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Break up the megabanks already (#OWS)
For the past few months at Occupy we’ve been focusing more and more on having a single message and goal. That has been to break up the big banks.
What’s great about this goal is that it’s a non-partisan issue; there is growing consensus (among non-bankers) from the left and the right that the current situation is outrageous and untenable. What’s not great, of course, is that the situation is so easy to spot because it’s so heinous.
Yesterday another voice joined the Break-Up-The-Big-Banks chorus in the form of an editorial at Bloomberg (hat tip Hannah Appel). They wrote a persuasive piece on breaking up the big banks based on simple arithmetic involving bank profits and taxpayer subsidy. Even the title fits that description: “Why Should Taxpayers Give Big Banks $83 Billion a Year?”. Here’s an excerpt from the editorial (emphasis mine):
…Banks have a powerful incentive to get big and unwieldy. The larger they are, the more disastrous their failure would be and the more certain they can be of a government bailout in an emergency. The result is an implicit subsidy: The banks that are potentially the most dangerous can borrow at lower rates, because creditors perceive them as too big to fail.
Lately, economists have tried to pin down exactly how much the subsidy lowers big banks’ borrowing costs. In one relatively thorough effort, two researchers — Kenichi Ueda of the International Monetary Fund and Beatrice Weder di Mauro of the University of Mainz — put the number at about 0.8 percentage point. The discount applies to all their liabilities, including bonds and customer deposits.
Big Difference
Small as it might sound, 0.8 percentage point makes a big difference. Multiplied by the total liabilities of the 10 largest U.S. banks by assets, it amounts to a taxpayer subsidy of $83 billion a year. To put the figure in perspective, it’s tantamount to the government giving the banks about 3 cents of every tax dollar collected.
The top five banks — JPMorgan, Bank of America Corp., Citigroup Inc., Wells Fargo & Co. and Goldman Sachs Group Inc. – - account for $64 billion of the total subsidy, an amount roughly equal to their typical annual profits (see tables for data on individual banks). In other words, the banks occupying the commanding heights of the U.S. financial industry — with almost $9 trillion in assets, more than half the size of the U.S. economy – would just about break even in the absence of corporate welfare. In large part, the profits they report are essentially transfers from taxpayers to their shareholders.
Next time someone tells me I want to take money out of rich people’s pockets (and that makes me a free market hater), I’m going to remind them that every time I pay taxes, 3 cents out of every dollar (that I know of) goes directly to the banks for no good reason whatsoever except the fact that they have the lobbyists to support this system. They’re bullies, and I hate bullies.
So no, I’m not suggesting we take honestly earned money out of the pockets of those who deserve it, I’m suggesting we stop stuffing insiders’ pockets with our money. Big difference.
But it’s not just money I object to – it’s future liability. There’s now an established track record of discovered criminal acts that don’t get anyone at the big banks in trouble. We are setting ourselves up for an even bigger bailout of some form soon, one that we taxpayers really may not be able to afford.
I think of the too-big-to-fail problem as like having an alcoholic brother-in-law who not only sleeps on your couch every night but also knows the PIN code on your ATM card. The money is irksome, no doubt, but what if that guy fell asleep smoking a cigarette and me and my kids die in the resulting fiery inferno? And it’s not that I think all addicts could be magically cured, but I don’t want them to have access to my personal stuff. Get them out of my house.
So can we break up the megabanks already? I’d really like to stop worrying about them because I have better things to do.
Occupy HSBC: Valentine’s Day protest at noon #OWS
Protest with #OWS Alternative Banking Group
I’m writing to invite you to a protest against mega-bank HSBC at noon on Valentine’s Day (Thursday) starting on the steps of the New York Public Library at 42nd and 5th. Details are here but it’s the big green box on the map on the Fifth Avenue side:
Why are we protesting?
Like you, I’m sure, I’d like nothing more than to stop worrying about shit that goes on in our country’s banks.
We have better things to do with out time than to get annoyed over enormous bonuses being given to idiots for their repeated failures. We’re frankly exhausted from the outrage.
I mean, the average person doesn’t have a job where they get an $11 million bonus instead of a $22 million dollar bonus when they royally screw up. Outside the surreal realm of international banking, the normal response to screw-ups on that level is to get fired.
You might expect a company that has been caught criminally screwing minorities out of fair contracts might be at risk of being closed down, but in this day and age you’d know that big banks, or TIBACO (too interconnected, big, and complex to oversee) institutions, as we in Alt Banking like to call them, are immune to such action.
There’s a clear evolving standard of treatment in the banking sector when it comes to criminal activity:
- the powers that be (SEC, DOJ, etc.) make a huge production over the severity of the fine,
- which is large in dollar amounts but
- usually represents about 10% of the overall profit the given banks made during their exploit.
- Nobody ever goes to jail, and
- the shareholders pay the fine, not the perpetrators.
- The perps get somewhat diminished bonuses. At worst.
The bottomline: we have an entire class of citizens that are immune to the laws because they are considered too important to our financial stability.
But why HSBC?
HSBC is a perfect example of this. An outrageous example.
HSBC didn’t get a bailout in 2008 like many other banks, even though they were ranked #2 in subprime mortgage lending. But that’s not because they didn’t lose money – in fact they lost $6 billion but somehow kept afloat.
And now we know why.
Namely, they were money-laundering, earning asstons by facilitating drugs and terrorism. This was blood money, make no mistake, and it went directly into the pockets of HSBC bankers in the form of bonuses.
When this years-long criminal mafia activity was discovered, nothing much happened beyond a fine, as per usual. Well, to be honest, they were fined $1.9 billion dollars, which is a lot of money, but is only 5 weeks of earnings for the mammoth institution – depending on the way you look at it, HSBC is the 2nd largest bank in the world.
Too big to jail
And that’s when “Too big to fail” became “Too big to jail.” Even the New York Times was outraged. From their editorial page:
Federal and state authorities have chosen not to indict HSBC, the London-based bank, on charges of vast and prolonged money laundering, for fear that criminal prosecution would topple the bank and, in the process, endanger the financial system. They also have not charged any top HSBC banker in the case, though it boggles the mind that a bank could launder money as HSBC did without anyone in a position of authority making culpable decisions.
Clearly, the government has bought into the notion that too big to fail is too big to jail. When prosecutors choose not to prosecute to the full extent of the law in a case as egregious as this, the law itself is diminished. The deterrence that comes from the threat of criminal prosecution is weakened, if not lost.
National Threat
You may recall that there was an extensive FBI investigation of OWS before Zuccotti Park was even occupied.
Ironic? As the Village Voice said, “apparently non-violent demonstration against corrupt banking is subject to more criminal scrutiny than actual corrupt banking.”
Question for you: which is the bigger national security threat, OWS or HSBC?
We demand
HSBC needs its license revoked, and there need to be prosecutions. Those who are guilty need to be punished or else we have an official invitation to criminal acts by bankers. We simply can’t live in a country which rewards this kind of behavior.
Mind you, this isn’t just about HSBC. This is about all the megabanks. Citi or BoA are exempt from prosecution, too. Our message needs to be “break up the megabanks”.
I’ll end with what Matt Taibbi had to say about the HSBC settlement:
On the other hand, if you are an important person, and you work for a big international bank, you won’t be prosecuted even if you launder nine billion dollars. Even if you actively collude with the people at the very top of the international narcotics trade, your punishment will be far smaller than that of the person at the very bottom of the world drug pyramid. You will be treated with more deference and sympathy than a junkie passing out on a subway car in Manhattan (using two seats of a subway car is a common prosecutable offense in this city). An international drug trafficker is a criminal and usually a murderer; the drug addict walking the street is one of his victims. But thanks to Breuer, we’re now in the business, officially, of jailing the victims and enabling the criminals.
Join us on Valentine’s Day at noon on the steps of the New York Public Library and help us Occupy HSBC. Please redistribute widely!
HSBC Valentine’s Day action (#OWS)
We in the Alt Banking group are planning a protest against “too big to jail” bank HSBC for Valentine’s Day. As soon as we started the planning we realized they are utterly ripe for satire with their ridiculous airport posters like this one:
Here’s a new poster for them, courtesy of Nick from our group (and crossposted from the Alt Banking blog):
Readers, can you help us come up with posters and slogans for the event? Bonus if it has to do with a Valentine’s Day theme, along the lines of “You broke my heart, HSBC!” or if it riffs on their slogan, “The World’s Local Bank”. We will be making posters and flyers with this stuff next Sunday afternoon, if you’re going to be up near Columbia you should join us.
Thanks for your help! If you tweet this, don’t forget to use the hashtag #HSBC as a gift to those guys.
update: Public Citizen in Maryland is attempting to revoke HSBC’s bank charter.
Links to videotaped talks and pdf slides
Busy at work today but I wanted to share a few links coming out of talks I gave recently.
First the one I gave at Brown University at the Agnes Conference (October 2012). It’s called “How Math is Used outside Academia”.
Second the one I gave at Stony Brook’s colloquium (December 2012). It has the same title.
These two are videos of the same talk (although with very different audiences), so please don’t watch both of them, you will get bored! If you like friendly audiences, go with Agnes. If you like to watch me getting heckled, go with Stony Brook.
[p.s.: I pretty much never watch other people's videos, so please don't watch either one, actually.]
The third talk, which was the shortest, was at the Joint Math Meetings (January 2013) but I don’t think it was taped. It was called Weapons of Math Destruction and the slides are available here (I’ve turned them into a pdf).
Open data and the emergence of data philanthropy
This is a guest post. Crossposted at aluation.
I’m a bit late to this conversation, but I was reminded by Cathy’s post over the weekend on open data – which most certainly is not a panacea – of my own experience a couple of years ago with a group that is trying hard to do the right thing with open data.
The UN funded a new initiative in 2009 called Global Pulse, with a mandate to explore ways of using Big Data for the rapid identification of emerging crises as well as for crafting more effective development policy in general. Their working hypothesis at its most simple is that the digital traces individuals leave in their electronic life – whether through purchases, mobile phone activity, social media or other sources – can reveal emergent patterns that can help target policy responses. The group’s website is worth a visit for anyone interested in non-commercial applications of data science – they are absolutely the good guys here, doing the kind of work that embodies the social welfare promise of Big Data.
With that said, I think some observations about their experience in developing their research projects may shed some light on one of Cathy’s two main points from her post:
- How “open” is open data when there are significant differences in both the ability to access the data, and more important, in the ability to analyze it?
- How can we build in appropriate safeguards rather than just focusing on the benefits and doing general hand-waving about the risks?
I’ll focus on Cathy’s first question here since the second gets into areas beyond my pay grade.
The Global Pulse approach to both sourcing and data analytics has been to rely heavily on partnerships with academia and the private sector. To Cathy’s point above, this is true of both closed data projects (such as those that rely on mobile phone data) as well as open data projects (those that rely on blog posts, news sites and other sources). To take one example, the group partnered with two firms in Cambridge to build a real-time indicator of bread prices in Latin America in order. The data in this case was open, while the web-scraping analytics (generally using grocery-story website prices) were developed and controlled by the vendors. As someone who is very interested in food prices, I found their work fascinating. But I also found it unsettling that the only way to make sense of this open data – to turn it into information, in other words – was through the good will of a private company.
The same pattern of open data and closed analytics characterized another project, which tracked Twitter in Indonesia for signals of social distress around food, fuel prices, health and other issues. The project used publicly available Twitter data, so it was open to that extent, though the sheer volume of data and the analytical challenges of teasing meaningful patterns out of it called for a powerful engine. As we all know, web-based consumer analytics are far ahead of the rest of the world in terms of this kind of work. And that was precisely where Global Pulse rationally turned – to a company that has generally focused on analyzing social media on behalf of advertisers.
Does this make them evil? Of course not – as I said above, Global Pulse are the good guys here. My point is not about the nature of their work but about its fragility.
The group’s Director framed their approach this way in a recent blog post:
We are asking companies to consider a new kind of CSR – call it “data philanthropy.” Join us in our efforts by making anonymized data sets available for analysis, by underwriting technology and research projects, or by funding our ongoing efforts in Pulse Labs. The same technologies, tools and analysis that power companies’ efforts to refine the products they sell, could also help make sure their customers are continuing to improve their social and economic wellbeing. We are asking governments to support our efforts because data analytics can help the United Nations become more agile in understanding the needs of and supporting the most vulnerable populations around the globe, which in terms boosts the global economy, benefiting people everywhere.
What happens when corporate donors are no longer willing to be data philanthropists? And a question for Cathy – how can we ensure that these new Data Science programs like the one at Columbia don’t end up just feeding people into consumer analytics firms, in the same way that math and econ programs ended up feeding people into Wall Street jobs?
I don’t have any answers here, and would be skeptical of anyone who claimed to. But the answers to these questions will likely define a lot of the gap between the promise of open data and whatever it ends up becoming.
Is mathbabe a terrorist or a lazy hippy? (#OWS)
The Occupy narrative, put forth by mainstream media such as the New York Times and led by friends of Wall Street such as Andrew Ross Sorkin, is sad and pathetic. A bunch of lazy hippies, with nothing much in the way of organized demands, and, by the way, nothing much in the way of reasonable grievances either. And moreover, according to Sorkin, Occupy had fizzled as of its first anniversary.
To an earnest reader of the New York Times, in other words, there’s no there there, and we can move on. Nothing to see.
From my perspective as an active occupier, this approach of casual indifference has seemed oddly inconsistent with the interest in the #OWS Alternative Banking group from other nations. I’ve been interviewed by mainstream reporters from the UK, Belgium, Canada, France, Germany, and Japan, and none of them seemed as willing to dismiss the movement or our group quite as actively as the New York Times has.
And then there was the country-wide clearing of the parks, which seemed mysteriously coordinated, and the press (yes, the New York Times again) knowing when and where it would happen somehow, and taking pictures of the police gathering beforehand.
Really it was enough to make one consider a conspiracy theory between the authorities and mainstream media.
I’m not one for conspiracy theories, though, so I let it pass. But other people were more vigilant than myself after the coordinated clearings, and, as I learned from this Naked Capitalism post, first Truthout attempted a FOIA request to the FBI, and was told that “no documents related to its infiltration of Occupy Wall Street existed at all”, and then the Partnership for Civil Justice filed a FOIA request which was served.
Turns out there was quite a bit of worry about Occupy among the FBI, and Homeland Security, even before Zuccotti was occupied. Occupy was dubbed a terrorist organization, for example. See the heavily redacted details here.
I guess to some extent this makes sense, as the roots of Occupy are outwardly anarchist, and there is a history of anarchist bombings of the New York Stock Exchange. I guess this could also explain the meetings the FBI and Homeland Security had with the banks and the stock exchange. They wanted to cover their asses in case the anarchists were violent.
On the other hand, by the time they cleared the park the movement was openly peaceful. You don’t get called lazy dirty hippies because you’re throwing bombs into buildings, after all. And the coordination of the clearing of the parks is no longer a conspiracy, it’s verified. They were clearly afraid of us.
So which is it, lazy hippy or scary terrorist? There’s a baffling disconnect.
The truth, in this case, is not in between. Instead, Occupy lives in a different plane altogether, as I’ll explain, and this in turn explains both the “lazy” and the “scary” narrative.
The “lazy” can be put to rest here and now, it’s just wrong. The response and relief efforts of Occupy Sandy has convincingly shown that laziness is not an underlying principle of Occupy.
But Occupy Sandy did expose some principles that we occupiers have known to be true since the beginning:
- that we must overcome or even ignore structured and rigid rules to help one another at a human level,
- that we must connect directly with suffering and organically respond to it as we each know how to, depending on circumstances, and
- that moral and ethical responsibilities are just plain more important than rules.
Such a nuanced concept might seem, from the outside, to be a bunch of meditating hippies, although you’d have to kind of want to see that to think that’s all it is. So that explains the “lazy” narrative to me: if you don’t understand it, and if you don’t want to bother to look carefully, then just describe the surface characteristics.
Second, the “scary” part is right, but it’s not scary in the sense of guns and bombs – but since the cops, the FBI, and Homeland Security speak in that language, the actual threat of Occupy is again lost in translation.
It’s our ideas that threaten, not our violence. We ignore the rules, when they oppress and when they make no sense and when they serve to entrench an already entrenched elite. And ignoring rules is sometimes more threatening than breaking them.
Is mathbabe a terrorist? Is the Alternative Banking group a threat to national security because we discuss breaking up the big banks without worrying about pissing off major campaign contributors?
I hope we are a threat, but not to national security, and not by bombs or guns, but by making logical and moral sense and consistently challenging a rigged system.
I’m planning to file a FOIA request on myself and on the Alt Banking group to see what’s up.
On trusting experts, climate change research, and scientific translators
Stephanie Tai has written a thoughtful response on Jordan Ellenberg’s blog to my discussion with Jordan regarding trusting experts (see my Nate Silver post and the follow-up post for more context).
Trusting experts
Stephanie asks three important questions about trusting experts, which I paraphrase here:
- What does it take to look into a model yourself? How deeply must you probe?
- How do you avoid being manipulated when you do so?
- Why should we bother since stuff is so hard and we each have a limited amount of time?
I must confess I find the first two questions really interesting and I want to think about them, but I have a very little patience with the last question.
Here’s why:
- I’ve seen too many people (individual modelers) intentionally deflect investigations into models by setting them up as so hard that it’s not worth it (or at least it seems not worth it). They use buzz words and make it seem like there’s a magical layer of their model which makes it too difficult for mere mortals. But my experience (as an arrogant, provocative, and relentless questioner) is that I can always understand a given model if I’m talking to someone who really understands it and actually wants to communicate it.
- It smacks of an excuse rather than a reason. If it’s our responsibility to understand something, then by golly we should do it, even if it’s hard.
- Too many things are left up to people whose intentions are not reasonable using this “too hard” argument, and it gives those people reason to make entire systems seem too difficult to penetrate. For a great example, see the financial system, which is consistently too complicated for regulators to properly regulate.
I’m sure I seem unbelievably cynical here, but that’s where I got by working in finance, where I saw first-hand how manipulative and manipulated mathematical modeling can become. And there’s no reason at all such machinations wouldn’t translate to the world of big data or climate modeling.
Climate research
Speaking of climate modeling: first, it annoys me that people are using my “distrust the experts” line to be cast doubt on climate modelers.
People: I’m not asking you to simply be skeptical, I’m saying you should look into the models yourself! It’s the difference between sitting on a couch and pointing at a football game on TV and complaining about a missed play and getting on the football field yourself and trying to figure out how to throw the ball. The first is entertainment but not valuable to anyone but yourself. You are only adding to the discussion if you invest actual thoughtful work into the matter.
To that end, I invited an expert climate researcher to my house and asked him to explain the climate models to me and my husband, and although I’m not particularly skeptical of climate change research (more on that below when I compare incentives of the two sides), I asked obnoxious, relentless questions about the model until I was satisfied. And now I am satisfied. I am considering writing it up as a post.
As an aside, if climate researchers are annoyed by the skepticism, I can understand that, since football fans are an obnoxious group, but they should not get annoyed by people who want to actually do the work to understand the underlying models.
Another thing about climate research. People keep talking about incentives, and yes I agree wholeheartedly that we should follow the incentives to understand where manipulation might be taking place. But when I followed the incentives with respect to climate modeling, they bring me straight to climate change deniers, not to researchers.
Do we really think these scientists working with their research grants have more at stake than multi-billion dollar international companies who are trying to ignore the effect of their polluting factories on the environment? People, please. The bulk of the incentives are definitely with the business owners. Which is not to say there are no incentives on the other side, since everyone always wants to feel like their research is meaningful, but let’s get real.
Scientific translators
I like this idea Stephanie comes up with:
Some sociologists of science suggest that translational “experts”–that is, “experts” who aren’t necessarily producing new information and research, but instead are “expert” enough to communicate stuff to those not trained in the area–can help bridge this divide without requiring everyone to become “experts” themselves. But that can also raise the question of whether these translational experts have hidden agendas in some way. Moreover, one can also raise questions of whether a partial understanding of the model might in some instances be more misleading than not looking into the model at all–examples of that could be the various challenges to evolution based on fairly minor examples that when fully contextualized seem minor but may pop out to someone who is doing a less systematic inquiry.
First, I attempt to make my blog something like a platform for this, and I also do my best to make my agenda not at all hidden so people don’t have to worry about that.
This raises a few issues for me:
- Right now we depend mostly on press to do our translations, but they aren’t typically trained as scientists. Does that make them more prone to being manipulated? I think it does.
- How do we encourage more translational expertise to emerge from actual experts? Currently, in academia, the translation to the general public of one’s research is not at all encouraged or rewarded, and outside academia even less so.
- Like Stephanie, I worry about hidden agendas and partial understandings, but I honestly think they are secondary to getting a robust system of translation started to begin with, which would hopefully in turn engage the general public with the scientific method and current scientific knowledge. In other words, the good outweighs the bad here.
Open data is not a panacea
I’ve talked a lot recently about how there’s an information war currently being waged on consumers by companies that troll the internet and collect personal data, search histories, and other “attributes” in data warehouses which then gets sold to the highest bidders.
It’s natural to want to balance out this information asymmetry somehow. One such approach is open data, defined in Wikipedia as the idea that certain data should be freely available to everyone to use and republish as they wish, without restrictions from copyright, patents or other mechanisms of control.
I’m going to need more than one blog post to think this through, but I wanted to make two points this morning.
The first is my issue with the phrase “freely available to everyone to use”. What does that mean? Having worked in futures trading, where we put trading machines and algorithms in close proximity with exchanges for large fees so we can get to the market data a few nanoseconds before anyone else, it’s clear to me that availability and access to data is an incredibly complicated issue.
And it’s not just about speed. You can have hugely important, rich, and large data sets sitting in a lump on a publicly available website like wikipedia, and if you don’t have fancy parsing tools and algorithms you’re not going to be able to make use of it.
When important data goes public, the edge goes to the most sophisticated data engineer, not the general public. The Goldman Sachs’s of the world will always know how to make use of “freely available to everyone” data before the average guy.
Which brings me to my second point about open data. It’s general wisdom that we should hope for the best but prepare for the worst. My feeling is that as we move towards open data we are doing plenty of the hoping part but not enough of the preparing part.
If there’s one thing I learned working in finance, it’s not to be naive about how information will be used. You’ve got to learn to think like an asshole to really see what to worry about. It’s a skill which I don’t regret having.
So, if you’re giving me information on where public schools need help, I’m going to imagine using that information to cut off credit for people who live nearby. If you tell me where environmental complaints are being served, I’m going to draw a map and see where they aren’t being served so I can take my questionable business practices there.
I’m not saying proponents of open data aren’t well-meaning, they often seem to be. And I’m not saying that the bad outweighs the good, because I’m not sure. But it’s something we should figure out how to measure, and in this information war it’s something we should keep a careful eye on.
Corporations don’t act like people
Corporations may be legally protected like people, but they don’t act selfishly like people do.
I’ve written about this before here, when I was excitedly reading Liquidated by Karen Ho, but recent overheard conversations have made me realize that there’s still a feeling out there that “the banks” must not have understood how flawed the models were because otherwise they would have avoided them out of a sense of self-preservation.
Important: “the banks” don’t think or do things, people inside the banks think and do things. In fact, the people inside the banks think about themselves and their own chances of getting big bonuses/ getting fired, and they don’t think about the bank’s future at all. The exception may be the very tip top brass of management, who may or may not care about the future of their institutions just as a legacy reputation issue. But in any case their nascent reputation fears, if they existed at all, did not seem to overwhelm their near-term desire for lots of money.
Example: I saw Robert Rubin on stage well before the major problems at Citi in a discussion about how badly the mortgage-backed securities market was apt to perform in the very near future. He did not seem to be too stupid to understand what the conversation was about, but that didn’t stop him from ignoring the problem at Citigroup whilst taking in $126 million dollars. The U.S. government, in the meantime, bailed out Citigroup to the tune of $45 billion with another guarantee of $300 billion.
Here’s a Bloomberg BusinessWeek article excerpt about how he saw his role:
Rubin has said that Citigroup’s losses were the result of a financial force majeure. “I don’t feel responsible, in light of the facts as I knew them in my role,” he told the New York Times in April 2008. “Clearly, there were things wrong. But I don’t know of anyone who foresaw a perfect storm, and that’s what we’ve had here.”
In March 2010, Rubin elaborated in testimony before the Financial Crisis Inquiry Commission. “In the world of trading, the world I have lived in my whole adult life, there is always a very important distinction between what you could have reasonably known in light of the facts at the time and what you know with the benefit of hindsight,” he said. Pressed by FCIC Executive Director Thomas Greene about warnings he had received regarding the risk in Citigroup’s mortgage portfolio, Rubin was opaque: “There is always a tendency to overstate—or over-extrapolate—what you should have extrapolated from or inferred from various events that have yielded warnings.”
Bottomline: there’s no such thing as a bank’s desire for self-preservation. Let’s stop thinking about things that way.
Whom can you trust?
My friend Jordan has written a response to yesterday’s post about Nate Silver. He is a major fan of Silver and contends that I’m not fair to him:
I think Cathy’s distrust is warranted, but I think Silver shares it. The central concern of his chapter on weather prediction is the vast difference in accuracy between federal hurricane forecasters, whose only job is to get the hurricane track right, and TV meteorologists, whose very different incentive structure leads them to get the weather wrong on purpose. He’s just as hard on political pundits and their terrible, terrible predictions, which are designed to be interesting, not correct.
To this I’d say, Silver mocks TV meteorologists and political pundits in a dismissive way, as not being scientific enough. That’s not the same as taking them seriously and understanding their incentives, and it doesn’t translate to the much more complicated world of finance.
In any case, he could have understood incentives in every field except finance and I’d still be mad, because my direct experience with finance made me understand it, and the outsized effect it has on our economy makes it hugely important.
But Jordan brings up an important question about trust:
But what do you do with cases like finance, where the only people with deep domain knowledge are the ones whose incentive structure is socially suboptimal? (Cathy would use saltier language here.) I guess you have to count on mavericks like Cathy, who’ve developed the domain knowledge by working in the financial industry, but who are now separated from the incentives that bind the insiders.
But why do I trust what Cathy says about finance?
Because she’s an expert.
Is Cathy OK with this?
No, Cathy isn’t okay with this. The trust problem is huge, and I address it directly in my post:
This raises a larger question: how can the public possibly sort through all the noise that celebrity-minded data people like Nate Silver hand to them on a silver platter? Whose job is it to push back against rubbish disguised as authoritative scientific theory?
It’s not a new question, since PR men disguising themselves as scientists have been around for decades. But I’d argue it’s a question that is increasingly urgent considering how much of our lives are becoming modeled. It would be great if substantive data scientists had a way of getting together to defend the subject against sensationalist celebrity-fueled noise.
One hope I nurture is that, with the opening of the various data science institutes such as the one at Columbia which was a announced a few months ago, there will be a way to form exactly such a committee. Can we get a little peer review here, people?
I do think domain-expertise-based peer review will help, but not when the entire field is captured, like in some subfields of medical research and in some subfields of economics and finance (for a great example see Glen Hubbard get destroyed in Matt Taibbi’s recent blogpost for selling his economic research).
The truth is, some fields are so yucky that people who want to do serious research just leave because they are disgusted. Then the people who remain are the “experts”, and you can’t trust them.
The toughest part is that you don’t know which fields are like this until you try to work inside them.
Bottomline: I’m telling you not to trust Nate Silver, and I would also urge you not to trust any one person, including me. For that matter don’t necessarily trust crowds of people either. Instead, carry a healthy dose of skepticism and ask hard questions.
This is asking a lot, and will get harder as time goes on and as the world becomes more complicated. On the one hand, we need increased transparency for scientific claims like projects such as runmycode provide. On the other, we need to understand the incentive structure inside a field like finance to make sure it is aligned with its stated mission.
Nate Silver confuses cause and effect, ends up defending corruption
Crossposted on Naked Capitalism
I just finished reading Nate Silver’s newish book, The Signal and the Noise: Why so many predictions fail – but some don’t.
The good news
First off, let me say this: I’m very happy that people are reading a book on modeling in such huge numbers – it’s currently eighth on the New York Times best seller list and it’s been on the list for nine weeks. This means people are starting to really care about modeling, both how it can help us remove biases to clarify reality and how it can institutionalize those same biases and go bad.
As a modeler myself, I am extremely concerned about how models affect the public, so the book’s success is wonderful news. The first step to get people to think critically about something is to get them to think about it at all.
Moreover, the book serves as a soft introduction to some of the issues surrounding modeling. Silver has a knack for explaining things in plain English. While he only goes so far, this is reasonable considering his audience. And he doesn’t dumb the math down.
In particular, Silver does a nice job of explaining Bayes’ Theorem. (If you don’t know what Bayes’ Theorem is, just focus on how Silver uses it in his version of Bayesian modeling: namely, as a way of adjusting your estimate of the probability of an event as you collect more information. You might think infidelity is rare, for example, but after a quick poll of your friends and a quick Google search you might have collected enough information to reexamine and revise your estimates.)
The bad news
Having said all that, I have major problems with this book and what it claims to explain. In fact, I’m angry.
It would be reasonable for Silver to tell us about his baseball models, which he does. It would be reasonable for him to tell us about political polling and how he uses weights on different polls to combine them to get a better overall poll. He does this as well. He also interviews a bunch of people who model in other fields, like meteorology and earthquake prediction, which is fine, albeit superficial.
What is not reasonable, however, is for Silver to claim to understand how the financial crisis was a result of a few inaccurate models, and how medical research need only switch from being frequentist to being Bayesian to become more accurate.
Let me give you some concrete examples from his book.
Easy first example: credit rating agencies
The ratings agencies, which famously put AAA ratings on terrible loans, and spoke among themselves as being willing to rate things that were structured by cows, did not accidentally have bad underlying models. The bankers packaging and selling these deals, which amongst themselves they called sacks of shit, did not blithely believe in their safety because of those ratings.
Rather, the entire industry crucially depended on the false models. Indeed they changed the data to conform with the models, which is to say it was an intentional combination of using flawed models and using irrelevant historical data (see points 64-69 here for more (Update: that link is now behind the paywall)).
In baseball, a team can’t create bad or misleading data to game the models of other teams in order to get an edge. But in the financial markets, parties to a model can and do.
In fact, every failed model is actually a success
Silver gives four examples what he considers to be failed models at the end of his first chapter, all related to economics and finance. But each example is actually a success (for the insiders) if you look at a slightly larger picture and understand the incentives inside the system. Here are the models:
- The housing bubble.
- The credit rating agencies selling AAA ratings on mortgage securities.
- The financial melt-down caused by high leverage in the banking sector.
- The economists’ predictions after the financial crisis of a fast recovery.
Here’s how each of these models worked out rather well for those inside the system:
- Everyone involved in the mortgage industry made a killing. Who’s going to stop the music and tell people to worry about home values? Homeowners and taxpayers made money (on paper at least) in the short term but lost in the long term, but the bankers took home bonuses that they still have.
- As we discussed, this was a system-wide tool for building a money machine.
- The financial melt-down was incidental, but the leverage was intentional. It bumped up the risk and thus, in good times, the bonuses. This is a great example of the modeling feedback loop: nobody cares about the wider consequences if they’re getting bonuses in the meantime.
- Economists are only putatively trying to predict the recovery. Actually they’re trying to affect the recovery. They get paid the big bucks, and they are granted authority and power in part to give consumers confidence, which they presumably hope will lead to a robust economy.
Cause and effect get confused
Silver confuses cause and effect. We didn’t have a financial crisis because of a bad model or a few bad models. We had bad models because of a corrupt and criminally fraudulent financial system.
That’s an important distinction, because we could fix a few bad models with a few good mathematicians, but we can’t fix the entire system so easily. There’s no math band-aid that will cure these boo-boos.
I can’t emphasize this too strongly: this is not just wrong, it’s maliciously wrong. If people believe in the math band-aid, then we won’t fix the problems in the system that so desperately need fixing.
Why does he make this mistake?
Silver has an unswerving assumption, which he repeats several times, that the only goal of a modeler is to produce an accurate model. (Actually, he made an exception for stock analysts.)
This assumption generally holds in his experience: poker, baseball, and polling are all arenas in which one’s incentive is to be as accurate as possible. But he falls prey to some of the very mistakes he warns about in his book, namely over-confidence and over-generalization. He assumes that, since he’s an expert in those arenas, he can generalize to the field of finance, where he is not an expert.
The logical result of this assumption is his definition of failure as something where the underlying mathematical model is inaccurate. But that’s not how most people would define failure, and it is dangerously naive.
Medical Research
Silver discusses both in the Introduction and in Chapter 8 to John Ioannadis’s work which reveals that most medical research is wrong. Silver explains his point of view in the following way:
I’m glad he mentions incentives here, but again he confuses cause and effect.
As I learned when I attended David Madigan’s lecture on Merck’s representation of Vioxx research to the FDA as well as his recent research on the methods in epidemiology research, the flaws in these medical models will be hard to combat, because they advance the interests of the insiders: competition among academic researchers to publish and get tenure is fierce, and there are enormous financial incentives for pharmaceutical companies.
Everyone in this system benefits from methods that allow one to claim statistically significant results, whether or not that’s valid science, and even though there are lives on the line.
In other words, it’s not that there are bad statistical approaches which lead to vastly over-reported statistically significant results and published papers (which could just as easily happen if the researchers were employing Bayesian techniques, by the way). It’s that there’s massive incentive to claim statistically significant findings, and not much push-back when that’s done erroneously, so the field never self-examines and improves their methodology. The bad models are a consequence of misaligned incentives.
I’m not accusing people in these fields of intentionally putting people’s lives on the line for the sake of their publication records. Most of the people in the field are honestly trying their best. But their intentions are kind of irrelevant.
Silver ignores politics and loves experts
Silver chooses to focus on individuals working in a tight competition and their motives and individual biases, which he understands and explains well. For him, modeling is a man versus wild type thing, working with your wits in a finite universe to win the chess game.
He spends very little time on the question of how people act inside larger systems, where a given modeler might be more interested in keeping their job or getting a big bonus than in making their model as accurate as possible.
In other words, Silver crafts an argument which ignores politics. This is Silver’s blind spot: in the real world politics often trump accuracy, and accurate mathematical models don’t matter as much as he hopes they would.
As an example of politics getting in the way, let’s go back to the culture of the credit rating agency Moody’s. William Harrington, an ex-Moody’s analyst, describes the politics of his work as follows:
In 2004 you could still talk back and stop a deal. That was gone by 2006. It became: work your tail off, and at some point management would say, ‘Time’s up, let’s convene in a committee and we’ll all vote “yes”‘.
To be fair, there have been moments in his past when Silver delves into politics directly, like this post from the beginning of Obama’s first administration, where he starts with this (emphasis mine):
To suggest that Obama or Geithner are tools of Wall Street and are looking out for something other than the country’s best interest is freaking asinine.
and he ends with:
This is neither the time nor the place for mass movements — this is the time for expert opinion. Once the experts (and I’m not one of them) have reached some kind of a consensus about what the best course of action is (and they haven’t yet), then figure out who is impeding that action for political or other disingenuous reasons and tackle them — do whatever you can to remove them from the playing field. But we’re not at that stage yet.
My conclusion: Nate Silver is a man who deeply believes in experts, even when the evidence is not good that they have aligned incentives with the public.
Distrust the experts
Call me “asinine,” but I have less faith in the experts than Nate Silver: I don’t want to trust the very people who got us into this mess, while benefitting from it, to also be in charge of cleaning it up. And, being part of the Occupy movement, I obviously think that this is the time for mass movements.
From my experience working first in finance at the hedge fund D.E. Shaw during the credit crisis and afterwards at the risk firm Riskmetrics, and my subsequent experience working in the internet advertising space (a wild west of unregulated personal information warehousing and sales) my conclusion is simple: Distrust the experts.
Why? Because you don’t know their incentives, and they can make the models (including Bayesian models) say whatever is politically useful to them. This is a manipulation of the public’s trust of mathematics, but it is the norm rather than the exception. And modelers rarely if ever consider the feedback loop and the ramifications of their predatory models on our culture.
Why do people like Nate Silver so much?
To be crystal clear: my big complaint about Silver is naivete, and to a lesser extent, authority-worship.
I’m not criticizing Silver for not understanding the financial system. Indeed one of the most crucial problems with the current system is its complexity, and as I’ve said before, most people inside finance don’t really understand it. But at the very least he should know that he is not an authority and should not act like one.
I’m also not accusing him of knowingly helping cover up the financial industry. But covering for the financial industry is an unfortunate side-effect of his naivete and presumed authority, and a very unwelcome source of noise at this moment when so much needs to be done.
I’m writing a book myself on modeling. When I began reading Silver’s book I was a bit worried that he’d already said everything I’d wanted to say. Instead, I feel like he’s written a book which has the potential to dangerously mislead people – if it hasn’t already – because of its lack of consideration of the surrounding political landscape.
Silver has gone to great lengths to make his message simple, and positive, and to make people feel smart and smug, especially Obama’s supporters.
He gets well-paid for his political consulting work and speaker appearances at hedge funds like D.E. Shaw and Jane Street, and, in order to maintain this income, it’s critical that he perfects a patina of modeling genius combined with an easily digested message for his financial and political clients.
Silver is selling a story we all want to hear, and a story we all want to be true. Unfortunately for us and for the world, it’s not.
How to push back against the celebrity-ization of data science
The truth is somewhat harder to understand, a lot less palatable, and much more important than Silver’s gloss. But when independent people like myself step up to denounce a given statement or theory, it’s not clear to the public who is the expert and who isn’t. From this vantage point, the happier, shorter message will win every time.
This raises a larger question: how can the public possibly sort through all the noise that celebrity-minded data people like Nate Silver hand to them on a silver platter? Whose job is it to push back against rubbish disguised as authoritative scientific theory?
It’s not a new question, since PR men disguising themselves as scientists have been around for decades. But I’d argue it’s a question that is increasingly urgent considering how much of our lives are becoming modeled. It would be great if substantive data scientists had a way of getting together to defend the subject against sensationalist celebrity-fueled noise.
One hope I nurture is that, with the opening of the various data science institutes such as the one at Columbia which was a announced a few months ago, there will be a way to form exactly such a committee. Can we get a little peer review here, people?
Conclusion
There’s an easy test here to determine whether to be worried. If you see someone using a model to make predictions that directly benefit them or lose them money – like a day trader, or a chess player, or someone who literally places a bet on an outcome (unless they place another hidden bet on the opposite outcome) – then you can be sure they are optimizing their model for accuracy as best they can. And in this case Silver’s advice on how to avoid one’s own biases are excellent and useful.
But if you are witnessing someone creating a model which predicts outcomes that are irrelevant to their immediate bottom-line, then you might want to look into the model yourself.
If Barofsky heads the SEC I’ll work for it
Neil Barofsky visited my Occupy group, Alternative Banking, this past Sunday. He was awesome.
We discussed the credit crisis, the recent outrageous HSBC ruling which quantified the cost banks near for money laundering for terrorists and drug lords at below cost, and the hopelessness, or on a good day the hope, of having a financial and regulatory system that will eventually work.
We discussed the incentives in the HAMP set-up, which explain why very few homeowners have actually received lasting relief from unaffordable mortgages. We discussed the incentives for fraud and other criminal behavior in the absence of real punishment, that too much money is being spent pursuing insider training because that’s what people understand how to do, and we discussed the reluctance of the regulators to litigate tough cases. We talked about how change has to come from the top, because all of these organizations are super hierarchical and require political will to get things done.
In the past year I was offered a job at the SEC, working as a quant in the enforcement division. Although I want to help sort out this mess, I haven’t felt that this job, which is relatively junior, would allow me to do that meaningfully.
But I came away from the meeting with Barofsky with this feeling: if we had someone in charge at the SEC like him who could speak truth to power and who is smart enough to see through economic jargon and bullshit well enough to understand incentives for fraud and lying, then I’d work there in a heartbeat.
Let’s just hope it doesn’t take another world-wide financial crisis before we get someone like that.
Can we put an ass-kicking skeptic in charge of the SEC?
The SEC has proven its dysfunctionality. Instead of being on top of the banks for misconduct, it consistently sets the price for it at below cost. Instead of examining suspicious records to root out Ponzi schemes, it ignores whistleblowers.
I think it’s time to shake up management over there. We need a loudmouth skeptic who is smart enough to sort through the bullshit, brave enough to stand up to bullies, and has a strong enough ego not to get distracted by threats about their future job security.
My personal favorite choice is Neil Barofsky, author of Bailout (which I blogged about here) and former Special Inspector General of TARP. Simon Johnson, Economist at MIT, agrees with me. From Johnson’s New York Times Economix blog:
… Neil Barofsky is the former special inspector general in charge of oversight for the Troubled Asset Relief Program. A career prosecutor, Mr. Barofsky tangled with the Treasury officials in charge of handing out support for big banks while failing to hold the same banks accountable — for example, in their treatment of homeowners. He confronted these powerful interests and their political allies repeatedly and on all the relevant details – both behind closed doors and in his compelling account, published this summer: “Bailout: An Inside Account of How Washington Abandoned Main Street While Rescuing Wall Street.”
His book describes in detail a frustration with the timidity and lack of sophistication in law enforcement’s approach to complex frauds. He could instantly remedy that if appointed — Mr. Barofsky is more than capable of standing up to Wall Street in an appropriate manner. He has enjoyed strong bipartisan support in the past and could be confirmed by the Senate (just as he was previously confirmed to his TARP position).
Barofsky isn’t the only person who would kick some ass as the head of the SEC – William Cohan thinks Eliot Spitzer would make a fine choice, and I agree. From his Bloomberg column (h/t Matt Stoller):
The idea that only one of Wall Street’s own can regulate Wall Street is deeply disturbing. If Obama keeps Walter on or appoints Khuzami or Ketchum, we would be better off blowing up the SEC and starting over.
I still believe the best person to lead the SEC at this moment remains former New York Governor Eliot Spitzer. He would fearlessly hold Wall Street accountable for its past sins, as he did when he was New York State attorney general and as he now does as a cable television host. (Disclosure: I am an occasional guest on his show.)
We need an SEC head who can inspire a new generation of investors to believe the capital markets are no longer rigged and that Wall Street cannot just capture every one of its Washington regulators.
How to evaluate a black box financial system
I’ve been blogging about evaluation methods for modeling, for example here and here, as part of the book I’m writing with Rachel Schutt based on her Columbia Data Science class this semester.
Evaluation methods are important abstractions that allow us to measure models based only on their output.
Using various metrics of success, we can contrast and compare two or more entirely different models. And it means we don’t care about their underlying structure – they could be based on neural nets, logistic regression, or decision trees, but for the sake of measuring the accuracy, or the ranking, or the calibration, the evaluation method just treats them like black boxes.
It recently occurred to me a that we could generalize this a bit, to systems rather than models. So if we wanted to evaluate the school system, or the political system, or the financial system, we could ignore the underlying details of how they are structured and just look at the output. To be reasonable we have to compare two systems that are both viable; it doesn’t make sense to talk about a current, flawed system relative to perfection, since of course every version of reality looks crappy compared to an ideal.
The devil is in the articulated evaluation metric, of course. So for the school system, we can ask various questions: Do our students know how to read? Do they finish high school? Do they know how to formulate an argument? Have they lost interest in learning? Are they civic-minded citizens? Do they compare well to other students on standardized tests? How expensive is the system?
For the financial system, we might ask things like: Does the average person feel like their money is safe? Does the system add to stability in the larger economy? Does the financial system mitigate risk to the larger economy? Does it put capital resources in the right places? Do fraudulent players inside the system get punished? Are the laws transparent and easy to follow?
The answers to those questions aren’t looking good at all: for example, take note of the recent Congressional report that blames Jon Corzine for MF Global’s collapse, pins him down on illegal and fraudulent activity, and then does absolutely nothing about it. To conserve space I will only use this example but there are hundreds more like this from the last few years.
Suffice it to say, what we currently have is a system where the agents committing fraud are actually glad to be caught because the resulting fines are on the one hand smaller than their profits (and paid by shareholders, not individual actors), and on the other hand are cemented as being so, and set as precedent.
But again, we need to compare it to another system, we can’t just say “hey there are flaws in this system,” because every system has flaws.
I’d like to compare it to a system like ours except where the laws are enforced.
That may sounds totally naive, and in a way it is, but then again we once did have laws, that were enforced, and the financial system was relatively tame and stable.
And although we can’t go back in a time machine to before Glass-Steagall was revoked and keep “financial innovation” from happening, we can ask our politicians to give regulators the power to simplify the system enough so that something like Glass-Steagall can once again work.
Free people from their debt: Rolling Jubilee (#OWS)
Do you remember the group Strike Debt? It’s an offshoot of Occupy Wall Street which came out with the Debt Resistors Operation Manual on the one-year anniversary of Occupy; I blogged about this here, very cool and inspiring.
Well, Strike Debt has come up with another awesome idea; they are fundraising $50,000 (to start with) by holding a concert called the People’s Bailout this coming Thursday, featuring Jeff Mangum of Neutral Milk Hotel, possibly my favorite band besides Bright Eyes.
Actually that’s just the beginning, a kick-off to the larger fundraising campaign called the Rolling Jubilee.
The main idea is this: once they have money, they buy people’s debts with it, much like debt collectors buy debt. It’s mostly pennies-on-the-dollar debt, because it’s late and there is only a smallish chance that, through harassment legal and illegal, they will coax the debtor or their family members to pay.
But instead of harassing people over the phone, the Strike Debt group is simply going to throw away the debt. They might even call people up to tell them they are officially absolved from their debt, but my guess is nobody will answer the phone, from previous negative conditioning.
Get tickets to the concert here, and if you can’t make it, send donations to free someone from their debt here.
In the meantime enjoy some NMH:
When are taxes low enough?
What with the unrelenting election coverage (go Elizabeth Warren!) it’s hard not to think about the game theory that happens in the intersection of politics and economics.
[Disclaimer: I am aware that no idea in here is originally mine, but when has that ever stopped me? Plus, I think when economists talk about this stuff they generally use jargon to make it hard to follow, which I promise not to do, and perhaps also insert salient facts which I don't know, which I apologize for. In any case please do comment if I get something wrong.]
Lately I’ve been thinking about the push and pull of the individual versus the society when it comes to tax rates. Individuals all want lower tax rates, in the sense that nobody likes to pay taxes. On the other hand, some people benefit more from what the taxes pay for than others, and some people benefit less. It’s fair to say that very rich people see this interaction as one-sided against them: they pay a lot, they get back less.
Well, that’s certainly how it’s portrayed. I’m not willing to say that’s true, though, because I’d argue business owners and generally rich people get a lot back actually, including things like rule of law and nobody stealing their stuff and killing them because they’re rich, which if you think about it does happen in other places. In fact they’d be huge targets in some places, so you could argue that rich people get the most protection from this system.
But putting that aside by assuming the rule of law for a moment, I have a lower-level question. Namely, might we expect equilibrium at some point, where the super rich realize they need the country’s infrastructure and educational system, to hire people and get them to work at their companies and the companies they’ve invested in, and of course so they will have customers for their products and the products of the companies they’ve invested in.
So in other words you might expect that, at a certain point, these super rich people would actually say taxes are low enough. Of course, on top of having a vested interest in a well-run and educated society, they might also have sense of fairness and might not liking seeing people die of hunger, they might want to be able to defend the country in war, and of course the underlying rule of law thingy.
But the above argument has kind of broken down lately, because:
- So many companies are off-shoring their work to places where we don’t pay for infrastructure,
- and where we don’t educate the population,
- and our customers are increasingly international as well, although this is the weakest effect since Europeans can’t be counted on that so much what with their recession.
In other words, the incentive for an individual rich person to argue for lower taxes is getting more and more to be about the rule of law and not the well-run society argument. And let’s face it, it’s a lot cheaper to teach people how to use guns than it is to give them a liberal arts education. So the optimal tax rate for them would be… possibly very low. Maybe even zero, if they can just hire their own militias.
This is an example of a system of equilibrium failing because of changing constraints. There’s another similar example in the land of finance which involves credit default swaps (CDS), described very well in this NYTimes Dealbook entry by Stephen Lubben.
Namely, it used to be true that bond holders would try to come to the table and renegotiate debt when a company or government was in trouble. After all, it’s better to get 40% of their money back than none.
But now it’s possible to “insure” their bonds with CDS contracts, and in fact you can even bet on the failure of a company that way, so you actually can set it up where you’d make money when a company fails, whether you’re a bond holder or not. This means less incentive to renegotiate debt and more of an incentive to see companies go through bankruptcy.
For the record, the suggestion Lubben has, which is a good one, is to have a disclosure requirement on how much CDS you have:
In a paper to appear in the Journal of Applied Corporate Finance, co-written with Rajesh P. Narayanan of Louisiana State University, I argue that one good starting point might be the Williams Act.
In particular, the Williams Act requires shareholders to disclose large (5 percent or more) equity positions in companies.
Perhaps holders of default swap positions should face a similar requirement. Namely, when a triggering event occurs, a holder of swap contracts with a notional value beyond 5 percent of the reference entity’s outstanding public debt would have to disclose their entire credit-default swap position.
I like this idea: it’s simple and is analogous to what’s already established for equities (of course I’d like to see CDS regulated like insurance, which goes further).
[Note, however, that the equities problem isn't totally solved through this method: you can always short your exposure to an equity using options, although it's less attractive in equities than in bonds because the underlying in equities is usually more liquid than the derivatives and the opposite is true for bonds. In other words, you can just sell your equity stake rather than hedge it, whereas your bond you might not be able to get rid of as easily, so it's convenient to hedge with a liquid CDS.]
Lubben’s not a perfect solution to the problem of creating incentives to make companies work rather than fail, since it adds overhead and complexity, and the last thing our financial system needs is more complexity. But it moves the incentives in the right direction.
It makes me wonder, is there an analogous rule, however imperfect, for tax rates? How do we get super rich people to care about infrastructure and education, when they take private planes and send their kids to private schools? It’s not fair to put a tax law into place, because the whole point is that rich people have more power in controlling tax laws in the first place.
Money market regulation: a letter to Geithner and Schapiro from #OWS Occupy the SEC and Alternative Banking
#OWS working groups Occupy the SEC and Alternative Banking have released an open letter to Timothy Geithner, Secretary of the U.S. Treasury, and Mary Schapiro, Chairman of the SEC, calling on them to put into place reasonable regulation of money market funds (MMF’s).
Here’s the letter, I’m super proud of it. If you don’t have enough context, I give a more background below.
What are MMFs?
Money market funds make up the overall money market, which is a way for banks and businesses to finance themselves with short-term debt. It sounds really boring, but as it turns out it’s a vital issue for the functioning of the financial system.
Really simply put, money market funds invest in things like short-term corporate debt (like 30-day GM debt) or bank debt (Goldman or Chase short-term debt) and stuff like that. Their investments also include deposits and U.S. bonds.
People like you and me can put our money into money market funds via our normal big banks like Bank of America. In face I was told by my BofA banker to do this around 2007. He said it’s like a savings account, only better. If you do invest in a MMF, you’re told how much over a dollar your investments are worth. The implicit assumption then is that you never actually lose money.
What happened in the crisis?
MMF’s were involved in some of the early warning signs of the financial crisis. In August and September 2007, there was a run on subprime-related asset backed commercial paper.
In 2008, some of the funds which had invested in short-term Lehman Brother’s debt had huge problems when Lehman went down, and they “broke the buck”. This caused wide-spread panic and a bunch of money market funds had people pulling money from them.
In order to avoid a run on the MMF’s, the U.S. stepped in and guaranteed that nobody would actually lose money. It was a perfect example of something we had to do at the time, because we would literally not have had a functioning financial system given how central the money markets were at the time, in financing the shadow banking system, but something we should have figured out how to improve on by now.
This is a huge issue and needs to be dealt with before the next crisis.
What happened in 2010?
In 2010, regulators put into place rules that tightened restrictions within a fund. Things like how much cash they had to have on hand (liquidity requirements) and how long the average duration of their investments could be. This helped address the problem of what happens within a given fund when investors take their money out of that fund.
What they didn’t do in 2010 was to control systemic issues, and in particular how to make the MMF’s robust to large-scale panic.
What about Schapiro’s two MMF proposals?
More recently, Mary Schapiro, Chairman of the SEC, made two proposals to address the systemic issues. In the first proposal, instead of having the NAV’s set at one dollar, everything is allowed to float, just like every other kind of mutual fund. The industry didn’t like it, claiming it would make MMF’s less attractive.
In the second proposal, Schapiro suggesting that MMF managers keep a buffer of capital and that a new, weird lagged way for people to remove their money from their MMF’s, namely if you want to withdraw your funds you’ll only get 97%, and later (after 30 days) you’ll get 3% if the market doesn’t take a loss. If it does take a loss, will get only part of that last 3%.
The goal of this was to distribute losses more evenly, and to give people pause in times of crisis from withdrawing too quickly and causing a bank-like run.
Unfortunately, both of Schapiro’s proposals didn’t get passed by the 5 SEC Commissioners in August 2012 – it needed a majority vote, but they only got 2.
What happened when Geithner and Blackrock entered the picture?
The third, most recent proposal, comes out of the FSOC, a new meta-regulator, whose chair is Timothy Geithner. The guys proposed to the SEC in a letter dated September 27th that they should do something about money market regulation. Specifically, the FSOC letter suggests that either the SEC should go with one of Schapiro’s two ideas or a new third one.
The third one is again proposing a weird way for people to take their money out of a MMF, but this time it definitely benefits people who are “first movers”, in other words people who see a problem first and get the hell out. It depends on a parameter, called a trigger, which right now is set at 25 basis points (so 25 cents if you have $100 invested).
Specifically, if the value of the fund falls below 99.75, any withdrawal from that point on will be subject to a “withdrawal fee,” defined to be the distance between the fund’s level and 100. So if the fund is at 99.75, you have to pay a 25 cent fee and you only get out 99.50, whereas if the fund is at 99.76, you actually get out 100. So in other words, there’s an almost 50 cents difference at this critical value.
Is this third proposal really any better than either of Schapiro’s first two?
The industry and Timmy: bff’s?
Here’s something weird: on the same day the FSOC letter was published, BlackRock, which is a firm that does an enormous amount of money market managing and so stands to win or lose big on money market regulation, published an article in which they trashed Schapiro’s proposals and embellished this third one.
In other words, it looks like Geithner has been talking directly to Blackrock about how the money market regulation should be written.
In fact Geithner has seemingly invited industry insiders to talk to him at the Treasury. And now we have his proposal, which benefits insiders and also seems to have all of the unattractiveness that the other proposals had in terms of risks for normal people, i.e. non-insiders. That’s weird.
Update: in this Bloomberg article from yesterday (hat tip Matt Stoller), it looks like Geithner may be getting a fancy schmancy job at BlackRock after the election. Oh!
What’s wrong with simple?
Personally, and I say this as myself and not representing anyone else, I don’t see what’s wrong with Schapiro’s first proposal to keep the NAV floating. If there’s risk, investors should know about it, period, end of story. I don’t want the taxpayers on the hook for this kind of crap.
Strata: one down, one to go
Yesterday I gave a talk called “Finance vs. Machine Learning” at Strata. It was meant to be a smack-down, but for whatever reason I couldn’t engage people to personify the two disciplines and have a wrestling match on stage. For the record, I offered to be on either side. Either they were afraid to hurt a girl or they were afraid to lose to a girl, you decide.
Unfortunately I didn’t actually get to the main motivation for the genesis of this talk, namely the realization I had a while ago that when machine learners talk about “ridge regression” or “Tikhonov regularization” or even “L2 regularization” it comes down to the same thing that quants call a very simple bayesian prior that your coefficients shouldn’t be too large. I talked about this here.
What I did have time for: I talked about “causal modeling” in the finance-y sense (discussion of finance vs. statistician definition of causal here), exponential downweighting with a well-chosen decay, storytelling as part of feature selection, and always choosing to visualize everything, and always visualizing the evolution of a statistic rather than a snapshot statistic.
They videotaped me but I don’t see it on the strata website yet. I’ll update if that happens.
This morning, at 9:35, I’ll be in a keynote discussion with Julie Steele for 10 minutes entitled “You Can’t Learn That in School”, which will be live streamed. It’s about whether data science can and should be taught in academia.
For those of you wondering why I haven’t blogged the Columbia Data Science class like I usually do Thursday, these talks are why. I’ll get to it soon, I promise! Last night’s talks by Mark Hansen, data vizzer extraordinaire and Ian Wong, Inference Scientist from Square, were really awesome.
We’re not just predicting the future, we’re causing the future
My friend Rachel Schutt, a statistician at Google who is teaching the Columbia Data Science course this semester that I’ve been blogging every Thursday morning, recently wrote a blog post about 10 important issues in data science, and one of them is the title of my post today.
This idea that our predictive models cause the future is part of the modeling feedback loop I blogged about here; it’s the idea that, once we’ve chosen a model, especially as it models human behavior (which includes the financial markets), then people immediately start gaming the model in one way or another, both weakening the effect that the model is predicting as well as distorting the system itself. This is important and often overlooked when people build models.
How do we get people to think about these things more carefully? I think it would help to have a checklist of properties of a model using best practices.
I got this idea recently as I’ve been writing a talk about how math is used outside academia (which you guys have helped me on). In it, I’m giving a bunch of examples of models with a few basic properties of well-designed models.
It was interesting just composing that checklist, and I’ll likely blog about this in the next few days, but needless to say one thing on the checklist was “evaluation method”.
Obvious point: if you have a model which has no well-defined evaluation model then you’re fucked. In fact, I’d argue, you don’t really even have a model until you’ve chosen and defended your evaluation method (I’m talking to you, value-added teacher modelers).
But what I now realize is that part of the evaluation method of the model should consist of an analysis of how the model can or will be gamed and how that gaming can or will distort the ambient system. It’s a meta-evaluation of the model, if you will.
Example: as soon as regulators agree to measure a firm’s risk with 95% VaR on a 0.97 decay factor, there’s all sorts of ways for companies to hide risk. That’s why the parameters (95, 0.97) cannot be fixed if we want a reasonable assessment of risk.
This is obvious to most people upon reflection, but it’s not systemically studied, because it’s not required as part of an evaluation method for VaR. Indeed a reasonable evaluation method for VaR is to ask whether the 95% loss is indeed breached only 5% of the time, but that clearly doesn’t tell the whole story.
One easy way to get around this is to require a whole range of parameters for % VaR as well as a whole range of decay factors. It’s not that much more work and it is much harder to game. In other words, it’s a robustness measurement for the model.
Gaming the Google mail filter and the modeling feedback loop
The gmail filter
If you’re like me, a large part of your life takes place in your gmail account. My gmail address is the only one I use, and I am extremely vigilant about reading emails – probably too much so.
On the flip side, I spend quite a bit of energy removing crap from my gmail. When I have the time and opportunity, and if I receive an unwanted email, I will set a gmail filter instead of just deleting. This is usually in response to mailing lists I get on by buying something online, so it’s not quite spam. For obvious spam I just click on the spam icon and it disappears.
You see, when I check out online to pay for my stuff, I am not incredibly careful about making sure I’m not signing up to be on a mailing list. I just figure I’ll filter anything I don’t want later.
Which brings me to the point. I’ve noticed lately that, more and more often, the filter doesn’t work, at least on the automatic setting. If you open an email you don’t want, you can click on “filter messages like these” and it will automatically fill out a filter form with the “from” email address that is listed.
More and more often, these quasi-spammers are getting around this somehow. I don’t know how they do it, because it’s not as simple as changing their “from” address every time, which would work pretty well. Somehow not even the email I’ve chosen to filter is actually deleted through this process.
I end up having to copy and paste the name of the product into a filter, but this isn’t a perfect solution either, since then if my friend emails me about this product I will automatically delete that genuine email.
The modeling feedback loop
This is a perfect example of the feedback loop of modeling; first there was a model which automatically filled out a filter form, then people in charge of sending out mailing lists for products realized they were being successfully filtered and figured out how to game the model. Now the model doesn’t work anymore.
The worst part of the gaming strategy is how well it works. If everybody uses the filter model, and you are the only person who games it, then you have a tremendous advantage over other marketers. So the incentive for gaming is very high.
Note this feedback loop doesn’t always exist: the stars and planets didn’t move differently just because Newton figured out his laws, and people don’t start writing with poorer penmanship just because we have machine learning algorithms that read envelopes at the post office.
But this feedback loop does seem to be associated with especially destructive models (think rating agency models for MBS’s and CDO’s). In particular, any model which is “gamed” to someone’s advantage probably exhibits something like this. It will work until the modelers strike back with a better model, in an escalation not unlike an arms race (note to ratings agency modelers: unless you choose to not make the model better even when people are clearly gaming it).
As far as I know, there’s nothing we can do about this feedback loop except to be keenly aware of it and be ready for war.












