Discussion and concern abounds on the Street whether the United States’ debt obligations receive a rating downgrade from the major agencies and an actual default occurs on U.S.-guaranteed debt. The rating agencies have their own skeletons in the closet from 2004 to 2009 that certainly contributed to the financial crisis and ongoing “Great Recession”. So, we have little doubt that the reformed bond raters will rise to rescue the capital markets from another calamity.
Bank investors should care most about the ratio of tangible capital to underlying risk assets, or the Tier 1 Common equity. Thus, what happens to Tier 1 Common ratios IF U.S. Treasuries and other guaranteed government bonds changed from a 0% risk-weight to 20% thanks to a ratings change?
We think investors need to be well aware of this issue, which is why we dug into the math. There are 984 bank holding companies(BHCs), among both private and public concerns, and we computed a median Tier 1 Common ratio of 10.67% at 3-31-11.
If the combined US Treasuries and State/Govt. issues dropped from a 0% risk-weight to 20%, the median capital ratio would drop to 10.34%. The capital deterioration seems benign. In our recent Weekly Musings industry note (see Pages 3 & 4), we show an example portfolio composition with the highlighted areas in yellow. For those BHCs with a large change in capital ratio, the companies had heavy capital above 15.0%.
In fact, we found only 5 banks whose Tier 1 Common dropped below the 7.0% threshold being established by the Basel III international capital standards. Each of these banks had a minor adjustment and were only modestly above 7.0% Tier 1 Common—this is hardly a needle-mover in our book.
For investors in banks stocks, a few key items to remember:
(1) The FDIC and Federal Reserve hold guidelines for how banks determine risk-weightings on securities, loans, and other assets disclosed on quarterly call report filings. If the FDIC and Fed do not alter the 0% risk-weights, perhaps this is a non-event.
(2) Many banks have long shifted into RMBS and other securities that already carry a 20% risk-weighting and are generally less exposed to pure U.S. government issues than in the past.
(3) Perhaps a greater risk to consider is a militant interpretation from bank auditors that an actual default on US Govt. debt should trigger a shift in risk-weighting despite inaction by regulatory agencies. Such an auditor could refuse to endorse quarterly financial statements. In this regard, the opinion of the accounting firms and their policy committees could be among the most important trend to watch.