How to Fix the Crisis in Six Easy Steps

There is a lot of chatter about different plans, market anticipations, and pitfalls when it comes to “fixing” the economy and, specifically, nationalization. Despite the fact that I don’t have the same reach as several uneducated members of the media, I figured I’d share what I think the way forward is, regardless.

Step 1: Nationalize Citi and Bank of America. Let’s be honest, with recent talks of expanded stakes, ringfenced assets, and no end of the losses in sight, it’s probably time the U.S. Government came to grips with the fact that they already own the losses and the positive impact of letting shareholders keep the upside is nonsensical. Further, these institutions will need more money for a long time to come. And, if you’re paying attention, you know that the markets seem to twist and turn with the news coming out of financial institutions. Nationalization rumors depress the markets, talks of further government action scare away new capital, and the fundamental health of these firms makes current investors run.

Step 2: Begin lending. With so much chatter and anger about institutions not lending, it almost makes me wonder why there is such a deep lack of understanding. These sick institutions are trying to shrink their balance sheets and have a ton of souring assets on them. They have to raise capital to support their current asset base, so why do we really expect these banks and other firms to lend? Some would claim that lending for the sake of lending got us into this mess, but they are either telling only part of the story or don’t get it–excessive leverage and poor risk management got us to this point. In fact, I suspect that defaults on even the riskiest loans would be much lower if bank capital was free enough to continue making mortgage loans based on normal requirements for returns and risk/reward.

So, how do we begin lending? Simple, start a government bank. Well, not exactly, but the government now owns Fannie, Freddie, AIG, Citi, and BofA (see step 1). Clearly the government now (by step 2) has the infrastructure and technical know-how to manage the logisitical issues of setting up and running a lending platform. Now the government can lend directly and not wait for sick banks to do it. Further, they can underwrite to fairly normal lending standards and get a premium return on their capital. Also, rather than poaching the nationalized entitites’ “talent,” the government cam employ many out of work finance workers throughout the country (after all, lending in Missouri should probably be done by people in Missouri).

Step 3: Begin replenishing bank assets with new, cleaner assets. With all of these souring assets on the books of banks, their capital base being eroded, and leverage decreasing, TARP capital is probably being deployed very inefficiently and, obviously, conservatively. Well, since step 2 involves lending and creating assets, the government should then implement an auction process–all assets the government creates would then be auctioned off, much like treasury bonds are, to banks. Since the government would be lending based on normal underwriting standards (as compared to the previous paradigm of loan underwriting), these assets would have a strong credit profile and will likely perform much better than legacy assets. JP Morgan, for example, should jump at the chance to generate higher levels of retained earnings by buying assets when the rates it needs to pay are at historically low levels, once its capital frees up. This solves the chicken-and-egg problem of curing sick banks, hurting from consumer defaults and depressed economic activity, to free up the credit markets and getting economic activity to increase despite a lack of credit.

One could easily permute this plan in many ways. One possible way is to offer to swap new assets for legacy assets at current market levels to facilitate a much more immediate strengthening of the banks’ balance sheets. Another variation could include some partial government guarentee on assets it originates. I’m sure there are thousands more ways one could add bells and whistles.

Step 4: Broaden the Fannie and Freddie loan modifications and housing stabilization plan to the government’s new properties. I suppose this should be some sort of addendum to step 1, but it’s important enough to require some emphasis on it’s own. With Citi and Bank of America being so large, I’m sure the housing stabilization plan will have a much broader reach once those are wards of the state. We’ve all heard the arguments for stopping foreclosures and refinancing borrowers… When the house next door is foreclosed upon, your house loses tens of thousands of dollar in value, increases housing supply, etc.

Step 5: Break up the institutions that are owned by the government. Markets have been clamoring for Citi to be broken up for years. Bank of America shareholders probably want Merrill to be broken off A.S.A.P. (ditto for Countrywide). Chew up these mammoth institutions and spit out pieces that, in the future, could fail because they aren’t too big. This should be done to AIG, Citi, Bank of America, and both Fannie and Freddie.

Step 6: Immediately implement a new regulatory regime. This is pretty much a “common sense measure.” President Obama has begun to call for this, and it’s pretty clear that with no more major investment banks around, the S.E.C.’s role needs to be re-defined. I’ve already laid out my thoughts on what this new structure should look like.

Between all of these steps, we should have the tainted institutions out of the system, credit will start to free up, banks asset base will become more reliable, and systemic risks will go down as we significantly decrease the number of firms that are “too big to fail.” Seems logical to me…

Dear Pundits: Citi isn’t Proof of Financial Supermarket Viabilty

Let’s be honest, Citi has some serious problems it has to fix. I’ve touched on many of them on this blog. But Citi’s failure is hardly an indictment of the “one stop” business model. It stands to reason that Citi is the example of how one cannot merely staple business together, allocate capital according to best returns for shareholders, and hope that a finance company can be run like a portfolio (ala G.E.).

One need only look at two competitors (and I’m sure Jamie Dimon thinks about this right before he lulls himself to sleep)–JP Morgan Chase and Citi. JP Morgan Chase has had a recent history of successful integrations, merging of businesses, stable leadership, and a cohesive corporate culture. No one at JPM sits around wondering how they can squeeze out the “other guys.” If you’re a Chase person you’re not trying to get all the JP Morgan people fired. Citi, on the other hand, has had management change after management change–each one is followed by an exodus of top, experienced executives. Guess what happens when one cobbles together a management team of people who are holdovers, new guard, and new hires… Citi! Guess what happens when no one takes the time to integrate businesses that have redundant product lines and systems, but rather let them operate all on their own… Citi!

In fact, one could be forgiven for thinking that standalone institutions are the business model in peril. Merrill, Lehman, and Bear, all pillars in the stand-alone investment bank community have disappeared from the landscape. Goldman and Morgan Stanley, the two remaining firms that were stand-alone investment banks six months ago, now include consumer banking in their business lines–much closer to the business mix of Citibank plus Salomon Brothers. Indeed, I would argue Citi’s investment bank performed like the lower tier of standalone investment banks, and ther mere existence of the consumer bank and deposit base “added in” allowed it to survive.

My theory is further bolstered by what Citi hopes to become and why. CitiCorp (Citi Corp? Citicorp?) is essentially a bank, an investment bank, and a brokerage all put together… And it’s half the size of Citi today. If that doesn’t say, we got the execution wrong but the model correct then I don’t know what does.

Oh, and don’t use BofA as a counter example… It was doing just fine on its own before swallowing Stan O’Neil’s mess whole (although the Ken Lewis negotiating tactics didn’t help). Further, Wachovia and Washington Mutual are examples for the opposite side of the equation–banks hoping to make money through capital markets operations and doing it poorly. Think of their problems as having evolved from having singularly focused, very poorly run investment banks attached to them.

The basic point: We’ve seen two financial supermarkets emerge here in the U.S. Both are still alive, and one is still profitable (The WSJ news alert shouldn’t have been “J.P. Morgan Chase’s Net Income Falls 76%” it should have been “J.P. Morgan Chase’s Net Income is Positive!”). The other’s problems are widely acknowledged as being cultural and borne of historical shortsightedness. Declaring the business model dead now would be silly.

Tips for a New Regulatory Structure

Since the candidates are making such a fuss about all these recent issues, and especially calling for more regulation, here are some helpful hints to ensure we all benefit…

1. Organize your regulatory structure like financial institutions organize their businesses. For example, instead of the C.F.T.C., M.S.R.B., N.A.S.D., and exchanges all regulating various parts of the financial infrastructure, build an overarching financial regulatory agency (you can even call it that, the F.R.A., I won’t charge you a quarter to use it each time). Have a division for banks and a division for broker dealers. In the division for broker dealers have the departments that oversee mergers and acquisitions, issuance of debt and equity, and trading in distinct units. Then, within each, subdivide it further–futures trading, exchanges, fixed income trading, etc. This is how firms organize their businesses. When a transaction crosses multiple areas, in the same way an investment bank would bring in multiple people “up the food chain” regulators can mimic that same structure and bring in people with similiar experience and oversight responsibilities.

A part of this is to merge banking oversight with broker-dealer oversight. This is because soon there will be no more standalone broker dealers… Ok, I’m kind of kidding… or am I? Another reason for this change is that, the same way large firms unite their operations and inter-weave their market activities, banks and broker dealers have become much more inter-connected. Let’s be honest, the average bank is less likely to be stable if it has a broker dealer that is massively leveraged and buying risky securities. Need an example? How about looking at Citi vs. J.P. Morgan Chase? Or E*Trade bank versus Commerce Bank?

2. Don’t let financial institutions lobby. Simple, right? Hank Paulson immediately put his boot on the throat of the Fannie and Freddy lobbying machine when bailing them out. Simple! With all the terrible things being said about lobbysists this cycle, you wouldn’t know politicians were running–so I’m sure there will be support for this kind of reform. Also, all things being equal, the average American is left worse off by lobbyists (hence the “reform” candidates all rail against lobbyists). Sadly, even the institutions the lobbysist were lobbying on behalf of seem to be in a situation where they would be better off had they not gotten what their lobbyists were lobbying for… Whew!

However, it must be difficult for a congressman to pass a law stopping a corporation from lobbying. It might even be illegal… not sure, I’m no lawyer. What I do know, however, is that if the governement decides to have their resources used to facilitate business for institutions, one could probably make the cessation of lobbying a condition. Would you rather put your money in an F.D.I.C. insured bank? Would you rather your bank could borrow at the discount window? Special tax breaks for profitable business lines? All these things should require the institution in question doesn’t lobby for, say, five years. I bet banks can get themselves into trouble often enough that, if they ask for help each time, a five year cessation of lobbying or hiring lobbyists will mean no more lobbying. Want to increase your leverage by borrowing freely from any of the Fed’s various sources of money? No lobbying.

3. Increase capital requirements for financial institutions. Make very strict rules for what counts as capital and how regulated ratios are determined. For example, perhaps holding Goodwill against sub-prime–backed C.D.O. squared’s isn’t the way to go. Or, maybe, allowing banks to book earnings from their credit deteriorating isn’t the way to go either. Suggesting that capital be better defined and more plentiful shouldn’t be a shock… this crisis of capital, with institutions begging investors to buy equity, is an issue with banks, capitalized as required, not having enough capital and failing (banks being used broadly). Lowering leverage lowers raises the economic margin of error. While lots of people will argue that an over-levered instution that invests in risky securities deserves to fail, why not avoid the over-levered institution that invests in risky securities in the first place? Actually, stop listening to me… Instead, for this, listen to The Deal Professor:

Lesson 4: Sometimes, You Can Only Raise Capital When You Don’t Need It

Lehman issued $4 billion in preferred stock in April — the share offering was oversubscribed. Even then, though, people whispered that the capital raise was a sign of weakness, reflecting Lehman’s anemic balance sheet. This paradox helped bring about the death of both Bear and Lehman: They needed capital, but raising it only made people more concerned about their state.

It is a Catch-22 for which we have yet to find a solution. And that is why, even to the bitter end, Lehman didn’t access the Federal Reserve’s emergency loan facility. If it had, everyone would have assumed it was in trouble.

The whole conundrum supports raising the capital reserve levels for investment banks. Ultimately, Lehman, Bear, Merrill and their balance sheets couldn’t stand the predicament

(Emphasis mine.)

See? Much more eloquent than I was…

4. Disclosure. One simple word. Require a lot more disclosure. How about setting well-defined scenarios that must appear and be spelled out in annual and quarterly filings? Report more sensitivities, using standard methods that are also disclosed, of assets to model parameters or market changes. If, for example, each investment bank was required to tell investors how their balance sheet would look if defaults ticked up to “5 CDR for life” there would be a lot less trouble today.

Also, force diclosures to occur more frequently. Make banks release some key metrics every Friday, for example. Having a 45-day delayed disclosure that is a snapshot from the last day of a 90-day period is completely ridiculous. We have computers now. One needen’t get out their abacus and punch cards to figure out earnings for a given period. Stop “month-end” dressing up of the balance sheet by requiring more frequent disclosure. Require banks to disclose maximums from the past x days. This way, if a bank tries to shrink it’s balance sheet purely to look like it’s done so, so that it can diclose soemthing that “looks better,” it will show up. Hiding information from shareholders or whomever else reads filings is not just troublesome, it shouldn’t be allowed.

These are just some of my random thoughts. I’m not sure they have merit, except where they are quoted from others. I’m no regulator, but if the next president needs and S.E.C. chairman, I suppose I can make myself available…

Build an Investment Bank: Technology

(As the first in this series, I’m trying to use construction terms to “build” our investment bank… we’ll see if it adds or detracts.)

The Foundation

As we begin our journey to build our very own investment bank, I’m going to make a few statements that people “in the know” will find both surprising and, in hindsight, very obvious. The topic, as the title states, is technology. Now, here are the statements:

1. A major contributing factor to the way banks did business, especially in the businesses that contributed the most to banks’ current  problems, was their lack of technology.
2. Credit default swaps, in all their glory, had most of their issues rooted in technological inadequacies at various institutions.
3. A large portion of the cost structures at investment banks are due to a lack of technological heft.

I know, these seem outrageous. However, as anyone who has worked at a few different firms will tell you, there is a massive difference between a firm with good technology and bad technology. Let me tell you a simple anecdote: When very senior executives at a firm called down to the managers in charge of securitized products, they asked for the current marks and a summary of the various exposures “on the books.” It took about ten people three days to cull through all the various positions, put marks on them, model them, and put a concrete value on them. There wasn’t time to break down exposures by anything but the most trivial categories. Now, why this end product was acceptable is a different issue, but it should be clear that an effort of this magnitude shouldn’t be necessary to answer questions so totally basic in the context of running a multi-billion-dollar (although now with fewer billions) financial institution. A corollary: If it takes you several days to enumerate the positions your area has, you don’t know what it is yourself.

Now, when I speak of technology, I’m really speaking of the specialized systems and solutions used to tackle business issues, and not really the “desktop support” kind of technology. The systems that manage risk and positions, handle accounting, maintain an integrated analytics platform, deliver research and other products internally and externally, manage the human resource functions of the firm, and otherwise grease the wheels of capitalism.

The Blueprint

Our technology plan will have a few different components…

Structural Frame 1: Whether our theoretical investment bank is a startup or an established entity, the technology at the core will be home grown.

Structural Notes: Hiring consultants to stitch together purchased solutions and legacy systems is unacceptable. Technology, in order to be most effective, needs to be responsive. When a trading desk needs to run its business, and the system provided is insufficient, then it’s an unacceptable solution, and things will be done manually. Remember synthetic CDOs? Remember the ABX and credit default swaps on sub-prime bonds? Would it surprise you to know that at many major investment banks there was a manual component involved with every single contract and trade? The systems weren’t able to handle these instruments, and these businesses scaled up at a rate that was untenable. Also, there were no analytics available for these products. Businesses bought third party solutions for modeling and analytics, but those didn’t integrate or scale, so all the marks and risk numbers used to compute capital needs and P&L were merely estimates as these businesses were growing the most.

Let that sink in. Is it any wonder the senior managers didn’t know, before it was too late, what the actual exposures were? Had these firms built an integrated set of systems instead of buying a patchwork of specialized programs to solve the most current problem, these issues would not have been nearly as bad. I won’t even tell, in detail, the story about how, years ago, the system for trading credit default swaps at one bank was so difficult to use that they only created one identifier for GM and GMAC, not distinguishing between the two at all. But, when they were both on the brink of being downgraded to junk, but GMAC was de-coupled from GM, I wonder what kind of fun it was to rummage through 5- to 8-year-old confirms trying to match thousands and thousands of trades with the exact entity? Costly? Absolutely. Avoidable? Double absolutely.

On another note, an investment bank need not be innovative, but if it isn’t, then it should be able to mimic innovations quickly. Reporting to management, having an accurate record of transactions and various changes to the firm’s balance sheet, the ability to run various analyses on various products, and other, more basic, reporting functions (not even mentioning compliance and regulatory functionality) are all things that should be implementable once something new hits, and the only way to make these kinds of incremental changes is to build, not buy. A business as complex as an investment bank shouldn’t be reliant on outside parties to build software vital to their business–both from a cost standpoint and from a delay-until-completion standpoint. Further, the procurement process takes months!

Structural Frame 2: The technology part of the organization will not be a monolithic standalone bureaucracy.

Structural Notes: Simply put, technology (the people or business unit) needs to be vested in the process of making a business more profitable. Rather than taking on the normal support role mentality of, “If I say ‘yes’ then I might be wrong and held accountable, so I will say ‘no.'” The best way to do this is to not have technology be its own portion of the organization. Allowing technology to have a seperate seat at the table–or, worse, report into some catchall support person–only contributes to creating a centralized process for technology decisions. Centralizing technology decisions for many businesses with different needs creates unnecessary layering and wedges a huge management structure between the people doing the actual work and the people who are using the product and paying for it.

The final plan, I believe, would be to have as many technology people as possible integrated into the physical workspace of the people that utilize their work. Have investment banking developers sitting amongst investment bankers. Have the developers that build trading applications sitting with traders. The reporting structure should be a matrix of sorts–senior technology managers should report into a business whose technology needs are distinct from other businesses (atomic, perhaps is a better word) as well as a more senior technology person. In essence, people working in technology would be ingrained with the thought that they are there to help–the business unit would be setup as the client and the technology super-structure would be more for managing the processes. Obviously when the business is viewed as the client, technology managers are incentivized to get the businesses what they want, and when the people (both doing the work and in charge of liaising with the clients/business) are integrated (and can see the working environment of their clients and usage of their products) a lot of inefficiency and “lost in translation” moments are avoided. Senior managers really need to think of their business as including technology instead of interacting with it. This is highly important and is much more likely with a structure like I’ve proposed. Also, the closeness will just yield some more technologically savvy people and even encourage people to move between the two “worlds.”

Structural Frame 3: The people who are hired for technology roles will be of a high caliber and will be under a compensation regime and in an environment that sets big technology companies to shame.

Structural Notes: This shouldn’t be a hard line of reasoning to follow, but in general the difference between firms that “get it” and firms that don’t is how they recruit. Having an engineering background, I was recruited for I.T. from a very good school for that sort of thing by a few banks. Those banks have a high correlation to both still being around and surviving the mortgage mess with the smallest scathing in their peer group. I know several people who have told me that some other firms, one that haven’t been so lucky, have absolutely ridiculous and incredibly stupid policies for recruiting technology people. Most notably, one Manhattan firm recruits from local state schools almost exclusively–this is done so that the students they recruit can work part time during their senior year of college. No school in the top fifty or so participates. If one had to draw a grid, and rank various factors as to how important they are, the program I have just mentioned is the most ridiculous, stupid, and demonstrating a complete lack of critical thinking skills (or, for that matter, basic grasp of the business and reality) of the programs I have heard of or encountered. The people responsible for it have all moved on and the firm has suffered greatly from it’s underinvestment in technology.

So, to recruit good people you need a draw. To be honest, most graduates don’t fully grasp the concept of upside or career path–especially not ones in I.T. This makes it simple to get them, just offer a bigger number for the compensation in the first year. While this would work, it should be clear that this won’t help make them much more productive than the average technology drone in an investment bank. Giving technology employees a compensation structure that matches the businesses they are supporting is, in my view, a great solution. Obviously there would be more stability, but there should be a linking of incentives to the business and an interconnectedness in how they think about how technology and the problems facing the business. They should also have an incentive to be proactive and try to advocate solutions to problems they see instead of waiting for others to focus on them–this contributes greatly to becoming a nimble organization.

As for work environment, whenever possible, for groups not truly linked to a single business, like infrastructure groups and the web development team, my focus would be on building a start up-like atmosphere. The marginal cost of things like free coffee, free food, and some extra square footage for odd amenities is insignificant in relation to the quality of the work produced by the people snatched from places like Microsoft and Google versus a lower caliber of student culled from whatever lower-tier school(s) happens to be nearby. When you know your competition and what they offer that you do not, it’s very easy to compete: just offer what they offer. For things that aren’t as timely and linked to a knowing how a certain business runs, there is no problem in creating a lifestyle and work ethic that is free-form as long as it meets goals and needs of the firm. (Note: This isn’t my unique idea. A certain investment bank with a strong brand does this sort of thing already… but I did think of it before I knew that!)

Structural Frame 4: Technology, especially experimental or new technologies, should be used to try to create, or even drive, value.

Structural Notes: This is more a philosophy than an actual directive, but it’s important to taking a firm’s strategy on technology to the “next level.” There is a massive body of knowledge within a firm that is lost everyday due to a lack of effort. Usually the solution is to put humans somewhere and have them manually type in numbers or perform mundane tasks to get this working smoothly. Not in our investment bank! Let me furnish you with an example. The corporate bond market works in an unusual way: traders send around “runs” or lists of bonds with quotes of where they are willing to buy and sell bonds via Bloomberg’s messaging system–they are generally free form text. Why do they do it this way? It’s quick and easy. The firm I worked at didn’t make any effort to collect these pricing levels and store them somewhere. However, for publishing strategy reports, helping the desk find trade ideas based on historical relationships, calculating risk metrics, and any other number of things, this data would have been vital. Technology can easily help to store, warehouse, and serve these sorts of datasets (readily available from the market but unstructured) and help the organization as a whole improve its efficiency. This is just one example, but it serves to illustrate a point that is extremely common in an investment bank–lots of things require information that no one keeps but was readily available. Technology can drive value for lots of internal things by helping to solve problems like this. And, honestly, there are too many things that are out of one’s control not to have an organized and structured solution to the simple things that can be fixed.

Another note on technology, however, is that as the Web innovates social behaviors and collaboration those technologies should be actively examined as potential solutions to problems an investment bank would face. For example, lots and lots of information is needed when talking to a client. Getting good market “color” that everyone can see, and that is available, consistent, and easy to find is important. Perhaps a series of blogs could be used to ensure the delivery of this content is made as efficient as possible. One way I added value at my firm was by knowing as many people as possible. When liquidity started becoming an issue, the people I spoke to on the desk that funded banks in the LIBOR-based funding market explained what was the situation and we were able to assess if we thought this warranted a change in our positions or business in general. If that desk had a blog where they posted color throughout the day and the firm had an easy way to deliver this information to all of its employees, perhaps this could have helped people develop a more specific view on the market and notice some irregularities leading to the current crisis. Could Wikis be used effectively? I’m sure that they could. If it was institutionalized to have an up-to-date knowledge base within the firm, and it was made a priority to keep those things updated, nuances and details on complex transactions could be documented. People could avoid falling into the same traps or having to research the same issues other already have. These are just a few examples of how new technology innovations can be used to create value where it would otherwise be impossible.

Structural Frame 5: Every employee should be very comfortable with technology and make a large effort to integrate it into their work.

Structural Notes: I hate to sound like a snob, but in general, if you can’t figure out things like email and basic spreadsheets, you don’t have a lot of room left to grow. People should learn new technologies as they are available and make an effort to work more effectively. If this isn’t a priority of almost everyone in the firm, then building new systems and integrating things into their daily “workflow” is useless. Part of pushing the envelope on how new things are used means that people will have to learn how to use them. I’ve seen too many people, uncomfortable with a new system, resort to keeping their risk positions and other vital data the firm should know in a spreadsheet. Unacceptable. Now, not everyone has to “ooohhh” and “aaahhhh” over new features and technological platforms, but everyone should be asking themselves how they can use some new technology product to make more money, pitch more transactions, better monitor the firm’s risk, develop a better strategy for investing, or whatever their job entails. I don’t think this is hard, but I do think it’s important. And, with technology employees sitting with business people and understanding how they work day-to-day, the resources to figure out these sorts of things will be much more readily available than at most other firms. (See how the “structural frames” all interplay?)

The Final Inspection

As one can see, I value the little things that help people get 10-15% more productivity out of their daily routine–that’s the edge most firm’s need to excel in what they are focusing on. However, most firms poorly thought out systems and infrastructure issues, especially when it comes to technology, adds a hugely cost-ineffective layer of one-fix-at-a-time solutions that have added up. Why have a system where traders can input their own trades as they do them? Give them a paper record and hire a person, with full benefits and being paid an amount commensurate with living in New York City, to type them in. Oh, and now that the business has grown to three times to trading volume in six months, let’s hire four more people. Why have a system that allows a capital markets person to view real-time quotes in their sector or updates those quotes into a spreadsheet or presentation? Just have a bunch of analysts do it by hand. Why would you want a system that can model securitizations and CDOs and run the numbers effectively? We can have someone do it in a spreadsheet, that’s “close enough.” Although it doesn’t capture the nuanced risk factors, I’m sure defaults will never get high enough to worry about. These are the kind of solutions that, from the start, one should be thinking about. From the first instant it’s possible to fix these, they should be fixed. I think the five parts of the framework I’ve laid out will make a good plan to follow when building the technology part of our investment bank!

You’ll notice your paycheck is lower. We have reformed it!

The F.T. had an article yesterday about  an organization (that I’ve never heard of) coming up with “code of best practice” to establish banker’s pay (note that the F.T. mentions rules would be geared toward traders, so much like most of the financial media, they think everyone at an investment bank is a banker). Obviously it’s a disadvantage for whichever institution institutes these things on their own–if you’re going to be paid less and be at a long-term risk for something you do at one institution, but not at another, then you’ll avoid working there. So, here’s my question: At what point is a bunch of bank’s, getting together to talk about a new code for pay, establishing a “code of best practice” versus being anti-competitive?  Just a thought.