One way you could spend this slow week is reading the “living wills” submitted by a bunch of banks telling regulators how to wind them up if they go under. Don’t, though: they’re about the most boring and least informative things imaginable and I am angry that I read them.* Here for instance is how JPMorgan would wind itself up if left to its own devices**:

(1) It would just file for bankruptcy and stiff its non-deposit creditors (at the holding company and then, if necessary, at the bank).

(2) If after stiffing its non-deposit creditors it didn’t have enough money to pay its depositors it would sell its highly attractive businesses in a competitive sale to willing buyers who would pay top dollar.

This seems wrong, no? And not just in the sense of “in my opinion that would be sort of difficult, what with people freaking out about JPMorgan going bankrupt and its highly attractive businesses having landing it in, um, bankruptcy.” It’s wrong in the sense that it’s the opposite of having a plan for dealing with banks being “too big to fail”: it’s premised on an assumption that the bank is not too big to fail. If JPMorgan runs into trouble that it can’t get out of without taxpayer support, it’ll just file for bankruptcy like anybody else. Depositors will be repaid (if they’re under FDIC limits); non-depositor creditors will be screwed just like they would be on a failure of Second Community Bank of Kenosha.

This works fine if JPMorgan is indistinguishable from Second Community Bank of Kenosha, but raises some doubts when JPMorgan is the sort of bank that, y’know, has to submit a resolution plan because Congress was worried that if it ran into trouble it would need a taxpayer rescue because of its importance – the importance of its non-deposit liabilities – to the global financial system. Its $70 trillion in derivative notionals? That whole thing where it’s one of two clearing banks in the tri-party repo market, taking cash from (non-depositor) cash investors and lending it intraday to securities dealers to keep the global financial system functioning? Meh, let a bankruptcy court sort them out.

Now to be fair this is JPMorgan’s second-favored approach. The first-favored approach is “use taxpayer money to keep us afloat,” in the form of a “Title II resolution” in which the FDIC would restructure the bank using “industry-backed funding” (i.e. the FDIC would give it loads of money, and then later there would be private fundraising to give the FDIC back its money). The outline of that plan is here and it’s interesting, though not that interesting: it’s sort of like super-fast bankruptcy where the subsidiaries are shielded and the FDIC provides the DIP funding and gets it replaced quickly by private funding, and it relies on certain unspoken assumptions (mainly that, in the circumstance in which JPMorgan is bankrupt, there’s private money to be raised anywhere) that might worry you if you were actually contemplating a failure of JPMorgan.

Still at least it’s a plan, and one that focuses on uninterrupted operation of non-deposit but systemically important businesses. The do-it-on-our-own resolution plans submitted this week aren’t even that. Of course they’re only public summaries; perhaps the longer, more specific plans submitted to regulators in confidence are better. I doubt it, though. Goldman, for one, thinks the whole assignment is busywork, and is not shy about saying so: “The circumstances leading to the failure of a systemically important financial institution will likely be different than the specific assumptions listed above [which include "Markets are functioning normally," "Other market participants are assumed to be in good financial condition," and "Funding markets are open for other market participants"], and we expect that future submissions of our Resolution Plan will include other conditions and may have different assumptions.”***

You can see why the Fed scheduled these plans to be submitted in this holiday-interrupted week: get the nice headline of “big banks have plans to be resolved via bankruptcy rather than bailout,” and move on without too much worry over the seriousness of those plans. The reality is that the Fed and the banks have a basically impossible task, of finding a way to resolve systemically important banks that fail without public money and without systemic effects. (Also without knowing anything about market conditions at the time of their failure.) Thus Goldman’s petulance about planning for an eventuality – Goldman fails and everyone else is fine – that is, if not impossible, at least uninteresting. And thus every bank’s prefacing its resolution plan with several pages of “our balance sheet is a mighty fortress and this will never never never happen BUT …”

Still, the banks shouldn’t be too annoyed by the busywork. It’s annoying for them, and a little embarrassing to talk in hypotheticals about their demise, but it’s better than the alternative. These plans are a fig leaf to cover up the problem of banks being too big to fail without bailouts and/or repercussions. Going about your business as a huge, interconnected, systemically important pillar of the financial system, at the cost of having a pretend plan to erase you from the map, is probably a lot easier and more lucrative than reducing your systemic importance now, while you’re still solvent.

Resolution Plans [Federal Reserve]
Big Banks’ ‘Living Wills’ Aiming For Bankruptcy Not Bailouts [Bloomberg]
‘I ain’t dead’ — US bank holding companies [FTAV]

* Values of “read” and “them” approximate.

** The text is boring so let’s put it here. Page 30:

The Resolution Plan would involve restructuring the Firm’s balance sheet with the goal of achieving well-capitalized status without imposing any losses on taxpayers. The Resolution Plan provides that, in order to achieve the significant benefits of resolution through recapitalization, the Firm’s lead bank subsidiary, JPMorgan Chase Bank, N.A. would be recapitalized, either without initiating one or more FDI Act receiverships, or if necessary, by utilizing the FDIC’s traditional resolution powers in receivership proceedings under the FDI Act. The value necessary for the recapitalization of JPMorgan Chase Bank, N.A. would come from intercompany balances owned by JPMorgan Chase and, if a receivership is commenced, any third-party claims left behind in the receivership. JPMorgan Chase would be placed in Chapter 11 proceedings and creditors and shareholders of JPMorgan Chase would realize value from the receivership only to the extent available to JPMorgan Chase as a shareholder of JPMorgan Chase Bank, N.A., after the payment of JPMorgan Chase Bank, N.A.’s creditors.

In the unlikely event that the amount of intercompany deposit and non-deposit third party liabilities at JPMorgan Chase Bank, N.A. are insufficient to recapitalize it, the Resolution Plan contemplates that the Firm would decrease the size of its consolidated balance sheet until it is adequately capitalized by divesting any of our lines of business, any of the twenty-five material legal entities which are significant to the activities of the Firm’s core business lines, or any other divestiture opportunity that presented itself to the Firm in resolution. The Firm believes that its core business lines and critical operations are highly attractive businesses. Many of them are global leaders and top competitors in the products and markets in which they have chosen to compete. As a result, each business unit would have multiple, diverse and not necessarily overlapping potential buyers.

*** Again the text is a little dull but I actually really admire its thoroughgoing petulance. “This is a stupid waste of time and we’re only doing it because you stupid people told us to do this stupid thing with these stupid assumptions,” it says, in every sentence. Pages 30-31:

While Goldman Sachs has previously submitted a recovery plan to our Supervisors, this is the first submission of our Resolution Plan. Supervisors have set out a specific approach to developing a resolution plan for firms such as GS Group. This approach includes an iterative process (i.e., submission then feedback over a period of time with changed assumptions for future years’ submissions). It is important to note that this initial submission of our Resolution Plan is also based upon specific guidance and baseline assumptions provided to us by our Supervisors. Additionally, and in accordance with the Final Rule and Dodd-Frank, our Resolution Plan assumes no extraordinary government support and further assumes that the Firm is resolved under the U.S. Bankruptcy Code and other applicable liquidation proceedings.

Specifically, our Resolution Plan has been prepared with the following baseline assumptions provided to us by our Supervisors:
- Sudden, idiosyncratic material financial distress at GS Group with no previous disruption to the markets
- All Material Entities of GS Group have entered some form of bankruptcy
- Markets are functioning normally
- Other market participants are assumed to be in good financial condition
- Funding markets are open for other market participants
- No extraordinary government support

The circumstances leading to the failure of a systemically important financial institution will likely be different than the specific assumptions listed above, and we expect that future submissions of our Resolution Plan will include other conditions and may have different assumptions. These changes might materially alter the specific choices undertaken as part of a resolution process. We would also expect future iterations of our plan may include consideration of potential actions under the FDIC’s Orderly Liquidation Authority and other supervisory approaches contemplated by the relevant statutes.

174 comments (hidden for your protection)
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Comments (174)

  1. Posted by VonSloneker | July 5, 2012 at 10:50 AM

    We're going to need a bigger mattress

    - Brody

  2. Posted by Guest | July 5, 2012 at 10:52 AM

    I keep hearing that Titanic song in my head when I read "Too Bog Too Fail." I hate that Titanic song. Make it stop.

    - Hungover guest

  3. Posted by Guest | July 5, 2012 at 10:59 AM

    Matt, is this what you were doing last night when the rest of us were watching fireworks?

  4. Posted by guest | July 5, 2012 at 11:07 AM

    I don't see any mention of wearing 'Fuck the Fed' t-shirts to meetings with regulators.

  5. Posted by Grinders | July 5, 2012 at 11:10 AM

    What were you expecting Matty boy? This exercise isn't so much for the bank as it is for the people who are invested or have some sort of dependence on the banks. It's meant to give them some sense of the unknowns that originate their fears. The banks know what they'll do. It's everybody else that is left panicking.

  6. Posted by pazzo83 | July 5, 2012 at 11:11 AM

    "I'm not fat, I'm big-boned"

    So that's all I have to write down?

    - Cartman

  7. Posted by guest | July 5, 2012 at 11:18 AM

    I just bought nuclear armageddon insurance for my condo. You know, assuming that the insurance company is operating normally following some nuclear devastation.

  8. Posted by pazzo83 | July 5, 2012 at 11:19 AM

    Just buy insurance on the insurance company.

    - GS Risk Mgmt

  9. Posted by guest | July 5, 2012 at 11:22 AM

    Sold!

    -AIG

  10. Posted by Here's Johnny | July 5, 2012 at 11:56 AM

    We have compiled every newspaper article about the Lehman Bankruptcy and filed it with the Fed. It will be more or less like that. Lots of advisory and legal fees and $0.25 on the dollar for everyone else.

  11. Posted by Dingaling | July 5, 2012 at 1:13 PM

    ": they’re about the most boring and least informative things imaginable and I am angry that I read them"

    Now you know how we feel after reading one of your posts

  12. Posted by Am I Doing it Rite? | July 5, 2012 at 1:15 PM

    Holy shit bro, did you just see those banks living wills? #HMD!

  13. Posted by Hakuna Matata Guy | July 5, 2012 at 1:45 PM

    Listen, I dont mean to get all "suggestion box" on you guys, but these are the types of days we need more than one story! Dying in here!

  14. Posted by J. Gorman | July 5, 2012 at 1:58 PM

    Morgan Stanley "living will:"

    1. Recapture top banner space on DB from Bonobos
    2. ???????????????
    3. PROFIT!!!!

  15. Posted by Hakuna Matata Fan | July 5, 2012 at 2:14 PM

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  16. Posted by B2b MD | July 5, 2012 at 2:25 PM

    Too hungover, didn't read.

    Guy who always says he will take it easy on the 4th and inevitably is still downing beers and doing stupid things with fireworks come midnight.

  17. Posted by LEH Risk Mgmt. | July 5, 2012 at 2:37 PM

    Don't worry, there are much worse things one could fine oneself recklessly blowing up over the summer months.

  18. Posted by Nervous Commenter | July 5, 2012 at 2:42 PM

    Where's Bess? Is Matt planning some evil experiment where we actually have to complete one of his "exercises for the reader?"

  19. Posted by guest | July 5, 2012 at 2:52 PM

    Our plan to give cheesehead hats to our non-deposit creditors has also been accepted by the Fed.

    - CEO of Second Community Bank of Kenosha

  20. Posted by Guest | July 5, 2012 at 3:00 PM

    So what would be the VaR on this investment again ?

    –JPM Risk Team

  21. Posted by Sore in Stamford | July 5, 2012 at 3:11 PM

    I can't believe my MD actually made me shoot bottle rockets out of my ass on the trading floor.

    1st degree taint burns > hemorrhoids

  22. Posted by SellingLow | July 5, 2012 at 3:12 PM

    Oooh ooooh I know this one! Hang on, hang on…. It's ZERO!! Right? Has to be. Makes sense.

    -UBS MD

  23. Posted by Ms. Levin | July 5, 2012 at 3:16 PM

    Matt,

    How many gimlets did you let Bess have while you were "approximately" reading all of these long and boring documents?

    -Ms. Levin (no relation to Carl)

  24. Posted by SellingLow | July 5, 2012 at 3:19 PM

    On slow days like today, I wish Bess would invite the commenters from CNN Money over for a friendly group mixer. They seem nice.

  25. Posted by Demographic Quant | July 5, 2012 at 3:36 PM

    Same with Deal Book and Deal Journal. A lot of the time I wonder why in the hell those people are even reading those Blogs, if you're a bleeding heart, Wall Street hating liberal, why in fuck's sake are you reading a blog about deal making? Trying to apply game theory to your efforts to preserve optionality for your client at the next round of negotiations at the empathy table?

  26. Posted by Guest | July 5, 2012 at 3:40 PM

    Matt, what size are your hands?

    -Murray Hill Curious

  27. Posted by SellingLow | July 5, 2012 at 3:41 PM

    I don't know what any of that means, but I think empathy is good, so yes!

    -OWS

  28. Posted by Guest | July 5, 2012 at 4:32 PM

    Just use real estate as a hedge

    –Lehman VP

  29. Posted by @PaulBlumenthal | July 5, 2012 at 4:32 PM

    Current system is fascism. That’s true. But true free market economy always finishes as fascism (corporationism). That’s something that you guys don’t see. Let me give you an example:

    It is 1998. Nobody heard of web search, right? I don’t think that the term was even defined. So, obviously as nobody knew what it was, there was no Government regulation or intervention in the web search market, right? So, we have 1998 and we have 2 guys in a Garage creating Google. And thanks to the lack of regulation and lack of the Government intervention Google works out beautifully. So far so good. We have 100% pure beautiful capitalism for Google. Everybody happy. Capitalism at its finest. Now comes the part that is explained by Marx and you guys simply don’t grasp: In the year of 2010 Google sponsors a bill to regulate the market economy so its position as a monopoly for web search is secured by the law. That’s the fact bill like this has been developed by Google. Now Google bribes (aka ‘lobbies’) the House/Senate/etc and gets what it wants: if you use Google connections goes through fat and fast Internet connection. If you use something else, no matter how many times better, the law says that slower connections must be used. That’s exactly right. That’s fascism: laws created by corporations to secure their monopolistic positions at the same time empowering Government more as now it needs to eavesdrop only Google’s traffic. Everybody wins. Except for constituency that is. Fascism. In other words once those corporations grow big enough thanks to the lack of regulation and free markets THEY will regulate instead of the Government (democratically elected Government I should add).

    And I know what will you say: “Ahh.. it’s still because of the GOvernment because the Government enables this. Because the GOvernment allows bribing and lobbying to happen”.
    Well, this argument is aking to communists argumentation that communism would work great if just people could understand that they ought to be equal and not want more than their neighbor. It is the same stupid logic: oh capitalism would work great only if these stupid people would understand not to take bribes, lobby and have no special interests. It is utopia my friends. Politicians will always accept fact checks from corporations. This way corporations ultimately destroy capitalism that created them and replace it with corporationism known also as fascism. That’s the path that not only Google took, but also banks in the past – hence FED was created to secure their interests in 1917. Big Pharma, hence MedicAid and Medicare were created. And military complex hence all the wars.

    You see capitalism is self-destructing. So go there and read Marx before dismissing him as an idiot.

    Paul Blumenthal, http://www.sh1ny.com Founder.

  30. Posted by Guest | July 5, 2012 at 4:34 PM

    Kick rocks dude

  31. Posted by UBS Dietician | July 5, 2012 at 4:45 PM

    So exactly how was your diet as a child divided between lead paint chips and paste?

  32. Posted by SellingLow | July 5, 2012 at 4:54 PM

    Mmmhmmmm. Cool story bro. What Deathcab song did you listen to while penning this? The one about "freckles in our eyes" and shit? I love that one.

    -UBS Cool Music Quant

  33. Posted by Gues #1 | July 5, 2012 at 5:48 PM

    You forgot the part where one of the guests here bangs your wife.

  34. Posted by Guest | July 5, 2012 at 6:32 PM

    Haven't you been smoking Peyote for six straight days, and couldn't some of this maybe be in your head?

    Cool story, Hansel.

  35. Posted by matt post liker | July 5, 2012 at 11:43 PM

    TLDR: this is like a matt post in response to a matt post……

  36. Posted by dontshoot_itsme | July 6, 2012 at 6:05 AM

    4 months from now, Matt's footnotes will be longer than the story text.

    - GS extrapolation quant

  37. Posted by guest | July 6, 2012 at 8:42 AM

    You lost me at "It is 1998. Nobody heard of web search…."

    - Yahoo, Altavista, InfoSeek, AOL, etc.

  38. Posted by Matt's Left Nut | July 6, 2012 at 9:44 AM

    How do you get 3 GS quants off of your couch? Jerk one off & the other 2 come. ……….see what I did there?

  39. Posted by Grinders | July 6, 2012 at 11:41 AM

    Aww, And you were doing so well with covering your lack of grammar skills in the first few sentences there.

  40. Posted by Güest | July 6, 2012 at 12:53 PM

    not really, no

  41. Posted by Vik. | July 6, 2012 at 4:17 PM

    Citigroup's living will

    1. Call FDIC to take over deposits to merge with Construciton Bank of China.
    2. Handover ongoing underwriting deal(s) to PNC.
    3. Sell corporate phone book to highest bidder (e.g. Monster.com or CareerBuilder)
    4. Sell rights to "Citi Never sleeps" slogan.
    5. Go to sleep.

  42. Posted by Jorge | July 6, 2012 at 4:21 PM

    Excite, AtHome, HotMomma, BigDaddy, Hot Bot, Ask.com, Jeeves.
    And what about Anna Kurnikova and Lycos?

    - Hulio Iglesias

  43. Posted by pretzel logic trader | July 7, 2012 at 2:48 AM

    go kill yourself

    - Ben gibard

  44. Posted by pretzel logic trader | July 7, 2012 at 2:50 AM

    TL perhaps but to comment post you did not bother reading makes a pathetic dumbass.

  45. Posted by Ron Perry | July 8, 2012 at 6:58 AM

    But that’s the one thing Dimon* can’t admit, since it would require him to support intrusive regulations. Stupidity, in Dimon’s mind, is always isolated and explainable, not systemic and unavoidable

    * replace with matt levine

  46. Posted by Jeff | July 8, 2012 at 12:49 PM

    So small business and individuals can fail and lose everything, but banks can't?
    Sounds like a great system
    http://www.dailyjobcuts.com

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