, which borrowers would inevitably face if they were making minimum payments or trying to refinance.

Traditionally, lenders require borrowers to document income and assets, but investigators with the Attorney General’s Office believe Countrywide offered reduced or no documentation loan programs to increase its loan sales. Countrywide also allegedly paid greater compensation to brokers for loans with higher interest rates and prepayment penalties because it could sell those loans for higher prices on the secondary market.

The Florida Attorney General's Office also asserts that "[Countrywide's] deceptive marketing practices were supposedly designed to sell costly loans while hiding or misrepresenting the terms and dangers. Countrywide’s deceptive sales practices resulted in a large number of loans ending in default and foreclosure, with the company reporting earlier this year that more than 25 percent of its subprime loans were delinquent. The Attorney General’s Office received more than 150 complaints about Countrywide, prompting a subpoena in February and ultimately leading to today’s lawsuit."

In a sign that the growing state legal assault on Countrywide is a bipartisan project, McCollum is the first Republican state attorney general to sue Countrywide.

As we've observed before, Countrywide's expanding legal troubles do not bode well for Bank of America, which plans to acquire Countrywide.

Adding to the pressure on Bank of America to abandon the Countrywide deal, McCollum vowed that he would go after Bank of America's assets to pay for the damages owed by Countrwide if the sale goes through.

Florida asks consumers who believe they have been victimized by Countrywide to call the Attorney General’s fraud hotline at 1-866-966-7226 or  file a complaint online at: http://myfloridalegal.com.

 UPDATE:

The state of Washington is expected to file a lawsuit against Countrywide soon, accusing Countrywide of discriminating against minority borrowers. The state wants to fine the mortgage lender and revoke its license to conduct business in the state.

First of all, Treasury Undersecretary Ryan pronounced that it may be in our best interest to let some financial institutions fail. What this means is that the Federal Reserve is out of ammo for Bear-Stearns like bail-outs for stockholders. One of my long-shot predictions for 2008 (see "2008 Predictions") was the failure of a major financial institution. Well, hold onto your hats because there may be more than one coming! The mortgage default mess has ravaged the balance sheets of banks. Only a day or so later, Citigroup announced that it will have to take yet another $9 billion in write-offs. By and large, these mortgage defaults and foreclosures are by average folks like you and me who just can't make ends meet anymore, thanks to the failure of wages to keep pace with inflation, thanks to the millions of job losses due to our enormous trade deficit.

Then came the Federal Reserve's decision to leave interest rates unchanged, and the accompanying announcement that it's worried about inflation. The Fed has found that it's interest-cutting campaign of the past few months has been totally ineffective in restoring the economy because the low rates haven't translated into reduced lending rates at the consumer level. Why? Because treasury yields didn't drop a bit. Why? Because the Fed's bond auctions have gone poorly. Investors won't buy them when they can get better interest rates elsewhere which, currently, is almost anywhere. This is why credit is drying up, seizing up the economy. Why does the government need to keep selling more and more treasury bonds? To finance its budget deficit, largely due to programs to offset the negative consequences of our trade deficit.

So if the Fed's interest cutting has all been illusory, will the Fed now raise rates to fight inflation? It may, but it knows that it's equally powerless here as well. The inflation we're experiencing is due to the decline in the dollar. Interest rate moves by the Fed will do virtually nothing to affect this. The decline in the dollar is due to our persistent, enormous trade deficit. We've been flooding the world with dollars and the over-supply is steadily eroding their value. One third of the trade deficit is due to oil imports and two thirds is due to imports of manufactured goods. You may ask, "won't the decline of the dollar help reverse the trade deficit?" That's what economists would have you think, but it's not true because the value of the dollar has nothing to do with the trade deficit. The trade deficit is due almost entirely to the collision of economic forces I warned of in Five Short Blasts - the inability of overpopulated nations to bring to the trade table an equivalent market in exchange for access to ours. The fact that the trade deficit has held steady while the dollar has declined dramatically is proof of this.

So the Fed is caught between a rock and a hard place. It's only recourse to affect the direction of the economy is the one that its chairman, Ben Bernanke, may find the most distasteful (for him) of all: admit that free trade (what I call blind trade) is a failed economic model and press the President and Congress to begin imposing tariffs as necessary to eliminate the trade deficit. Failing this, the U.S. economy will continue to unravel, which is now happening at an alarming rate as the financial, manufacturing and construction sectors of the economy are simultaneously nearing collapse.

One final item of interest is that Barack Obama had a meeting with CEO's of major U.S. companies. This is significant because the deteriorating economy assures that Obama will soon be president. Such a meeting calls to mind a similar meeting that Dick Cheney held with energy industry leaders soon after election to seek advice in formulating energy policy. We all know how that turned out. Let's hope Obama's meeting doesn't yield similar results. What did the CEO's tell Obama? Only Ford CEO Alan Mulally (sp?) was talking afterwards and made some vague reference to emphasizing the importance of government and industry working together.

So no one's talking, but I can tell you exactly what each one of them told Obama: 1) "We need tax breaks," and 2) "Beware of protectionist trade sentiment. Everything will be alright if we just have more free trade."  Frankly, I don't worry that much about tax policy. It takes a certain amount of revenue to run an orderly society and, regardless of how it's collected, in the end it will be paid by you and me, either directly to the government or indirectly, in the form of higher prices paid for goods. But, regarding the second item above, we can only hope that Obama can see through the smoke and mirrors of free trade pushers and cheerleaders and put the nation's interests ahead of those of global corporations. He'd better. He certainly doesn't want to leave the economy in far worse shape than he found it, as his predecessor has.

In a lawsuit filed this morning in Los Angeles Superior Court, California Attorney General Jerry Brown sued Countrywide Financial, its chief executive Angelo Mozilo, and president David Sambol, for engaging in deceptive advertising and unfair competition by pushing homeowners into mass-produced, risky loans for the sole purpose of reselling the mortgages on the secondary market.

The lawsuit alleges that Countrywide Financial used deceptive tactics to push homeowners into complicated, risky, and expensive loans so that the company could sell as many loans as possible to third-party investors. 

The complaint also alleges that the company marketed complex and difficult to understand loans with very low initial or “teaser” interest rates or payments. Countrywide employees, including loan officers, underwriters, and branch managers--who were under intense pressure to process a constantly increasing number of loans--misrepresented or obfuscated the fact that borrowers who obtained certain types of loans would experience dramatic increases in monthly payments.

Here you can read the complaint filed in California v. Countrywide Financial Corp, Full Spectrum Lending, Angelo Mozilo, and David Sabol.

According to the Calfornia Attorney General's Office, "In the past, lenders like Countrywide sold home loans to customers and held the loans in their own portfolio, an incentive to maintain strong underwriting standards. Countrywide, however, sold its loans to third-parties in the form of securities or whole loans, often earning more profit for riskier loans. The business model generated windfall profits for Countrywide."

"The company pushed these loans by emphasizing a low “teaser” or initial rate, often as low as 1 percent for pay option ARMs. Countrywide obscured the negative effects--including rising rates, prepayment penalties and negative amortization--which would inevitably result from making minimum payments or trying to refinance. The company misrepresented or hid the fact that borrowers who obtained its home loans--including exploding adjustable rates and negatively amortizing loans--would experience dramatic increases in monthly payments."

"In an effort to rope in as many customers as possible, Countrywide greatly relaxed and liberally granted exceptions to its mortgage lending standards. Traditionally, lenders required borrowers to document income and assets but Countrywide offered reduced or no documentation loan programs to increase its loan sales. Angelo Mozilo and David Sambol actively pushed for easing underwriting standards and granting exceptions to documentation requirements."

"In Countrywide’s 2006 annual report, the company touted the massive growth of its loan production from $62 billion in 2000 to $463 billion in 2006--three times the increase of the U.S. residential loan production market, which tripled from $1.0 trillion in 2000 to $2.9 trillion in 2006. 26 percent of Countywide loans were for California properties. The company sold an ever-increasing number of loans in an effort to gain a 30 percent market share of loan originations and then sell its loans on the secondary market, as mortgage-backed securities or pools of whole loans. Countrywide’s securities trading volume increased from $647 billion in 2000 to $3.8 trillion in 2006."

"Countrywide routinely sold loans based upon a borrower’s stated income and without verifying the information. Loan officers memorized scripts that marketed low payments by focusing on the potential customer’s dissatisfaction, saying, for example, 'Which would you rather have, a long-term fixed payment, or a short-term one that may allow you to realize several hundred dollars a month in savings?' The loan officer did not state that the payment on this new loan would exceed the payment on the current loan.

"Countrywide paid greater compensation to brokers for loans with a higher interest rates, as well as prepayment penalties, because it could sell those loans for higher prices on the secondary market. Countrywide also paid rebates to brokers who originated loans with prepayment penalties, adjustable rates and high margins."

"Countrywide operated an extensive telemarketing operation in which it touted its expertise and claimed to find the best financial options for customers. Customer Service representatives at Countrywide call centers were required to complete calls within three minutes, often processing sixty-five to eight-five calls per day. Employees who did not meet quotas were terminated. The company’s deceptive marketing practices, designed to sell costly loans while hiding or misrepresenting the terms and dangers, included:

• Encouraging borrowers to refinance or obtain financing with complicated mortgage instruments like hybrid adjustable rate mortgages or payment option adjustable mortgages;
• Marketing complex loan products by emphasizing a very low “teaser” rate while misrepresenting the steep monthly payments, increased interest rates and risk of negative amortization;
• Dramatically easing underwriting standards to qualify more people for loans;
• Using low or no-documentation loans which allowed no verification of stated income;
• Hiding total monthly payment obligations by selling homeowners a second mortgage in the form of a home equity line of credit;
• Making borrowers sign a large stack of documents without provider time to read the paperwork; and
• Misrepresenting or hiding the fact that loans had prepayment penalties."

"As the secondary market’s appetite for loans increased, Countrywide further relaxed its standards to finance borrowers with ever-decreasing credit scores. Countrywide employees routinely overrode the company’s computerized underwriting system, known as CLUES, which issued loan analysis reports recommending or discouraging loans based on factors such as a consumer’s credit rating. As the pressure to produce loans increased, Countrywide set up an entire department in Plano, Texas, at the direction of Mozilo and Sambol, where employees could submit requests for underwriting exceptions. In 2006, 15,000 to 20,000 loans a month were processed through this exception process.>

"Countrywide’s deceptive sales practices resulted in a large number of loans ending in default and foreclosure. According to Countrywide’s February 2008 records, a staggering 27 percent of its subprime mortgages were delinquent. Overall, approximately 20,000 Californians lost their homes to foreclosure in May 2008 and 72,000 California homes were in default, roughly 1 out of 183 homes."

"Despite receiving numerous complaints from borrowers claiming that they did not understand their loan terms, Countrywide ignored loan officer’s deceptive practices and loose underwriting standards. Countrywide also pushed its borrowers to serially refinance, repeatedly urging borrowers to obtain home loans to pay off their current debt."

The California Attorney General's Office asks that consumers who believe they have been victimized by Countrywide Consumers should file a complaint by contact the Attorney General’s Public Inquiry Unit in writing at Attorney General's Office California Department of Justice Attn: Public Inquiry Unit P.O. Box 944255, Sacramento, California or through an online complaint form available at http://ag.ca.gov/contact/complaint_form.php?cmplt=CL

Here you can read the complaint in Illinois v. Countrywide Financial Corp., Countywide Home Loans Inc., Full Spectrum Lending, Countrywide Home Loans Servicing LP, and Angelo R. Mozilo. 

The lawsuit, which will be filed on Wednesday in Cook County, accuses Countrywide and Mozilo of improper underwriting standards, structuring loans with risky features, and misleading consumers with hidden fees and fake marketing claims, including its still heavily advertised “no closing costs loan.” 

The complaint also alleges that Countrywide created incentives for its employees and brokers to sell questionable loans by paying them more on such sales.

The lawsuit asks for an unspecified amount of monetary damages and requests that the court require Countrywide to rescind or reform all the questionable loans it sold from 2004 through the present. 

In addition, the lawsuit asks the Court to require that Mozilo personally contribute to paying the damages.

Illinois Attorney General Lisa Madigan also asks the court for 90 days to review any loans currently in foreclosure or moving toward foreclosure.

The complaint states that Countrywide was the largest lender in Illionis from 2004 through 2006, selling about 94,000 loans to consumers in the state. The company operated about 100 retail branch offices in Illinois and its loans were also offered by Illinois mortgage brokers. Countrywide also purchased loans through a network of 2,100 correspondent lenders in the state.

The complaint also describes dubious practices in Countrywide’s huge servicing arm, which oversees $1.5 trillion in loans. 

For example, the complaint alleges that an Illinois consumer whose Countrywide mortgage was in foreclosure came home to find that the company had changed her locks and boarded up her home, although no judgment had been entered and no foreclosure sale conducted, and that It took a week for the homeowner to regain access to her home.

Attorney General Madigan claims that “People were put into loans they did not understand, could not afford and could not get out of. This mounting disaster has had an impact on individual homeowners statewide and is having an impact on the global economy. It is all from the greed of people like Angelo Mozilo.”

The lawsuit is being filed on the same day that Countrywide's shareholders will meet to decide whether to agree to a sale of the company to Bank of America.

We've written before about why we think that Bank of America will ultimately pull out of the deal. 

Adding to the arguments that we earlier made against Bank of America's purchase of Countrywide, the New York Times notes that "The lawsuit adds to the considerable legal risks facing Bank of America as it prepares to absorb Countrywide in a takeover announced in January. Countrywide and its executives have been named as defendants in shareholder lawsuits, and the company’s practices are the subject of investigations by the Securities and Exchange Commission, the F.B.I. and the Federal Trade Commission, which oversees loan servicing companies."

In