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Peter J. Wallison                    481


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         total assets of $4 trillion.  If we assume that the banks had a leverage ratio of about
         15-to-1 in 2008 and the investment banks about 30-to-1, that would mean that the
         equity capital position of the banking industry as a whole would be about $650
         billion and the same number for the investment banks would be about $130 billion,
         for a total of $780 billion. Under these circumstances, the collapse of the PMBS
         market alone reduced the capital positions of U.S. banks and investment banks by
         approximately 41 percent on a mark-to-market basis. Th  is does not mean that any
         actual losses were suff ered, only that the assets concerned might have to be written
         down or could not be sold for the price at which they were previously carried on the
         fi rm’s balance sheet.
              In addition, Roubini and Parisi-Capone estimated that U.S. commercial
         and investment banks suff ered a further mark-to-market loss of $225 billion on
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         unsecuritized subprime and Alt-A mortgages.  Th  ey also estimated that mark-to-
         market losses for fi nancial institutions outside the U.S. would be about 40 percent
         of U.S. losses, so there was likely to be a major eff ect on banks and other fi nancial
         institutions around the world—depending, of course, on their capital position at the
         time the PMBS market stopped functioning. I am not aware of any data showing the
         mark-to-market eff ect of the collapse of the PMBS market on other U.S. fi nancial
         institutions, but it can be assumed that they also suff ered similar losses in proportion
         to their holdings of PMBS.
              Losses of this magnitude would certainly be enough—when combined
         with other losses on securities and loans not related to mortgages—to call into
         question the stability of a large number of banks, investment banks and other
         fi nancial institutions in the U.S. and around the world. However, there was one
         other factor that exacerbated the adverse eff ect of the loss of a market for PMBS.
         Although accounting rules did not require all PMBS to be written down, investors
         and counterparties did not know which fi nancial  institutions were holding the
         weakest assets and how much of their assets would have to be written down over
         time. Whatever that amount, it would reduce their capital positions at a time when
         investors and counterparties were anxious about their stability. Th  is was the balance
         sheet eff ect that was the third element of Chairman Bair’s summary.
              To summarize, then, the following are the steps through which the
         government’s housing policies transmitted losses—through PMBS—to the largest
         fi nancial  institutions:  (i) the 19 million NTMs acquired or guaranteed by the
         Agencies were major contributors to the growth of the bubble and its extension
         in time; (ii) the growth of the bubble suppressed the losses that would ordinarily
         have brought the development of NTM-backed PMBS to a halt; (ii) competition
         for NTMs drove subprime lenders further out the risk curve to fi nd high-yielding
         mortgages to securitize, especially when these loans did not appear to be producing
         losses commensurate with their risk; (iv) when the bubble fi nally burst, the
         unprecedented number of delinquencies and defaults among all NTMs—the great
         majority of which were held or guaranteed by the Agencies—caused investors to

         56   Timothy F. Geithner, “Reducing Systemic Risk in a Dynamic Financial System,” Remarks at the
         Economic Club of New York, June 9, 2008, available at http://www.ny.frb.org/newsevents/speeches/2008/
         tfg080609.html.
         57   Nouriel Roubini and Elisa Parisi-Carbone, “Total $3.6 Trillion Projected Loan and Securities
         Losses,” p.7.
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