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Just because they didn't have a Chief Risk Officer doesn't mean they didn't have a risk management team. They MUST have had an Enterprise Risk Management team whose sole responsibility is to look at risk like this. The main role that the CRO would have is to pound on desks that something had to be done.

The biggest problem SVB had was a mismatch of duration between assets and liabilities. As interest rates started jumping, they should have acted on this by hedging or some other mitigation strategy. But this article's insinuations that people must have known as early as 2021 is ridiculous. The first rate hike was March 2022, and the subsequent one in May 2022 was already after the CRO ended her term.

For SVB to have problems, it needed 2 distinct problems: 1) interest rates had to rise and 2) customers had to start withdrawing funds. #1 started in March 2022, but I think #2 probably happened later than that. I think funding probably dried up Q3, which probably took startups as a surprise which forced them to burn more cash. By then interest rates started to ratchet up by 75 basis points at a time and the stock market hit their lows in October.

One possible scenario is that the ERM team flagged all this throughout 2022, but the CFO couldn't stomach the cost of hedging their portfolio and kept hoping for a reprieve or reversal.

Regardless, I think it's definitely possible that they knew something was wrong in Q3-22. The fact they didn't act until end of Q1-23 by selling off all their AFS assets in desperation is a evidence to me that they were holding out for hope and couldn't bear it anymore until the new CRO forced it. It doesn't seem conceivable to me that they had an entire ERM team that sat around with their thumbs up their asses not understanding the problems they had in the back half of 2022.

EDIT -

There's 3 other things I didn't think of but I just skimmed through their 10K.

1) They had the bulk of the HTM in Mortgage Backed Securities. In a falling rate environment, customers refinance, which means those loans get paid off, and their HTM asset gets converted into cash, which they need to redistribute back into another security. They could have used that cash to pay off depositors withdrawing their cash. But they could As rates go up, all the customers stopped refinancing, customers stopped buying new houses, and SVB wasn't getting those mortgages paid off, which probably cut into their cash.

2) Yes, startups must have been burning through cash, but I also how many of those customers pulling their funds out were just buying US treasuries or moving them into high interest products outside of SVB. This might have been a factor. I myself started buying US Treasuries for over half my portfolio now that 90-day T-bills are over 5%.

3) The 10K was filed on Feb 24, and SVB dumped their AFS portfolio on March 9. That's less than 2 weeks. There's no way that the auditors shouldn't have known about this sale, and they would have raised a huge stink if they knew. So either they were hiding all of this from the auditors, which sounds like fraud or something very acute occurred during those 2 weeks but I can't imagine what that is.

I'm going to be extremely interested to hear the reports from the inside because I'm sure people in SVB finance do not want to get pinned with the blame of this.

EDIT 2:

Found it. Moody's threatened to downgrade which forced the sale of AFS. So that explains it. So maybe everyone thought everything was okay and the surprise threat of the downgrade is what caused the house of cards to fall.

https://www.cnbc.com/2023/03/11/silicon-valley-banks-demise-...



In 2021 they should have known:

1. Long dated treasuries would almost certainly underperform long term if there were any interest rate increases

2. Interest rate increases were likely due to high inflation, low unemployment

3. Interest rate increases would correlate with a reduction in deposits

I’m not blaming a single person at all, but the bank in general should have been aware of this. While this seems more obvious in retrospect, it should at the very least have become obvious once the first rate hikes were announced


I don't think any of these are relevant to the situation.

1 is obvious, that's CFA Level 1.

2 is also obvious but in 2021 the Fed said inflation was transitory. After over a decade of sub-2% inflation, it wasn't hard to not believe that.

3 is not true. As rates rise, more people pull money out of the stock market and park it into higher interest deposits. The problem with SVB is that they don't have a lot of retail customers that would park their investments.


I don't know how fast banks can sell treasuries, but I feel like the answer has to be shorter than "all of 2022"

3 is pretty predictable for a bank that advertised itself as banking half of all VC-backed startups in the U.S.


> 3 is not true. As rates rise, more people pull money out of the stock market and park it into higher interest deposits.

For "lower deposits" read "fewer startups get funded and deposit their funds at the bank."


Oh the fed said inflation was transitory, risk team can take the day off I guess, no need to worry. 3. is true because literaly half their were deposits startups who will have a hard time raising if interest rates rise.


> I’m not blaming a single person at all, but the bank in general should have been aware of this.

What does this even mean? What else is there to blame other than individual people making decisions?


Probably the senior executive team in aggregate, but the speculation based on dates of departure/joining is unfairly laying blame at individuals without much evidence


SVB indeed made some very questionable bets, but people should remember that the Fed was saying "inflation is transitory" up until the end of 2021: https://fortune.com/2021/12/03/inflation-no-longer-transitor...

If you actually believed that narrative, you wouldn't think buying long term MBS was that risky. I think you'd be crazy not to doubt the narrative at least a bit given all the money dumped into the system during covid, I'm just saying it's not just one bank making questionable stupid decisions.


Job of the risk team is to be skeptical, ask "but what if it's not?" and hedge against that possibility. If your job is to believe everything you hear without doing proper risk analysis, why should a bank pay you?


High inflation was coming anyway due to the baby boomer cohort retiring. Then the governments of the world pulled ten trillion dollars out of thin air. Anybody with a business degree who didn't see crazy high inflation coming out of that should've had it revoked.


> Anybody with a business degree who didn't see crazy high inflation coming out of that should've had it revoked.

Jay Powell had a degree in politics and law. So, yeah.


Powell completed his JD in 1979 but then started working in investment banking by '84 and stayed in various finance jobs including under-secretary of finance from then to now. So he has the relevant experience. I doubt a business degree rather than a JD from the seventies would make any difference today.


This was news to me, but now I understand it (someone with more banking knowledge can correct me if I'm wrong): Securities held by a bank can be classified as either "Hold to Maturity" or "Available for Sale". HTM assets can not legally be hedged against interest rate risk. Reason for this is that if assets are actually held to maturity, there really isn't any interest rate risk.

https://viewpoint.pwc.com/dt/us/en/pwc/accounting_guides/der...

"The notion of hedging the interest rate risk in a security classified as held to maturity is inconsistent with the held-to-maturity classification under ASC 320, which requires the reporting entity to hold the security until maturity regardless of changes in market interest rates. For this reason, ASC 815-20-25-43(c)(2) indicates that interest rate risk may not be the hedged risk in a fair value hedge of held-to-maturity debt securities."


There is no risk of principal loss in held to maturity assets in a vacuum, but there can still be risk if durations of assets and liabilities don't match, and interest rates move. IE if you've made a bunch of long-term loans at relatively low interest rates, funded by money you've borrowed short-term (including deposits), and then interest rates go up, you can find your cashflow suddenly negative.


Having a team is something very different than having someone officially nominated with reporting lines upwards and board visibility.




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