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	<title>Comments for Betting the Business</title>
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	<link>http://bettingthebusiness.com</link>
	<description>Financial risk management for non-financial corporations</description>
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		<title>Comment on CSI: prop trading investigation squad. by John Parsons</title>
		<link>http://bettingthebusiness.com/2013/04/21/csi-prop-trading-investigation-squad/#comment-434</link>
		<dc:creator><![CDATA[John Parsons]]></dc:creator>
		<pubDate>Mon, 22 Apr 2013 15:16:45 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1862#comment-434</guid>
		<description><![CDATA[So we agree on your main point. The original post says what you say, right there in the second proviso. I have no beef with your point.]]></description>
		<content:encoded><![CDATA[<p>So we agree on your main point. The original post says what you say, right there in the second proviso. I have no beef with your point.</p>
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		<title>Comment on CSI: prop trading investigation squad. by The Crimson Reach</title>
		<link>http://bettingthebusiness.com/2013/04/21/csi-prop-trading-investigation-squad/#comment-433</link>
		<dc:creator><![CDATA[The Crimson Reach]]></dc:creator>
		<pubDate>Mon, 22 Apr 2013 14:13:40 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1862#comment-433</guid>
		<description><![CDATA[Two things.

1. JP only &#039;insisted it was hedging&#039; with regard to its CIO division. Not its &#039;derivatives portfolio&#039;. These aren&#039;t the same thing, and the graph you actually have is the latter not the former.

2. I don&#039;t &#039;assume&#039; that market making (or i would rather say, &#039;non-CIO activities&#039;) is what dominates that figure, I&#039;m just saying it&#039;s possible, and indeed we have no reason to believe otherwise.

I notice that (at least if I understand the figure correctly) the &#039;derivatives portfolio&#039; was ramped *way down* in size/risk/basis starting in around 2009. Does that jibe with what is known/understood about their CIO trading? Because if not, why would you look at this figure and think it reflects the fingerprints of their CIO to any material degree at all?

I&#039;m all for looking at and using all available data. I understand available data is limited. I also understand that my Volcker position is not orthodox and to someone who does favor the rule, &#039;was CIO primarily hedging?&#039; is an interesting question. I think my main point was, &#039;does their derivatives portfolio hedge the rest of the bank?&#039; is just not the same question. There is no earthly reason why it should or would, Volcker or no Volcker. &#039;Derivatives vs non derivatives&#039; is not a good proxy for CIO vs rest-of-bank.

Best]]></description>
		<content:encoded><![CDATA[<p>Two things.</p>
<p>1. JP only &#8216;insisted it was hedging&#8217; with regard to its CIO division. Not its &#8216;derivatives portfolio&#8217;. These aren&#8217;t the same thing, and the graph you actually have is the latter not the former.</p>
<p>2. I don&#8217;t &#8216;assume&#8217; that market making (or i would rather say, &#8216;non-CIO activities&#8217;) is what dominates that figure, I&#8217;m just saying it&#8217;s possible, and indeed we have no reason to believe otherwise.</p>
<p>I notice that (at least if I understand the figure correctly) the &#8216;derivatives portfolio&#8217; was ramped *way down* in size/risk/basis starting in around 2009. Does that jibe with what is known/understood about their CIO trading? Because if not, why would you look at this figure and think it reflects the fingerprints of their CIO to any material degree at all?</p>
<p>I&#8217;m all for looking at and using all available data. I understand available data is limited. I also understand that my Volcker position is not orthodox and to someone who does favor the rule, &#8216;was CIO primarily hedging?&#8217; is an interesting question. I think my main point was, &#8216;does their derivatives portfolio hedge the rest of the bank?&#8217; is just not the same question. There is no earthly reason why it should or would, Volcker or no Volcker. &#8216;Derivatives vs non derivatives&#8217; is not a good proxy for CIO vs rest-of-bank.</p>
<p>Best</p>
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		<title>Comment on CSI: prop trading investigation squad. by John Parsons</title>
		<link>http://bettingthebusiness.com/2013/04/21/csi-prop-trading-investigation-squad/#comment-432</link>
		<dc:creator><![CDATA[John Parsons]]></dc:creator>
		<pubDate>Mon, 22 Apr 2013 12:41:09 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1862#comment-432</guid>
		<description><![CDATA[A couple of thoughts in reply.

1. OK, if you reject the Volcker Rule, then you may not be interested. But, for those of us dealing with the Volcker Rule, the questions matter. Indeed, JP Morgan has insisted it was hedging and would be in compliance with the Rule. It has not defended its actions by dismissing the wisdom of the Rule as you have. My post is only pushing on their defense.

2. The aggregation to the entire derivatives portfolio is an artifact of the available public data. You are certainly right that the publicly reported financials are not very valuable for an in depth analysis the different lines of business at the big banks. That&#039;s another issue entirely. But I wouldn&#039;t be so nihilistic as to not even look at the numbers for the aggregated portfolio.

3. You conjecture that the exposure on the derivatives portfolio may be an feature of the market making line of business. That&#039;s correct, it may be. At least in principle, as a logical possibility, if not an empirical likelihood. Have you actually taken a look at the figure? It&#039;s telling you something about the dynamics of the exposure. Do those dynamics look like what comes from a market making business? Maybe. But I&#039;ve never seen a model of a market making business that generates that exposure. Have you? Instead of debating abstract logical possibilities, we need to try to understand these lines of business and their drivers. I&#039;m open to this pattern reflecting market making. But then we will have learned something about market making. But I&#039;m not open to just assuming that it does without taking the numbers seriously and considering the implications and whether they make sense with the other aspects of the business that we know about. That&#039;s too lazy.]]></description>
		<content:encoded><![CDATA[<p>A couple of thoughts in reply.</p>
<p>1. OK, if you reject the Volcker Rule, then you may not be interested. But, for those of us dealing with the Volcker Rule, the questions matter. Indeed, JP Morgan has insisted it was hedging and would be in compliance with the Rule. It has not defended its actions by dismissing the wisdom of the Rule as you have. My post is only pushing on their defense.</p>
<p>2. The aggregation to the entire derivatives portfolio is an artifact of the available public data. You are certainly right that the publicly reported financials are not very valuable for an in depth analysis the different lines of business at the big banks. That&#8217;s another issue entirely. But I wouldn&#8217;t be so nihilistic as to not even look at the numbers for the aggregated portfolio.</p>
<p>3. You conjecture that the exposure on the derivatives portfolio may be an feature of the market making line of business. That&#8217;s correct, it may be. At least in principle, as a logical possibility, if not an empirical likelihood. Have you actually taken a look at the figure? It&#8217;s telling you something about the dynamics of the exposure. Do those dynamics look like what comes from a market making business? Maybe. But I&#8217;ve never seen a model of a market making business that generates that exposure. Have you? Instead of debating abstract logical possibilities, we need to try to understand these lines of business and their drivers. I&#8217;m open to this pattern reflecting market making. But then we will have learned something about market making. But I&#8217;m not open to just assuming that it does without taking the numbers seriously and considering the implications and whether they make sense with the other aspects of the business that we know about. That&#8217;s too lazy.</p>
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	<item>
		<title>Comment on CSI: prop trading investigation squad. by Are all things supposed to hedge all other things now? &#124; Rhymes With Cars &#38; Girls</title>
		<link>http://bettingthebusiness.com/2013/04/21/csi-prop-trading-investigation-squad/#comment-428</link>
		<dc:creator><![CDATA[Are all things supposed to hedge all other things now? &#124; Rhymes With Cars &#38; Girls]]></dc:creator>
		<pubDate>Mon, 22 Apr 2013 02:39:30 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1862#comment-428</guid>
		<description><![CDATA[[...] Parsons looks at whether JP Morgan&#8217;s &#8216;derivatives portfolio&#8217; (?) (all derivatives? so [...]]]></description>
		<content:encoded><![CDATA[<p>[...] Parsons looks at whether JP Morgan&#8217;s &#8216;derivatives portfolio&#8217; (?) (all derivatives? so [...]</p>
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		<title>Comment on Can Hedging Save Cyprus? by Linx/comment &#124; Rhymes With Cars &#38; Girls</title>
		<link>http://bettingthebusiness.com/2013/04/17/can-hedging-save-cyprus/#comment-418</link>
		<dc:creator><![CDATA[Linx/comment &#124; Rhymes With Cars &#38; Girls]]></dc:creator>
		<pubDate>Wed, 17 Apr 2013 18:33:01 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1860#comment-418</guid>
		<description><![CDATA[[...] wants to buy some Cyprus-GDP-linked Cyprus structured notes? Don&#8217;t all raise your hands at once. I&#8217;ll admit I&#8217;m scratching my head over the [...]]]></description>
		<content:encoded><![CDATA[<p>[...] wants to buy some Cyprus-GDP-linked Cyprus structured notes? Don&#8217;t all raise your hands at once. I&#8217;ll admit I&#8217;m scratching my head over the [...]</p>
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	<item>
		<title>Comment on Can Hedging Save Greece? by Can Hedging Save Cyprus? &#171; Betting the Business</title>
		<link>http://bettingthebusiness.com/2012/02/23/can-hedging-save-greece/#comment-416</link>
		<dc:creator><![CDATA[Can Hedging Save Cyprus? &#171; Betting the Business]]></dc:creator>
		<pubDate>Wed, 17 Apr 2013 12:43:42 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1413#comment-416</guid>
		<description><![CDATA[[...] we&#8217;ve written in a couple of earlier posts, this is easier said than done. But it&#8217;s certainly thinking along the right [...]]]></description>
		<content:encoded><![CDATA[<p>[...] we&#8217;ve written in a couple of earlier posts, this is easier said than done. But it&#8217;s certainly thinking along the right [...]</p>
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		<title>Comment on The Promise and Pitfalls of Indexed Debt by Can Hedging Save Cyprus? &#171; Betting the Business</title>
		<link>http://bettingthebusiness.com/2011/10/25/the-promises-and-pitfalls-of-indexed-debt/#comment-415</link>
		<dc:creator><![CDATA[Can Hedging Save Cyprus? &#171; Betting the Business]]></dc:creator>
		<pubDate>Wed, 17 Apr 2013 12:43:39 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1267#comment-415</guid>
		<description><![CDATA[[...] we&#8217;ve written in a couple of earlier posts, this is easier said than done. But it&#8217;s certainly thinking along the right [...]]]></description>
		<content:encoded><![CDATA[<p>[...] we&#8217;ve written in a couple of earlier posts, this is easier said than done. But it&#8217;s certainly thinking along the right [...]</p>
]]></content:encoded>
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		<title>Comment on Dynamic Hedging or Futile Speculation? by Gold’s Random Walk &#171; Betting the Business</title>
		<link>http://bettingthebusiness.com/2013/04/03/dynamic-hedging-or-futile-speculation/#comment-411</link>
		<dc:creator><![CDATA[Gold’s Random Walk &#171; Betting the Business]]></dc:creator>
		<pubDate>Fri, 12 Apr 2013 12:47:41 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1831#comment-411</guid>
		<description><![CDATA[[...] week I wrote a post in which I mentioned that the time series of commodity spot prices are often mean reverting. They [...]]]></description>
		<content:encoded><![CDATA[<p>[...] week I wrote a post in which I mentioned that the time series of commodity spot prices are often mean reverting. They [...]</p>
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		<title>Comment on Congressional Intent &amp; Futurization by GELDBLOG &#187; Blog Archive &#187; Try und Swaps zu regulieren ist gescheitert</title>
		<link>http://bettingthebusiness.com/2012/12/13/congressional-intent-futurization/#comment-405</link>
		<dc:creator><![CDATA[GELDBLOG &#187; Blog Archive &#187; Try und Swaps zu regulieren ist gescheitert]]></dc:creator>
		<pubDate>Sat, 06 Apr 2013 16:23:31 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1720#comment-405</guid>
		<description><![CDATA[[...] standardizable Swaps werden praktisch nicht zu unterscheiden vom Typ Terminkontrakte sind, erklärt  Wirtschaftswissenschaftler John Parsons auf seinem Blog , Wetten das [...]]]></description>
		<content:encoded><![CDATA[<p>[...] standardizable Swaps werden praktisch nicht zu unterscheiden vom Typ Terminkontrakte sind, erklärt  Wirtschaftswissenschaftler John Parsons auf seinem Blog , Wetten das [...]</p>
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		<title>Comment on Hiding Risk by Netting Exposures by John Parsons</title>
		<link>http://bettingthebusiness.com/2013/02/22/hiding-risk-by-netting-exposures/#comment-404</link>
		<dc:creator><![CDATA[John Parsons]]></dc:creator>
		<pubDate>Thu, 04 Apr 2013 11:40:27 +0000</pubDate>
		<guid isPermaLink="false">http://bettingthebusiness.com/?p=1809#comment-404</guid>
		<description><![CDATA[Pardha,
You make some very important points which dig much deeper into the issue than the usual discussion. I need to take some time to think my way through your points. My main point was that the argument in favor of taking the net exposure at face value ignores the dynamics. It shows a snapshot of exposure assuming the risk referees blow a whistle and declare &quot;game over&quot; and all players simply count up their positive and negative exposures. In reality, there are no referees and no sudden whistle. There are complicated market dynamics, sudden events and rumors, and there are strategic actions taken by all parties which dramatically alter the positive and negative exposures as the game plays out. The final result can be very different from what the net exposure had predicted. Your point, as I understand it, is that collateral works differently in this dynamic game than do offsetting exposures. And that CSA&#039;s shape they dynamics, along with other things. You are basically agreeing that we shouldn&#039;t ignore the dynamics, as a simple netting would. But you are delving deeper into what determines the dynamics. Good point.]]></description>
		<content:encoded><![CDATA[<p>Pardha,<br />
You make some very important points which dig much deeper into the issue than the usual discussion. I need to take some time to think my way through your points. My main point was that the argument in favor of taking the net exposure at face value ignores the dynamics. It shows a snapshot of exposure assuming the risk referees blow a whistle and declare &#8220;game over&#8221; and all players simply count up their positive and negative exposures. In reality, there are no referees and no sudden whistle. There are complicated market dynamics, sudden events and rumors, and there are strategic actions taken by all parties which dramatically alter the positive and negative exposures as the game plays out. The final result can be very different from what the net exposure had predicted. Your point, as I understand it, is that collateral works differently in this dynamic game than do offsetting exposures. And that CSA&#8217;s shape they dynamics, along with other things. You are basically agreeing that we shouldn&#8217;t ignore the dynamics, as a simple netting would. But you are delving deeper into what determines the dynamics. Good point.</p>
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