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Black Magic Tuesday update: Spineless SEC and BB, Worried Government (Author: )
Posting Date:2011-01-11

Update Wednesday, 12/1/11, 6 am Nicolas Haque’s follow up report below on the rebound. He says it happened within a “matter of minutes”. Rumour has it that the government-backed/owned banks and agencies purchased these shares massively so that investors’ losses were minimised. In the West, they call that a “bailout”. We call it “stabilisation”. More on that after the video.

A possible explanation might be hidden beyond the stock market. While a fracas was going on in downtown Motijheel, many forgot that a great challenge looms ahead for the government — the municipal election. A non-partisan affair by book, it is essentially a political battle which the government must win to have its grasp on the grassroots..

With a crashed stock market and broken investors — remember that the reach of this market penetrated even the remote places, as brokerage houses opened branches across the country and pooled money of the unsuspecting small savers — there is little chance for the government-backed candidates to win.

So a great deal of scurry must have happened in the offices of policymakers. Many great heads must have met greater heads. And decisions were made that the market must be yanked back on track for the time being. It did not matter whether fundamentals had enough gravitational force to keep the market on track.

Update Tuesday, 11/1/11, 8 am: They’re already calling it Black Monday. The FT picked it up an hour ago (highlights below the video). Nicolas Hoque’s report for Al-Jazeera below. For those of us outside Dhaka, the scenes speak volumes about the amount of anger out there.

FT adds:

The central bank then indicated it would become more aggressive in enforcing long-standing, but largely ignored, rules that cap bank exposure to the stock market at 10 per cent of deposits. The order prompted banks – some of which are believed to have as much as 75 per cent of their deposit base in the market – rapidly to cut exposure, sending prices tumbling and prompting allegations of foul play and share price manipulation from retail investors.

Reflecting the government’s nervousness over the political fallout from the stock market drop, the Rapid Action Battalion of the Bangladeshi police – the elite anti-crime and anti-terror squad – on Sunday arrested a local journalist covering the stock market for a leading newspaper. He was later released.

(Emphasis added)

In the comments section, idune and I have been wondering aloud all day about the rules governing commercial bank exposure and why BB did not limit their exposure till now. Clearly the SEC is not the only regulator to blame.

————————————————

Sunday, 9/1/11: The Financial Express reports that the DSE general index has fallen 600 points, a 7.7% downward decrease. The headline for the story is instructive: “SEC takes steps to boost share prices”.

The SEC’s purpose for existing is given in detail here, on its website. Its self-proclaimed mission statement reads:

Mission of the SEC is to:

Protect the interests of securities investors. Develop and maintain fair, transparent and efficient securities markets. Ensure proper issuance of securities and compliance with securities laws. I argue that by capitulating to investors for the last few months, especially on the issue of margin requirements, the SEC is undermining its own credibility as a strong regulator and helping to increase leverage in the market, making an unwinding of any potential bubble even more painful than is necessary.

Now some might say that “boosting share prices” falls under “protecting the interests of securities investors”. It does not. An investor is rewarded for taking on the risk that her/his investment might fail. An investor is not a lender – s/he should not even expect the principal back if things go wrong. Given these conditions, there is a great need for a market regulator in equity investments. The SEC protects the interest of securities investors by ensuring that only trustworthy companies are allowed to sell shares on the bourses, that these companies adhere to a certain standard of corporate governance, that they regularly publish statements on their financial positions etc. All this can be found on the web page above.

Additionally it has certain duties towards ensuring the proper functioning of the secondary market – i.e. where investors buy and sell shares from other investors. The investors usually buy/sell through brokerage houses and merchant banks, putting down only a fraction of the money needed for investment. The exact fraction is usually determined by the SEC. This fraction (the so-called margin loans) is what the SEC has been tinkering with over the past few months. The best rules are those that are enforced through thick and thin. But one may make an exception for the extraordinary circumstances in which the SEC finds itself: namely, having to tackle a bubble that the Bangladesh Bank seems incapable of handling.

Basically every time it sees trouble (DSE index falling from its lofty heights, investors burning cars), the SEC loosens the restrictions on such loans*. What good does this do really? This simply increases investors’ leverage (see the simple example presented below), allows greater speculative activity and increases the value of the index based on liquidity and “animal spirits” rather than fundamental value. The very definition of the bubble the SEC is seeking to prevent.

I understand it is quite scary to have an angry mob in front of your office. The government has taken the right step by deploying the law enforcers there. Investors need to take responsibility for their own decisions to invest, and yes, it will be painful (again). The SEC is not and should not be a paternal organisation that ensures win, win, win, all the time.

Perhaps now, feeling a bit safer, the SEC can play the role it is expected to play: promote fundamental analysis among investors rather than making it easier for them to fuel the speculative bubble that has lifted the DSE to this improbable level. And maybe- I know this is asking too much – finding out what led to the initial meteoric rise in the index in the first place and why they did nothing about it then. Some introspection is warranted.

The signs don’t look good so far. The SEC issued directives today to increase more “liquidity” in the market. It essentially has loosened the margin requirement as much as possible, and is now tinkering with waiting times for the margin facility. Previously a new investor would have to wait a month before s/he could take out such loans. As of today, the new investor has to wait 2 weeks. Again, speculative trading becomes easier. It also repealed the 100 million taka loan cap to any single investor – ensuring that the bigger players can take larger positions. This smacks of desperation on the SEC’s part. I doubt that the institutional investors will be foolish enough to start taking large, long positions in this market.

Next time, one hopes the SEC has enough spine to hold its ground and say “enough is enough”. Not holding my breath.

——————————–

*The examples below have been simplified intentionally. To understand the SEC’s motive behind loosening, one has to appreciate that the falling prices of stocks – the collateral for (most? all?) margin loans – has resulted in margin calls for most investors, including the big ones. That, however, is no reason for rule changes that simply undermine its own credibility in the long term.

The progression of margin loan requirements over the past few months goes like this:

July 8th, 2010: SEC rules that loans will be given on a 1:1 basis. So if you wanted to buy shares worth 100 taka, you needed to put down only 50 taka of your own money. The other 50 taka could be borrowed from the merchant bank/broker. (50 = 1X50)

November 22nd: it rules that loans up to 0.5 the investors’ margin/collateral can be given. This means that an investor wishing to buy 100 taka worth of shares needs 66.6 taka in downpayment and can borrow 33.3 taka from the bank. (33.3 = 0.5 X 66.6 approx.) This was a tightening of the rules as talk of a DSE bubble went mainstream.

December 13th: SEC loosens its stance so that loans could be given on a 1 to 1 ratio again. It’s “tight” stance lasted all of 21 days.

December 19th: it loosens further, ruling that an investor could borrow at 1.5 terms their “margin”. Put simply, if you want to buy 100 taka worth of stock, you need to put up only 40 taka of your own money. The bank lends you the rest (60 = 1.5 X 40).

January 9th: Unable to loosen the margin requirement any further without prompting serious concerns, it loosens other legal restrictions, such as cap on loan to any individual client and the waiting time before margin loans can be issued.





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Idune said on Tuesday 11 Jan 2011 at 21:14:01 :

Blame to SEC or BB
#1 written by idune
about 1 day ago
Quote
@dhakashohor
In your analysis you did not take Bangladesh bank actions into account. And without those it
presents a completely wrong picture of market situation. Without going into details, while SEC
played with margin rule Bangladesh bank

1) Severely squeezed money supply
2) Hiked bank deposit requirements
3) Reduced Bank investment ceiling into capital market

All these policy enforcement came into effect almost at same time within last month of the year. So
net effect on the market was – yes there was increased margin BUT there was no money available to
lend because of Bangladesh bank directives. Talking about watering the plant after cutting roots.

Bangladesh Bank expressed interest was to make QUICK correction (reduction of bank exposoure) but in
real result they have crashed the market. No experienced banker or financial policy maker in their
right mind would embark on such hostile contractionary move unless either they don’t know what they
are doing or they have a market crash in their mind.

As we speak Mon Jan 9th, 2011 9:40 am market is another 660 points down. Finance minister yesterday
said market will not be like 1996 BUT in reality market from interms of point, percentage and
confidence loss already crossed the 1996 rubicon.

No doubt there will be other justification and finger pointing but at the end people will remember
1996 all over again.

[Reply]

jyoti Reply:
January 10th, 2011 at 3:08 pm

“No experienced banker or financial policy maker in their right mind would embark on such hostile
contractionary move”

Indeed. As I said when the central bank governor was appointed:

Heading the central bank requires a solid understanding of macroeconomic theory and empirics, and
practical experience in banking and finance. The central banker needs to have years of experience
that allows one to develop a thorough understanding of the data, or network in the industry that
allows one to make a few phone calls and get a feel for things in a rapidly evolving world. The
central banker needs to complement rigorous analysis that is founded on a solid understanding of
macroeconomic theory and practice with subjective judgement that comes only with experience.
http://jrahman.wordpress.com/2009/06/23/the-year-of-living-dangerously-on-the-selection-of-the-bank-governor-and-his-challenges/

At that time, everyone congratulated the government for appointing a ‘pro-poor’ governor. I was
practically the sole voice who said this was an irresponsible appointment that will be regretted one
day.

However, to criticise the BB for monetary contraction alone is also half right. Bangladesh Bank has
fueled the bubble inadvertently for a long while through its exchange rate policy. Since early 2009,
as the dollar depreciated, there was upward pressure on taka. To keep taka fixed, BB expanded money
supply, and the extra liquidity ended up in the stock market. BB should have allowed taka to
appreciate gradually throughout the past two years. (As an aside, this would have also meant lower
food prices through the taka-rupee rate). I wrote about it here:

http://unheardvoice.net/blog/2010/12/27/perils-of-the-peg/

BB woke up to the problem way too late, and had no choice but to step on the brake so abruptly.
That’s what happens when problems are not recognised despite all the tell-tale signs.

But it’s not only a macro / monetary failure. There were also micro / regulatory failures. SEC
played stop-go as the post suggests, when it should have acted steadily throughout last year.

[Reply]

dhakashohor Reply:
January 10th, 2011 at 7:46 pm

idune, I honestly don’t know enough about BB’s actions and the amount of investment by commercial
banks in the stock market over the past year. Any sources you have would be much appreciated.

From the little I can make out, it seems that the banks were over-exposed to the risks of a bubble
bursting in the stock market. If that is the case, asking them to hold more capital was the prudent
thing to do. If that meant that money just rushed out of the market, so be it. In the bigger
picture, financial system stability trumps stock market stability.

I agree with Jyoti bhai’s take on BB actions – and would like to emphasise that BB itself should
have investigated the stock market boom much, much earlier. I think it realised that the banks were
in trouble and issued that directive. In my opinion, it should have taken those steps you mention
much earlier, when the bubble was forming. Questions need to be asked as to why it did not do so.

Today, as investors ran riot again and trading was halted, SEC loosened the margins again. It might
be doing this to ease investors who are getting hammered by margin calls. But this is at best a
toothless exercise, at worst sends the wrong signals to investors that the SEC can be forced to
shift its stance on almost anything. The problem is basic over-valuation of the entire stock market
– overinvestment in assets that simply cannot have returns that justify such huge investments. SEC,
like the Irish government, seems to think its a liquidity problem. For those of us watching from the
outside, it looks very much like a solvency problem.

[Reply]

idune Reply:
January 10th, 2011 at 8:05 pm

@dhakashohor
Financial sector health was not any worse now then let’s say middle of last year at height of over
exposure of banks. To Jyoti’s point these over exposure persisted throughout last year but rather
than taking gradual action Bangladesh Bank went for a quick fix. I have argued Bangladesh bank
inaction throughout last year in another thread. Argument here is, not a quick fix that is hostile
to market condition but do a gradual reduction of exposure. This way you can achieve both the
reduction of risk and a stable market.

[Reply]

dhakashohor Reply:
January 10th, 2011 at 8:18 pm

Your point about gradualism is valid and I agree you. If the Bank had detected this sort of exposure
earlier, then they could have taken gradual action.

I can not verify/deny your claim about health of financial sector. My only take away is that when a
regulator rushes, it’s because there’s some imminent danger that they know about. Otherwise, their
incentives are not to upset the boat – especially when the boat is a rising stock market. Possibly
why the bubble was allowed to form in the first place. I could be completely wrong about this.

.#2 written by idune
about 1 day ago
Quote
Jyoti thanks for pointing out specific policy flaws in exchange rate and money supply. At the moment
Bangladesh Bank hostile and quick fix policy are standing on the way of any hope of recovery. I see
SEC still relaxing margin rule but Bangladesh Bank still gung ho about they have nothing to do with
stock market, when in fact their policy resulted a crash rather than correction. Here is what I see
are some possible remedy that could bring confidence back in market.

1) From past experience it was seen active buying by Investment Corporation of Bangladesh (ICB),
govt managed fund, help restore some confidence. With 2300 points down govt will able to make good
profit from this entry point. But in today’s situation ICB action alone will not be enough.

2) Rather than imposing hard ceiling at 10% for bank investment in the market, Bangladesh bank can
relax that to 15-18%. And pursue a policy that they will decrease that ceiling gradually over next
15-18 months. While power situation improves industrial investment will pick up and bank will find
avenue to reduce their exposure anyway with gradual Bangladesh bank approach.

3) Third is increase targeted money supply and then once market become stable, take gradual approach
not an overnight contraction.

Otherwise SEC margin rule relaxation will only results more collapse of the market severe than 1996.
And brokerage houses and merchant banks are not unwilling and unable to lend to SEC directed level
of margin.

[Reply]

.#3 written by kopasamsu
about 1 day ago
Quote
seriously guys, why dont you ever blame the greedy investors for the crash?

man they made the word super duper hyper inflated price look like nothing at all, when not very
profitable

exxon mobil americas largest corporation and also the most profitable company of 2010 they made a
profit of 19.3 billion dollars

today trades at $75.21 and in 1990 during this time it was around $12.50 (google finance)

it took them 20 years to gain 6 folds, in bangladesh such gains happen over night

so who is to blame? and dont blame the opportunists, most of the investors in the market are
financially illiterate

they should have learned from 1996 and most recently the us bubble in 2008

truth is friggin bengalis are greedy and when all goes wrong they need someone to blame!

[Reply]

dhakashohor Reply:
January 11th, 2011 at 6:22 am

No one on this thread has said small investors are blame-less. I applauded the government’s move to
deploy armed forces in the post. In the one I wrote before (Phoren Approval), I tried to show that
retail investors had not always followed the best signals for judging the future worth of their
assets.

But in a crash like this, almost everyone is to blame. And, if it so many people’s money were not at
stake, it would be funny to watch everyone run and cover their backs. BB says it’s SEC. SEC says
it’s BB. Both blame institutional investors. Institutional investors blame the small, retail
investors. Retail investors blame “market manipulators”. I’m sure tomorrow, Shahrier Kabir will
blame Jamaat, and Jamaat will blame India. (Bdnews24 might blame Yunus and certain sushils might
blame the Rahman-Zia brothers). In a crisis, blame game is the first response in Bangladesh.

[Reply]

.#4 written by idune
about 1 day ago
Quote
Here are two articles from today on three Bangladesh bank
directives I talked about in my earlier post. I was hoping they
would take gradual steps and since yesterday Bangladesh Bank has
withdrawn or postponed those directives.
http://www.sheershanews.com/?view=details&data=Forest&news_type_id=1&menu_id=6&news_id=1114
http://www.thefinancialexpress-bd.com/more.php?news_id=122578&date=2011-01-11

[Reply]

dhakashohor Reply:
January 11th, 2011 at 6:32 am

Thank you very much for the links. Much appreciated.

Do note, it seems that certain banks seem to have invested more in the stock market than they were
allowed to under the rules set forth by BB. Now that we have a crisis, instead of investigating this
anomaly, BB is saying, “7 khoon maaf. Je bhaabey paro index ta uthao.”

2 concerns:

1) no one will ask why BB failed to catch this rule-breaking in the first place. Why did they fail
to notice this rule-breaking when it was taking place?

2) this creates moral hazard going forward. When everything calms down and everyone forgets about
this crisis and moves on, what is to stop the banks doing this all over again, knowing that BB will
forgive them if they just over-invest enough to destabilise the situation?

Again, I differ from you in that your concern is that BB let the bubble burst too quickly (it looks
more and more likely that it would have done so anyway). My concern is, why did it not pick up this
diversion into the stock market sooner? And now that it did pick it up, why did/will it not punish
those banks adequately?

[Reply]

idune Reply:
January 11th, 2011 at 7:13 am

“banks seem to have invested more in the stock market than they were allowed to under the rules set
forth by BB”

Third Bangladesh bank directive I mentioned in my post was to address that.

Bangladesh bank does run a sophisticated monitoring they knew this access investment from very
beginning. Problem is when there is no investment scope because of power gas stagnation banks just
jumped in the market. There were over 35000 cr taka idle money at the beginning of the year. We did
not see this phenomenon before.

response to your 2 concerns.

1) It was at least several months that Bangladesh Bank knew and acknowleged about the excess
investment. These bankers dumped money on SEC to Bangladesh bank to Ministry. Do you think anyone
will talk about why it was not detected earlier than that?

2) We have long passed moral hazard. And between you and me we can just think about it. As I
suggested this ceiling has to be decreased gradually otherwise damage and moral hazard will be even
greater. One shining light among all these mayhem is that Bangladesh largest private bank Islamic
Bank Bangladesh Ltd did not invest in the stock market yet remained most profitable bank (more than
1100 cr taka) in Bangladesh. Perhaps, there is still some moral out there.

[Reply]

dhakashohor Reply:
January 11th, 2011 at 7:32 am

Thanks for the clarifications. So this “idle money” in the commercial banking system – how did banks
go about channelling this into the stock market? From the FE article above, it seemed that the banks
had directly invested it themselves somehow. But reading this
http://www.thedailystar.net/newDesign/news-details.php?nid=169629 made me think that they had given
out loans to all sorts of investors to play around in the share market with.

Where can I get the info on this? Is there any law in Bangladesh that prohibits scheduled banks from
investing directly in the stock market?

.#5 written by idune
about 23 hours ago
Quote
Some investment was done directly, some through merchant banking wing. This and interim govt gave
sores licenses and now every bank has their merchant banking wing. As far I know it’s not illegal
for bank to invest in capital market so long they are wihin limit, which currently raised at 15%.
Commercial bank investing in stock market may be new phenomenon in Bangladesh but this has been done
almost in any country. In india limit for commercial bank to invest in capital market is 40%
(includes investment, loan etc.) of their capital. I don’t know if US has any limit at all.

http://www.financialexpress.com/news/banks-want-to-invest-more-in-stocks/607549/

[Reply]

.#6 written by dhakashohor
about 57 minutes ago
Quote
Best name and theory for the stock market rally:
http://www.thedailystar.net/newDesign/news-details.php?nid=169702

If I had some money lying around, I’d invest it in the DSE till the municipal elections!


Abdus Sukkur said on Wednesday 23 Feb 2011 at 21:20:45 :

Distance between govt. & investors
The investore louded and chanted anti-corruption slogans and urged the concerned body to take
necessary measures to stablise the share market. But the govt. solves the problem from opposite
direction. I recall a joke :
The teacher teaches the student \"PARBATI was a wife of SAGHAR\". The student asks \"Sir, what is
the gender of PARBATI ? Was he a man or woman\" Here the investors and govt. maintain a great
distance to solve the share bazar fall. It seems like teacher and student.




 
 
 
 

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