The Administration is putting high hopes on TALF, especially now that the program will reach as high as $1 trillion (remember when $1 trillion was a lot of money?). It has always seemed to me that TALF would fall short of the mark. The key constraint
Eligible collateral includes U.S. dollar-denominated cash ABS that are backed by auto loans, credit card loans, student loans, or small business loans that are fully guaranteed by the SBA, and that have a credit rating in the highest investment-grade rating category from two or more nationally recognized statistical rating agencies and do not have a credit rating below the highest investment grade rating category from a major rating agency.
The expansion of TALF to CMBS also requires AAA-ratings. I suspected that limiting the program to investment grade securities would severely curtail the effectiveness of the program for one simple reason - that, relative to expectations of officials, investment grade borrowers are relatively few, and they have maintained that status by not accumulating excessive debt, so already they are not inclined to borrow. The spending bubble was not driven by high grade debt; it was driven by low grade debt disguised as high grade debt. Focusing on high grade debt as the solution will thus prove insufficient to give the economy much traction.
Two recent stories tend to support this point. First, from the Wall Street Journal:
The government's $200 billion program to revive the market for securities backed by consumer loans may end up providing little help to the very industry that needs it most: U.S. auto makers.
As the Federal Reserve hashes out final terms of its Term Asset-Backed Securities Loan Facility, or TALF, it is becoming clear that securities that help finance auto dealers mightn't meet some criteria. That would block a form of funding that auto companies had hoped would provide immediate relief as they fight for survival.
The problem came to a head because of credit ratings. The Fed has insisted that any deal it helps finance be given a triple-A rating from Moody's Investors Service, Standard & Poor's or Fitch Ratings. Bankers said this kicks out deals backed by loans to auto dealers because S&P and Moody's, in particular, have cut the ratings on such securities over the past several weeks as the industry grapples with potential bankruptcy filings and weaker demand for U.S. cars.
The second is from Bloomberg:
The Fed, through the TALF, could reduce the cost of financing commercial real estate by taking as collateral CMBS already traded in the secondary market rather just new bonds, said RBS analyst Lisa Pendergast in Greenwich, Connecticut.
Accepting bonds from the secondary market would be a “big deal” for reviving credit, said Jan Sternin, a senior vice president at the Mortgage Bankers Association in Washington.
The central bank also should make loans with at least a five-year term against CMBS, Pendergast said. The TALF is now geared to make loans of no more than three years against collateral, a misalignment with the typical five- or 10-year term of commercial mortgages.
“Nobody would buy a 10-year asset with a three-year loan,” she said.
The Fed initially proposed a one-year term for TALF loans it will make before revising to a three-year period in December.
Without TALF support, borrowers would have a tougher time refinancing maturing debt and avoiding delinquency or foreclosure, said Chip Rodgers, senior vice president at the Real Estate Roundtable, a trade group in Washington.
The Fed has said it will only accept newly issued AAA-rated CMBS collateral. Presumably, newly issued CMBS could be used to refinance maturing debt, assuming the refinanced debt could be rated AAA. And, I suspect, therein lies the heart of the industry's conundrum. Given the deterioration in credit quality, we can presume that much of the maturing debt is rated at something less than AAA. Much less. Consequently, the TALF would do little to help refinance maturing commercial mortgage debt, at least directly (I would not count on the indirect effect of building confidence in dodgy assets via liquidity programs). They know it - the article contains a telling quote:
Atlanta Fed President Dennis Lockhart said today that commercial real estate is “the one domestic factor that keeps me up at night.”
“Many banks are pretty heavily exposed to commercial real estate,” he said in Orlando, Florida.
Lockhart must sleep well compared to me; I have a laundry list of economic issues that keeps me up at night.
If the maturing debt cannot be refinanced at reasonable interest rates, then rising defaults and additional asset markdowns will wreak further havoc on the banking industry. The Fed cannot fix this if they limit their loan programs to AAA-rated ABS, as the problem debt by definition has a lower rating. This appears to be the signal the industry is sending, so holders of CMBS want the next best thing - the Fed to absorb the risk of the existing AAA-ABS:
Top-rated commercial mortgage bonds are currently trading at about 10.82 percentage points more than benchmark interest rates, compared with 2.32 percentage points a year ago, Bank of America Corp. data show. In January 2007, the debt traded at 0.22 percentage point.
Seems those "top-rated" bonds are riskier than expected. Better to sell them off to the Fed (and eat the haircut) while they are still AAA rated. Of course, it may already be too late; ratings are dropping fast:
Moody's Investors Services downgraded an additional $23.89 billion of commercial mortgage-backed securities amid concerns that losses would grow from increased leverage, reduced reserves to pay debt and loan losses.
The move follows the ratings firm's announcement last week that it would review the ratings of some $300 billion of bonds backed by commercial-real-estate loans. More than a quarter of those securities are vulnerable to multiple-notch credit downgrades.
Last Thursday, Moody's said it will apply new assumptions about falling property cash flows and stressed capitalization rates, which are the ratio of net income to its value, when considering the rating of the bonds. The review is slated to be completed within 60 days.
Including the latest round of downgrades, $62.09 billion of CMBS has been downgraded by Moody's in the past week.
The commercial real-estate market had held up better than the residential real-estate market, but it began to deteriorate quickly at the end of 2008 as the recession deepened.
The ratings firm had expected cumulative losses of 2% on commercial bonds issued between 2006 and 2008, but it has increased that to 5%.
Moody's, which on Tuesday downgraded 124 classes and affirmed 69, expects a significant decline in future property cash flows on higher tenant defaults, bankruptcies and a sharp decline in lease-renewal rates. Those cut include 47 tranches valued at $6.6 billion from Wachovia Corp., which was acquired by Wells Fargo Co. (WFC) five weeks ago, 11 classes valued at $3.8 billion at JPMorgan Chase & Co. (JPM) and 10 classes valued at $2.8 billion at UBS AG (UBS).
Existing CMBS might not be rated AAA for long.
Bottom Line: TALF limitations provide protection for the taxpayer, but curtail the program's effectiveness. This is not meant to imply that efforts should not be made to support the normal functioning of credit markets; it's simply to keep expectations about effectiveness in check.