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28 Sep 04:58

Book Review: DIY Financial Advisor

by David Merkel

diy-financial-advisor-3842593-f00

I am generally not a fan of formulaic books on investing, and this is particularly true of books that take unusual approaches to investing. This book is an exception because it does nothing unusual, and follows what all good quantitative investors know have worked in the past.  The past is not a guarantee of the future, but if the theories derived from past data make sense from what we know about human nature, that’s about as good as we can get.

The book begins with a critique of the abilities of financial advisors — their fees, asset allocation, and security selection.  It then shows how models of financial markets outperform most financial advisors.

Then, to live up to its title , the book gives simple versions of models that can be applied by individuals that would have outperformed the markets in the past.  You can beat the markets, lower risk, and “Do It Yourself [DIY].”  It provides models for asset allocation, stock selection, and risk control, simple enough that a motivated person with math skills equal to the first half of Algebra 1 could apply them in a moderate amount of time per month.  It also provides a simpler version of the full model that omits the security selection for stocks.

The book closes by offering three reasons why people won’t follow the book and do it themselves: fear of failure, inertia, and not wanting to give up an advisor who is a friend.  It also offers three risks for the DIY investor — overconfidence, the desire to be a hero (seems to overlap with overconfidence), and that the theories may be insufficient for future market behavior.

This is where I have the greatest disagreement with the book.  I interact with a lot of people.  Most of them have no interest in learning the slightest bit about investing.  Some have some inclination to learn about investing, but even the simple models of the book would make their heads spin, or they just wouldn’t want to take the time to do it.  Some of it is similar to seeing a Youtube video on draining and refilling your automatic transmission fluid.  You might watch it, and say “I think I get it,” but the costs of making a mistake are sufficiently severe that you might not want to do it without an expert by your side.  Most will take it to the repair garage and pay up.

I put a knife to my own throat as I write this, as I am an investment advisor, but there is more specialized knowledge in the hands of an auto mechanic than in an investment advisor, and the risk of loss is lower to manage your own money than to fix your own brakes.  That said, enough people after reading the book will say to themselves, “This is just one author, and I barely understand the performance tables in the book — if right, am I capable of doing this?  Or, could it be wrong?  I can’t verify it myself.”

The book isn’t wrong.  If you are willing to put in the time to follow the instructions of the authors, I think you will do better than most.  My sense is that the grand majority people are not willing to do that.  They don’t have the time or inclination.

 

Quibbles

The book could have been clearer on the ROBUST method for risk control.  It took me a bit of effort to figure out that the two submodels share half of the weight, so that when submodels A & B flash green — 100% weight, one green and one red — 50% weight, both red — 0% weight.

Also, the book is enhanced by the security selection model for stocks, but how many people would have the assets to assemble and maintain a portfolio with sufficient diversification?  The book might have been cleaner and simpler to leave that out.  The last models of the book don’t use it anyway.

Summary / Who Would Benefit from this Book

I liked this book, and I recommend it for those who are willing to put in the time to implement its ideas.  This is not a book for beginners, and you have to be comfortable with the small amount of math and the tables of financial statistics, unless you are willing to trust them blindly.  (Or trust me when I say that they are likely accurate.)

But with the caveats listed above, it is a good book for people who are motivated to do better with their investments.  If you want to buy it, you can buy it here: DIY Financial Advisor.

Full disclosure: I received a copy from one of the authors, a guy for whom I have respect.

If you enter Amazon through my site, and you buy anything, I get a small commission.  This is my main source of blog revenue.  I prefer this to a “tip jar” because I want you to get something you want, rather than merely giving me a tip.  Book reviews take time, particularly with the reading, which most book reviewers don’t do in full, and I typically do. (When I don’t, I mention that I scanned the book.  Also, I never use the data that the PR flacks send out.)

Most people buying at Amazon do not enter via a referring website.  Thus Amazon builds an extra 1-3% into the prices to all buyers to compensate for the commissions given to the minority that come through referring sites.  Whether you buy at Amazon directly or enter via my site, your prices don’t change.

26 Sep 03:16

Value Investing is not so easy

by subra
When people get fancy degrees in investing, they get trapped in jargon. Luckily for me I got into investing before I had any degree. Let us look at some of the jargon. Value Investing vs Growth Investing: All investing is value investing. You put Rs. 100 today hoping to earn more than Rs. 100 over […]
25 Sep 15:45

Volkswagen Uses A Defeat Device To Rig Emission Tests of Diesel Cars, Will Have Serious Impact

by Deepak Shenoy

Volkwagen could been fined upto $18 billion for manipulating emission tests in America. They apparently used a “defeat device” in certain diesel cars that were designed to reduce emissions only if the car was being tested.

What’s the problem?

Diesel cars have become more popular worldwide recently, as engines have evolved. Diesel engines use more compression and as a fuel diesel can provide greater economy (30% more distance driven than for petrol). But it’s a more “dirty” fuel, in that it produces more Nitrogen Oxides, or NOx. (But apparently, less carbon monoxide). NOx is responsible for smog, so the US in particular is very stringent on NOx emission norms.

Diesel engines used to be noisy and rattled a lot, but changes in engine design ensured that they ran smoother and had lower emissions, while retaining great fuel efficiency. But VW apparently couldn’t cut the emissions enough to have good performance and fuel efficiency, so they cheated.… (Read On...)

25 Sep 15:44

Bangalore struggles to fill potholes – An interesting (and tragic) case of technology vs labor..

by Amol Agrawal
Bangalore’e eternal struggle with potholes, garbage, water and power continue and keep getting worse. This post is on this interesting story on potholes and how the administration is just clueless on what to do. In 2013, amidst huge fanfare govt. had imported Python– a pothole filling machine. Another machine was imported from Canada called Jetpacker. Even […]
25 Sep 15:44

Eat your own cooking?

by subra
A hotelier who puts a board saying “The owner eats here” is supposed to be a good hotelier. He eats his own cooking. However should an IFA (Independent Financial Adviser) or a bank RM, or a Life Insurance agent have his own Adviser? Or should he do his own financial planning? I do not know […]
25 Sep 15:41

New Wealth Builders

by Muthu

The Economist Intelligence Unit (EIU) has released a report recently. There is a new category of wealthy people identified as ‘New Wealth Builders’ (NWBs).

As per this report, high net worth (HNW) households are those holding financial assets worth more than $2 million (Rs.13 crores; throughout this piece, I’ve assumed $1=Rs.65). This is in addition to a primary residence.

New wealth Builders are those who have (in addition to primary residence), financial assets of $100,000 (Rs.65 lakhs) to $2 million (Rs.13 crores). This category has grown significantly over last 10 years and is expected to grow much in the years to come.

NWBs have created wealth through their profession or business during the last 10 years. Only a small portion (3%) has inherited wealth.

4.8 lakh households in India are classified as NWBs.

We’ve seen in earlier reports that around 2 lakh households in India have net worth of $1 million or more.

We’ve also seen that a household is considered rich if it has financial assets above $100,000 (Rs.65 lakhs) in addition to a primary residence.

There are 300 million households in India, out of which half a million households have wealth more than $100,000. So 0.16% of India is wealthy.

EIU projects India to have 4.9 million NWB households in 2020; with an average wealth of $178,000 (Rs.1.15 crore).

This is very significant as close to 2% of our households would become wealthy by 2020.


25 Sep 15:40

Sahaj: Get New LPG Cylinder connection online

by bemoneyaware

How to get a new Gas i.e LPG Connection? Earlier it was going to the nearest Gas Distributor, submitting the application form along with Proof of Identity and Address for new connection and then waiting for Agency to allot  you a new gas connection. On 31 Aug 2015  scheme, Sahaj, was launched enabling online release of new LPG connections. Portal www.mylpg.in will help customers register for new LPG connections online as well as make online payments for the same.

How to  get a new LPG Connection online?

Earlier, even currently at many places, getting a new LPG connection, for domestics use i.e 14.2 kg, means going to nearest distributor agency, filling up and submitting the application form and document proof and then waiting. Every family is eligible to get only LPG connection from any of the three suppliers i.e. Indane/ HP Gas/ Bharat Gas. One had no idea when will one get LPG connection. At times one was forced to even buy stove from the distributor.

Major LPG cylinder providers in India are:

  • Bharat Petroleum Corporation Limited (Bharat Gas)
  • Hindustan Petroleum Corporation Limited (HP Gas)
  • India Oil Corporation Limited (Indane) Who is eligible to get LPG connection

The new age consumer looks for a hassle free experience in all types of transactions. Keeping this in mind and in line with the continuing effort of Oil Marketing Companies to bring transparency in the supply and distribution of LPG the initiative was undertaken. This initiative would also eliminate multiple visits to the distributor’s showroom by the prospective consumers for completing formalities and problems arising out of them. It will also cut down on the time taken for release of connection. Consumers can now book a new connection online. It will be verified within 48 hours and a person from the nearest LPG agency will deliver a new connection at the door-step in next 3-4 daysSo it will take a week for one to get a new LPG connection. This is an additional step taken towards the vision of Digital India.

  • The scheme has been launched in 12 cities, including Chandigarh, Delhi, Ahmedabad, Bengaluru, Bhopal, Bhubaneshwar, Chennai, Hyderabad, Kolkata, Lucknow, Mumbai, Patna and Pune. Slowly it will expand to all of India
  • Under ‘Sahaj’, new LPG connections will be released online through www.mylpg.in
  • Customers can register for new LPG connections as well as make payments online

What are the advantages of getting a new LPG connection online?

The advantages of registering for a new LPG connection online is:

  • Better monitoring: Each stage in new connection release process can be electronically monitored resulting in reduction of lead time for release of new connection.
  • Choice to consumer: The consumer is empowered to select the type of connection i.e. single cylinder or double cylinder connection as well products like hotplate etc. on web as per their need eliminating the possibility of forced selling of these products by distributors.
  • Consumer Education: – While applying online for availing a new connection, the prospective consumer has to go through the conditions applicable for using LPG connection. This helps to educate the consumer.
  • Tracking & Intimations:-Tracking option and intimations by SMS and email are also available at various stages.
  • Cashless transactions: Consumers have the freedom to pay through their Credit/Debit cards, net banking through a robust payment gateway. Besides transparency, it allows customers to take immediate buying decision and also eliminates the possibility of overcharging.
  • No visits to Showroom of distributor / Home Delivery: This initiative provides immense flexibility by allowing the prospective consumer to register for new LPG connections online from the comfort of their home/office and pay online. There is no requirement for visiting distributor’s showroom saving on time and energy. Original Subscription Voucher (SV) along with the equipment requested by the customer is delivered to their home.
  • Online Inter-Company De-duplication: This facility is integrated with online inter-company de duplication check for multiple connection check before intimation of release of connection is sent to the prospective consumer. This helps in weeding out the possibility of release of multiple connections to the same household and avoids blocking of connection at a later date.

How to register for a new LPG Cylinder connection online?

One can now book a new connection online at :

  • Prospective Customer Registers for new connection by filling Online KYC Form & uploading POI & POA.
  • Enter Details like :
    • Personal Details like Name, Date of Birth, Father’s Name, Close relative name which can Spouse name or Mother’s name
    • Address Details with Proof of Address
    • Proof of Identity and Ration Card details if one has a ration card.
    • Subsidy : Give up Subsidy or Aadhaar or Bank Details for Cash Transfer. You can also enrol for Giving up the LPG subsidy while filling the form. Our article LPG Subsidy and Direct Benefit Transfer Scheme explains it in detail.
  • Submit the application along with Photograph and Proof of Identity and Proof of address.
  • On successful submission of your application, you will get a reference number. Please use the reference number to track the status of your application.
  • Once your application is approved , you will get an SMS and email to pay for the cylinders and regulator. It is said that your application will be verified within 48 hours and a person from the nearest LPG agency will deliver a new connection at the door-step in next 3-4 days. The documents will be verified physically.During physical verification of the documents at the time of delivery or during safety inspection of installation or verification of uploaded documents if any deviation is found, the distributor shall cancel the request for release of connection and the amount will be refunded to the prospective customer by distributor. No cancellation charges will be levied.
  • You can now pay the registration amount on-line through secure payment gateway using the following channels:
    • Net Banking
    • Credit Card
    • Debit Card
  •  One can buy additional products like Hot plate(gas stove) and Suraksha Hose while applying for new connection with online payment.

e-SV is the electronic subscription voucher which has the details of number of cylinders and pressure regulator loaned to the consumer against the security deposit. This document is emailed to the customer upon release of LPG connection online.

Details that need to be filled is shown in image below. This is from Bharat Gas online form. Click on image to expand.

Application Form for New LPG Connection

Application Form for New LPG Connection

Cancelling the request

Customer has an online provision to cancel his request for new connection. However after making the payment if cancellation is opted by the prospective customer, he / she shall have to contact distributor for getting the refund manually. No cancellation charges will be levied.

Tracking the New LPG Connection Application Status

One can track the application status of new LPG connection online through the following links

How to do refilling of LPG cylinder?

Related Articles:

It is a good initiative by the Government and Oil Marketing Companies and a convenience to ordinary citizen. How has been your experience of getting the LPG cylinder, how do you book your cylinder – phone, online or SMS, have you opted out of LPG subsidy? If you use getting the new LPG cylinder connection online then how was your experience.

24 Sep 05:21

Hedge Fund Manager Buys Drug, Hikes Price from $15 to $750. Available in India for Rs. 3!

by Deepak Shenoy

There’s a (former) hedge fund manager called Martin Shkreli. He runs Turing Pharmaceuticals which bought a drug called Daraprim, and instantly raised prices of the drug from $13.5 per tablet to $750. The drug is more than 50 years old (so no patent protection) and is used to treat toxoplasmosis, which affects people who have AIDS, or some forms of cancer, and babies too. The price increase will dramatically increase their cost of care.

This has caused a major outrage in the US, with Hillary Clinton going as far as to say she will “lay out a plan to take it on“.

Shkreli isn’t a particularly endearing personality, and went on TV shows to say that he needed the money to increase research on victims of toxoplasmosis, even though many doctors claim the drug works well as it is. And that he thinks it isn’t his fault that patient’s debt will have to rise after his price hike.… (Read On...)

24 Sep 05:20

Don’t Worry About Public Bond Market Illiquidity

by David Merkel
Photo Credit: Mike Beauregard || Frozen solid, right?

Photo Credit: Mike Beauregard || Frozen solid, right?

The talk regarding an illiquid public corporate bond market goes on, and if you’ve read me over the past year on this topic, you know that I don’t think it is a serious issue.  One of the reasons why it is not a big issue is that the public bond market is designed to be low liquidity.

It starts with how bonds are originally issued.  New bonds and new stocks are issued in similar ways, but with a few differences:

  • IPOs of stocks have a higher retail component.  Bonds, aside from muni bonds, are typically almost entirely institutional
  • IPOs are typically priced cheap, but with bonds the cheapness is smaller and more frequent.
  • Bond IPOs usually happen with companies that have issued other bonds before
  • Bond IPOs happen more frequently, except in a bear market
  • Bond IPOs typically happen more rapidly, minutes to a few days, except in a bear market

IPOs on Wall Street get allocated if they are oversubscribed.  When they are oversubscribed, the deal is typically good, and everyone wants more, so they put in huge orders.  The dealer desks on Wall Street solves this problem by allocating proportionate to the size that they have come to understand the managers in question typically buy and sell at, with some adjustment for account profitability.

Those that flip cheap bonds for a quick profit typically get penalized, and their allocations get reduced.  Those that buy bonds in the open market when the deal breaks and becomes “free to trade” can become eligible for larger allocations.  The dealer desks work in this way because they want the buyers to be long-term holders, and not seekers of easy profits from flipping.  That doesn’t mean you can never trade a bond you have bought — just not in the first month, subject to a few exceptions like a small allocation, your credit analyst rejected it, etc.  (Oh, and if one of those exceptions exists, the primary dealers want to do the secondary trade.  If the exceptions don’t exist, they don’t want to know about it.)

If flippers ever get big, despite the efforts of the dealer desks, they will price a deal very tight, and let the flippers take a big loss, with no one wanting to buy the excess bonds unless they are much, much cheaper.

The main effect of this is that once a deal is allocated, it is typically “well-placed,” with few secondary trades after the IPO.  This is even more pronounced with mortgage bonds, which aside from the AAA tranches, have very small tranche sizes, making them very illiquid.

In this environment, where yields have fallen over the past few years, it is difficult for financial companies that have bought bonds to replace the income if they sell the bond.  Thus, few bonds will be sold unless they are in the hands of buyers that don’t have a formal balance sheet, or, when credit quality is deteriorating badly.

Add in one more factor, and you can see why the market is so illiquid — the buy side of the market is more concentrated than in prior years, with big buyers like PIMCO, Blackrock, Metlife, Prudential, etc. being a larger portion of the market.  Concentrated markets with few holders tend to be less liquid.

All Good/Bad Things Must Come to an End

Some of these factors can be reversed, and others can be mitigated.

  • There’s no reason why the buy side has to stay concentrated.  Big institutions eventually break up because diseconomies of scale kick in.  Management teams typically do worse as companies get more complex.
  • Eventually interest rates will rise.  Once bonds are in a nearly neutral to negative capital gains positions, parties with balance sheets will trade bonds again.
  • Even mutual funds that own a lot of yieldy bonds can have a strategy for dealing with the illiquidity.  Yieldy bonds have excess yield relative to bonds of similar duration and credit quality, and are often less liquid because there is something odd about them that makes some portion of the market skeptical, which reduces liquidity.  A mutual fund holding a lot of less liquid bonds, can deal with illiquidity by selling opportunistically, selling more liquid bonds in the short-run, while discreetly inquiring on a few less liquid issues to see where real bids might be.  Remember, the amount of underperformance is likely to be limited, if any, so a run on a mutual fund is not likely, but in the unlikely case of a run, this can mitigate the effects.  Personally, I would not be concerned, so long as you keep your pricing marks conservative if cash outflows become a rule in the short-run.

In closing, don’t worry about illiquidity in the bond markets.  If there is a need for liquidity, the problem will solve itself as sellers lose a little bit in order to gain cash to make payments.  It’s that simple.

24 Sep 05:17

JPMorgan and Amtek Auto: who won who lost whom to blame

by subra
By now everybody knows that JP Morgan bought a lemon from Axis Bank. Name of the lemon was Amtek Auto. Well it does not matter. Name of the Fund: JP Morgan India Treasury Fund. What should a Treasury fund contain: Government bonds. (look up Wikipedia please). Who is to ensure that a Treasury fund should […]
24 Sep 05:15

William McKnight: The Basic Rule of Management that Propelled 3M

by Shane Parrish

William L. McKnight
In 1907 William L. McKnight joined Minnesota Mining and Manufacturing Co (3M) as an assistant bookkeeper. He rose quickly through the ranks and became president in 1929 and chairman of the board in 1949. His timeless management philosophy, laid out below, encouraged 3M management to “delegate responsibility and encourage men and women to exercise their initiative.”

The Basic Rule of Management

As our business grows, it becomes increasingly necessary to delegate responsibility and to encourage men and women to exercise their initiative. This requires considerable tolerance. Those men and women, to whom we delegate authority and responsibility, if they are good people, are going to want to do their jobs in their own way.

Mistakes will be made. But if a person is essentially right, the mistakes he or she makes are not as serious in the long run as the mistakes management will make if it undertakes to tell those in authority exactly how they must do their jobs.

Management that is destructively critical when mistakes are made kills initiative. And it’s essential that we have many people with initiative if we are to continue to grow.

***

Still curious? Pair with David Packard’s 11 Simple Rules For Getting Along With Others.

Source

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Sponsored By: Greenhaven Road Capital: You think differently - now invest differently.

24 Sep 05:15

10 Tips To Identifying Your Key Markets

by john.staples@salesbenchmarkindex.com (John Staples)

As we cover in this year’s workshop on How to Make Your Number in 2016, top performing CEOs organize their Corporate Strategies according to an eight-step plan.

Perhaps the most crucial step in this plan is the Markets phase.

Why is this phase so important? Because it sets company-wide goals for approaching the marketplace, selling products, and edging out competitors. With a clear understanding of which markets you’re going to tackle, your Corporate team can effectively allocate resources to make the most of each market’s opportunities.

Here’s what you need to know to accomplish the Markets phase.

24 Sep 05:14

Car-free days, traffic jams and social capital

by SK

While most news nowadays is fairly hilarious, one piece was more hilarious than the others. This was about traffic jams in Gurgaon yesterday, a day that had been declared as a “Car Free Day”.

You might wonder why there might be traffic jams on days that are supposedly “Car Free”. I don’t know the precise effect this can be classified under, but it’s somewhere in a linear combination of Prisoner’s Dilemma and Tragedy of the Commons and correlation, all led by a lack of social capital.

There are no rules that declare the day to be car free. It’s just a “request” by the local government (traffic police in this case). While there were some nominal efforts to improve public transport for the day, etc, there was nothing else that was different yesterday from other days. So why did it lead to a traffic jam?

If you know it’s a car free day and you have a car, you’ll assume that other people are going to leave their cars at home, and that you are going to have a free ride in free-flowing non-traffic if you take out your car. And so you take out your car. Unfortunately, the number of people who think such is enough to cause a traffic jam.

The problem stems with a lack of social capital in Indian cities (based on anecdotal experience (my own data point from 2008-09), I would posit it is lower in Gurgaon than in other Indian cities). As a consequence, when people are trying to make the “great optimisation”, they allocate a greater weight than necessary to their own interests, and consequently a lesser than necessary weight to others’ interests. And thus you end up with outcomes like yesterday’s. More generally, “requests” to people to give up a private benefit for others’ benefits can at best turn out to be counterproductive.

While designing policies, it’s important to be realistic and keep in mind ease of implementation. So if the reality is low social capital, any policy that requires voluntary giving up by people is only going to have a marginal impact.

Coming back to traffic, I’m increasingly convinced (I’ve held this conviction since 2006, and it has only grown stronger over time) that the only way to make people switch to public transport is to lead with supply – flood the streets with buses, which among other things actually increase the cost of private transport. Once there is sufficient density of buses, these buses can be given their own lanes which further pushes up the cost of driving. Then we can look at further measures such as prohibitive parking costs and congestion pricing.

We can have these notional “no car days” and “bus days” and “no honking days” but it is unlikely that any of them will have anything more than a token effect.

24 Sep 05:11

Two L&T Road Projects Default, But There’s No Recourse To The Company. Is This The Beginning?

by Deepak Shenoy

Two road projects that involve L&T have “defaulted” on payments, says ICRA.

L&T Halol Shamlaji Tollway Quasi-Default: Because Of Alternative Road in Gujarat!

The L&T-HSTL, which is a special purpose vehicle built to operate a tolled road between NH8 and SH5 (Vadodara to Halol) in Gujarat, and which has built a massive 173 km four laned highway between Halol and Shamlaji. The project spend 1305 cr. on building the road, and they haven’t been able to recover the money through tolls. (ICRA downgraded to D)

Since the beginning of tolling operations, the traffic volume witnessed in this stretch (in three of the four Toll Plazas) has been significantly lower than the initial estimates, due to presence of a significant alternate route, resulting in lower than anticipated cash accruals. The alternate route was substantially improved by GOG into a competing road subsequent to award of this bid leading to considerable diversion of traffic from the Project stretch.

(Read On...)
24 Sep 04:59

Why do we gloss over state capability deficiencies?

by noreply@blogger.com (Gulzar Natarajan)
Why do we consistently under-estimate state capability deficit and see technology and other innovations as the solution to public policy problems?

Consider three examples. One, using GIS to improve property tax collection. Two, technology interventions (GIS mapping, SCADA, smart meters and smart grids, etc) or financial engineering of state balance sheets to reduce distribution losses in their electricity distribution companies. Three, state-of-the-art regulation and processes to improve the effectiveness of regulatory institutions. All have been tried ad-infinitum not just in India, but across the world, with minimal success. 

It is not to say that these are not useful, but just that the underlying problems are fundamentally about weak state capability (at local government, public sector unit, and state/central government levels respectively above), and without atleast partially addressing them, the fixes suggested will hardly make a dent on the problem. In all these cases, policy makers over-estimate the contributions of technology interventions and process re-engineering in delivering the desired policy objectives. In fact, there are atleast six distinct biases that nudge us into an unqualified embrace of such interventions.

1. The desire for the tangible and conclusive. It has become part of the social internalization that everyone now views a policy intervention in terms of norms and components, clearly defined processes, time-lines, and a list of outcomes, all of which should form the basis for scaling up. Even when operational flexibility is afforded, the overall architecture is generally self-enclosed.

Unfortunately, most such policy interventions are transactional, requiring continuous engagement by officials at the cutting-edge with other human stakeholders. Such engagements, the quality of which is critical, cannot be prescriptive and decreed into implementation. They require capable and engaged individuals, who are sufficiently empowered (with resources and operational freedom), to discharge their responsibilities in an environment which allows them the freedom to do so.

Given that all these assumptions are questionable in the median case, the scaling-up challenge becomes simply humongous. We need less prescriptive and uniform approaches to dealing with the problem. But such approaches involve providing considerable program design and implementation autonomy with attendant delegation of responsibilities, which would make monitoring far more difficult (in fact, the current type of monitoring pretty much impossible) and outcomes less certain. In other words, this is an altogether different program design, implementation and monitoring paradigm. It would need greater tolerance for failures and turmoil and adoption of more dynamic program management approaches.

2. The partial equilibrium bias. In our problem solving moments, even when we are most logical, we rarely go beyond the first order problems. Accordingly, once we can do a GIS mapping of all the properties, the tax administration is reduced to a simple process of tagging and matching. This assumes that it is easier (than doing the same manually) to do GIS mapping and generate analytics, and then act on them to expand tax base and improve collection efficiency.

What if the implementation process of GIS mapping itself can be interminable (how many cities have completed even one iteration of city-wide GIS property mapping)? What if the process of constant updation of the GIS database can be a challenge (this assumes that the Town Planning guys have all the information available on the changes made to houses and new construction)? What if getting the tax collectors to act on the analytics may prove insurmountable (do we seriously believe that the bill collectors in their area or the Commissioner for the city as a whole already does not know about who are the big defaulters)? These, and many more, second and third order issues remain far from out thoughts when we support such interventions.

The neatness and simplicity of the partial equilibrium of the interventions, and the false sense of comfort that it provides, blinds us to the general equilibrium dynamics that are invariably generated and should necessarily be overcome for any such intervention to succeed.

3. Convenience bias. All of us are primed towards embracing something that appeals as neat and simple, and one which increases our convenience. For sure, GIS mapping and regulatory reforms appear very neat and simple, and are better than the existing systems to tackle the problem being addressed. It has always been the case that we demand "more and better, even when less is enough".

4. Optimism bias. It is always the danger that project teams under-estimate the magnitude of the task entrusted and see the road ahead with more optimism than it should merit. Accordingly, officials who champion a technology or process intervention are instinctively likely to under-estimate the problems and over-estimate their chances of success. 

5. Doing-something-new (or innovation) bias. When something is persistently wrong or a failure, we tend to over-react and assume that the existing design and processes have failed and we need to adopt something new. We have deeply internalized that failures are due to lack of innovation with design, process, and technology. Very rarely do we step-back to see whether the original design and processes themselves were rigorously implemented or not. It is very comforting to rationalize away failures by blaming it on the design and other extraneous factors, rather than questioning our implementation capability.

6. Best-practice bias. Occasionally, amidst the gloom surrounding the implementation canvas, we see bright-spots and embrace them as best-practice models to be transplanted across the world. Accordingly, the best-practice regulatory architecture is transplanted into a system which neither has the resources nor the pre-requisite environmental conditions for the effective implementation of the best-practice model. Little do we try to examine whether the bright spot was due to the extraordinary personal initiative of a committed individual or group of individuals or due to some systemically built (and therefore replicable) capacity. 

7. Finally, the illusion of control bias. No policy maker or political leader wants to face up to the reality that their primary implementation instrument, the bureaucracy, in its present condition, is just not capable enough to implement the proposed intervention, leave aside achieve the desired outcomes. Once this assumption is shaken, it can be a very unsettling process for bureaucrats and politicians to craft a policy intervention and its implementation plan. In fact, unlike earlier, when you only had to design a policy intervention (a best-practice model), now you have to also craft an implementation plan. Worse-still, you need to tailor the policy intervention, conditional on your implementation capability. Apart from being personally unsettling, the challenge associated is, in any case, now far more complex than before.

It is more likely that all of them bind in varying degrees nudging policy makers and political leaders to under-estimate state capability problems.
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24 Sep 04:51

Why Italy could not build a coffee chain like Starbucks (despite being much better at making Coffee) ?

by Amol Agrawal
An interesting conversation between Profs. Luigi Zingales and Tyler Cowen on series of issues. Zingales wonders why Italy could not build a chain of coffee shops despite being great at making coffee: COWEN: ….One of my favorite papers by you isyour paper with Bruno Pellegrino. It’s a great name for coauthoring a paper on Italy. […]
23 Sep 10:23

Latticework of Mental Models: Pavlovian Conditioning

by Anshul Khare

Last month I decided to pay a visit to my friend Dr. Placebo in his clinic. It was a Friday and for some strange reason people are too happy to fall sick on a Friday. So it was a relatively less busy day for my doctor friend. For that matter it should be easy for you to guess the busiest day of the week for him – Monday of course. :)

I wasn’t sick as such but I like to catch up with Dr. Placebo once in awhile. In the past he has helped me in thinking about important mental models including Do Something Bias [1] and Mean Reversion [2]. So I was hoping that a chit chat with him will again nudge me to some fresh insights. I wasn’t wrong.

“So doc! Tell me something ironical about your profession?”, I asked him thinking that a question like that could lead the conversation to an interesting direction.

“The biggest irony of being a physician is that many people don’t really need doctor’s help. Many a times, my prescription is effective because people believe in them. Their belief in my treatment is what cures them. You see your doctor and you feel better.”

He continued, “Sometimes just the fact that a doctor or nurse is paying attention to us and reassuring us not only makes us feel better but also triggers our internal healing processes. In many cases they would benefit just by popping a sugar pill. And it’s a proven fact also known as Placebo Effect.

“I see. That kind of explains your strange name.”, I winked thinking that he wouldn’t mind a friendly tease.

“Don’t get me started on the origins of my name. But you should read about Pavlovian Conditioning. Now if you please excuse me, I have to leave now. It’s Friday and I have plans.”, saying this he got up from his chair and started leaving.

I think I had offended him by joking about his name. Moreover he had already given me more time than what he usually gives to his fee paying patients. So this free rider had to leave.

But the visit had good payoff for me because it led to me to discover the next topic for Latticework series – Pavlovian Conditioning which is sometimes referred to as classical conditioning.

If you have been following Safal Niveshak for sometime, I can safely bet that you know who Charlie Munger is. For the uninitiated ones, he is the vice chairman of Berkshire Hathaway and Buffett’s best buddy. He’s known for his multidisciplinary thinking and considered to possess the smartest brain. And he is 91 years old.

Based on my readings about Charlie Munger, I can say that one of his favorite mental model from psychology is Pavlovian Conditioning. It’s one of those topics which has appeared multiple times in many of Charlie’s speeches.

So what is Pavlovian Conditioning? It’s a behavioural trait which was first discovered by a Russian scientist named Ian Pavlov. In Seeking Wisdom [3], Peter Bevelin describes Pavlov’s experiment –

The Russian scientist Ivan Pavlov studied the digestive system of dogs when he observed that a stimulus unrelated to food made the dogs salivate. In one experiment he rang a bell just before giving food to the dog. He repeated this several times until the dog salivated at the sound of the bell alone. No sight or smell of food was present. The sound of the bell produced the same response as the food. The dog learned to associate the bell with food.

I realize that I’m not much different from Pavlov’s dog. Everytime I order a pizza, I start drooling when the doorbell rings. I wonder if it’s Pavlov standing on the other side of the door holding a bell and a notebook instead of hot pizza.

The conditioning works to trigger negative emotions also like fear. Bevelin adds –

Experiments have shown that we can learn to fear a harmless stimulus if it is paired with an unpleasant one. If for example rats consistently receive mild electrical shock after hearing a tone, the rats learn to develop a fear of the tone alone.

A Manipulation Tool

In his seminal work, Influence [4], Robert Cialdini talks about his friend who was having trouble selling a certain kind of turquoise jewellery. In spite of trying all sales tricks and marketing gimmicks she couldn’t move the sales. One fine day her staff, by mistake, changed the price tags for those turquoise pieces to double the original price. To their surprise, because of this increased price, the stock was sold out in a day.

How do you explain this strange behaviour from her customers? Well, Pavlov just told us.

The customers, with little knowledge of turquoise, were conditioned to associate high price with high value. These were the people who had been brought up on the rule “You get what you pay for”. Their conditioning led them to mistake the high price (bell) for quality (food) and they swooped down(salivated).

There is one place in the world where Pavlov is secretly revered like a god. Can you guess?

Well I can’t offer any supporting facts but I can say with reasonable confidence that the answer is Las Vegas or for that matter every casino in the world. Casino operators probably use almost every kind of behavioural trick to keep the gamblers longer inside the casino because they know that the longer the game continues, the larger the bets. Large rooms, noisy and flashy machines, sounds of spilling coins, hubbubs of crowds, and entertaining music, along with the smells of free food, drinks and perfume, provide the essential Pavlovian vibes to encourage gamblers to stay with their games for as long as possible.

The slot machines in the casinos exploit yet another behavioural bias called Variable Reinforcement [5], which is another form of conditioning, also known as Operant Conditioning(OC). In Pavlovian conditioning the response(salivation) is involuntary whereas in OC it’s a conscious decision on the part of subject. Like a rat falsely associating a lever press with supply of food and keeps pressing the lever endlessly.

In Business

In 1996 Charlie Munger delivered a talk titled Practical Thought on Practical Thought [6]. In this talk he used the example of Coca-Cola’s business model and explained how Pavlovian association lies at the heart of coke’s strategy. Charlie explains –

The neural system of Pavlov’s dog causes it to salivate at the bell it can’t eat. And the brain of man yearns for the type of beverage held by the pretty woman he can’t have.

…we must use every sort of decent, honorable Pavlovian conditioning we can think of. For as long as we are in business, our beverage and its promotion must be associated in consumer minds with all other things consumers like or admire.

For decades, Coke’s strategy has been to create a strong association between it’s drink and ‘happiness’ in the consumer’s mind [7].


And it’s not just Coke but a large part of modern advertising industry has relied on Pavlovian Conditioning.

There is another interesting manifestation of this bias in the world of business, also known as “Persian Messenger Syndrome”. Here is an excerpt from Charlie’s talk on The Psychology Of Human Misjudgement [8]

Some of the most important miscalculations come from what is accidentally associated with one’s past success, or one’s liking and loving, or one’s disliking and hating, which includes a natural hatred for bad news…Ancient Persians actually killed some messengers whose sole fault was that the brought home truthful bad news, say, of a battle lost… [this tendency] is alive and well in modern life, albeit in less lethal versions. It is actually dangerous in many careers to be a carrier of unwelcome news.

Charlie uses the example of CBS(as warning) and explains how this problem is tackled in Berkshire –

Chairman Paley (at CBS) was hostile to people who brought him bad news. The result was that Paley lived in a cocoon of unreality, from which he made one bad deal after another, even exchanging a large share of CBS for a company that had to be liquidated shortly thereafter….At Berkshire, there is a common injunction: Always tell the bad news promptly. It is only the good news that can wait. It also helps to be so wise and informed that people fear not telling you bad news because you are so likely to get it elsewhere.

Charlie Munger has his own nomenclature for most of these biases including Pavlovian Conditioning which he calls Influence by Mere Association.

In Investing

One of the ways Pavlovian Conditioning shows its effect in investing is when investors start associating indexes to be the true and accurate representation of the whole economy. Remember the indexes don’t necessarily reflect the whole world of stocks. It’s just a collection of few companies based on their market capitalization.

When the Sensex/Nifty falls (akin to Pavlov ringing the bell), it triggers a conditioned response (panic or fear akin to salivation) in investors and without even investigating the business fundamentals of the stocks in their portfolio they start selling.

Another interesting implication of classical conditioning is a tendency to classify businesses as stereotypes. In his recent lecture in Google [9], Professor Sanjay Bakshi explained how hostile stereotyping by Mr. Market can have wonderful consequences for the value investor.

Exploiting Pavlovian Conditioning

So far our discussion has hovered around unintended and mostly undesired outcomes of pavlovian conditioning. In the spirit of inversion [10] let’s see if we can exploit this behavioural quirk for our benefit.

Awareness about classical conditioning can be very useful for creating good habits or breaking bad habits. Once you can identify the cue which triggers the associated conditioned response you can easily break the routine and replace the bad habit with a good one. Charles Duhigg, author of Power of Habits [11], explains this idea brilliantly in this video [12].

Conclusion

I suspect that towards the end of his research, Mr. Pavlov was probably getting manipulated by his dogs. My suspicion was later confirmed by this image which I found on the internet.

pavlovs-dog

Just kidding!

The world around us is changing pretty fast and the modern computers are becoming cheaper, faster and more intelligent than ever which means they are ready to replace a large part of human workforce.

The day is not far where our work and skills will be threatened by an artificial intelligence. So to stay relevant, we need to make sure that we remain valuable to the society in a way which can’t be substituted by a robot. And there is just one way to do that – become a learning machine.

My friend Jana Vembunarayanan recently delivered a thoughtful lecture to young university students in Chennai [13]. The lecture made me realize the urgency of task i.e., acquisition of worldly wisdom. Charlie Munger has been saying the same thing for years –

I constantly see people rise in life who are not the smartest, sometimes not even the most diligent, but they are learning machines. They go to bed every night a little wiser than they were when they got up and boy does that help, particularly when you have a long run ahead of you.

Of course the best way to start the process of lifelong learning is to master the fundamentals. The big ideas from the major disciplines. The cognitive framework that you build using these big ideas is what Charlie Munger has dubbed as Latticework of Mental Models.

Nobel Laureate Herb Simon writes –

The better decision maker has at his/her disposal repertoires of possible actions; checklists of things to think about before he acts; and he has mechanisms in his mind to evoke these, and bring these to his conscious attention when the situations for decision arise.

By sharing my learnings through this Latticework series, I have embarked on a journey to accelerate my own learning process. I sincerely hope that in my quest to seek worldly wisdom the reader also benefits.

Take care and keep learning.

The post Latticework of Mental Models: Pavlovian Conditioning appeared first on Safal Niveshak.

    
23 Sep 05:36

Simple Financial Advice

by subra
Many a times people ask me for a ‘one pager on financial advice’ that one can give to a 23 year old. So here it is: Success in life comes from investing. So first invest in a good education. There is nothing to beat a good education – a good institute, a good library, some […]
23 Sep 05:25

On Slack: Amtek Auto Group, NPAs, Bank Holiday without Pay, Fed Rates and more…

by Gautam Jagannathan

CapM Premium Header

The Slack Discussions

The Slack group at Capital Mind Premium has been extremely active and if you haven’t been there, pop us a note by replying to this email. (If you’re a trial member this probably sound like Greek to you; it will be available when you sign up!)

A brief summary of some of the interesting things discussed there in the last few days:

#macronomics: Saudi sees no need for oil summit, best leave market alone

Top oil exporter Saudi Arabia sees no need to hold a summit of producing countries’ heads of state if such discussions would fail to produce concrete action toward defending oil prices, sources familiar with the matter said on Thursday.

http://www.reuters.com/article/2015/09/10/us-opec-oil-idUSKCN0RA26620150910

http://www.bloombergview.com/articles/2015-09-11/saudis-are-winning-the-war-on-shale

#options: The Case for Put Writing / Further Improving Put Write Performance

Jesse Livermore of the always interesting Philosophical Economics outlines the case for writing puts in his recent post The World’s Best Investment for the Next 12 Months.… (Read On...)

23 Sep 05:06

Amtek Auto Defaults on 800 cr. bonds. A View On The Tricky Recovery Process.

by Deepak Shenoy

And the expected has happened: Amtek Auto has defaulted on its 800 cr. of bonds that were due on Sunday. They had till end of day yesterday to pay up, and they didn’t make that payment.

For a bank holding the bonds this account is technically not an NPA until 90 days is over. So they can extend and pretend and hope that Amtek manages to salvage itself. Since the banking system has exposure to more than 7,000 cr. of loans to Amtek, you can bet your next salary that they will restructure the loan in some way and manage to not call it an NPA at all. Meaning, they’ll give it more money and “defer” repayment for a year or two, and hope that this will revive Amtek.

For a mutual fund like JP Morgan AMC that holds the bonds, this is a default that means they don’t get paid right now.… (Read On...)

23 Sep 04:58

Warning: December 2015 F&O Contracts Will Need To Be A Multiple Of 75, You Have Three Days To Act

by Deepak Shenoy

Lot sizes for Futures and Options contracts starting November are increasing, and the Nifty will go to a lot size of 75.

What happens, then, if you had bought LEAPS (Long Term Options) of December 2015? These have a current lot size of 50.

September contracts expire on September 24 (Thursday). Come September 25 (which is a holiday, so it is actually Sep 28), and you will have new contracts for December 2015. (Currently today contracts are Sep, Oct and Nov. On Sep 28, the Sep contracts would have expired, so they will have the three months of Oct, Nov (both already there) and Dec)

When the December contracts come into place they will have a contract size of 75.

If you own 50 shares of Nifty (December 2015) you have three days to increase it to a contract size that is exactly divisible by 75, otherwise you won’t be able to sell your shares!… (Read On...)

23 Sep 04:58

A China PSU About To Default?

by Deepak Shenoy

The equivalent of a Public Sector Unit (PSU) in India is a State Owned Enterprise (SOE) in China. And one of them, apparently, is about to default.

A unit of one of the elite club of 112 big enterprises directly owned by the central government, China National Erzhong Group employed a workforce of more than 13,000 in 2012, when it had assets of Rmb25bn. But a slowing economy saddled with industry overcapacity has hobbled the heavy industry group, leading to losses of Rmb8.4bn in 2014.

“Under the influence of the macroeconomic environment, the demand for the company’s main products remains depressed, and our industry is suffering from severe overcapacity, making competition unusually fierce and causing the price of our products to slide lower,” Erzhong said in a filing late on Monday.

The company suspended trading of Rmb1bn in five-year notes sold in 2012, citing “uncertainty” about whether it could meet a Rmb56.5m ($8.9m) interest payment due next week.

(Read On...)
23 Sep 04:26

Regulatory governance problems in the legislative function at RBI and SEBI

by Ajay Shah
by Arpita Pattanaik and Anjali Sharma.

The problem


Regulations which are issued by regulators, have the full status of law. A person who violates a regulation stands to be punished exactly like a person who violates a law. But regulations are written by unelected officials. Ordinarily, in liberal democracy, the power to make law is restricted to those who have won elections. How do we reconcile this contradiction? The answer adopted, the world over, is to establish a sound regulation-making process, through which unelected officials do not have arbitrary law-making power.

Under sound public administration, when unelected officials wish to draft regulations, they should articulate reasons. All regulatory actions result in both costs and benefits for regulated entities and the market. In a good system, only those interventions, for which the benefits exceed the costs, are implemented. This requires regulators' to carry out a formal cost-benefit analysis and engage with the public through a consultation process.

Such transparency in the regulation making process has many benefits. It anchors the financial system by providing legal certainty. It creates transparency and predictability about the values and goals of financial policy and regulation making, and accountability in regulatory actions. As an outcome, market participants are able to conduct their business with confidence. Das et. al. (2004) find that balanced degrees of transparency, accountability, integrity and independence of the regulator, result in a sound and improved financial system.

In the Indian landscape, financial sector regulators have been endowed with a surprising mix of powers by the Parliament. They can make laws, enforce them and punish regulated entities that violate these laws. Often regulatory actions enjoy protection from judicial review as they are deemed to be "actions taken in good faith". However, the regulation making process followed by financial sector regulators in India is nowhere close to these standards. Regulations are issued as unilateral pronouncements. Little or no detail is provided about the problem being solved or the reason for the regulatory action. Often, there is a real risk of a ban on products (example), a ban on participants (example), retroactive changes in tax policy (example), changes in margins (example), position limits (example 1, example 2) and trading lots (example) and changes in investment norms (example) being introduced without any warning or rationale.

These maladies are part of the problems faced in doing business in India. The Report of the Standing Council on International Competitiveness of the Indian Financial Sector finds that mistakes in financial regulation and regulatory uncertainty are important factors that hamper financial market development across market segments in India. In contrast, jurisdictions that are or seek to be centers for international finance, follow robust regulatory governance practices and ensure regulatory certainty.

Improving regulatory governance


A recent development towards obtaining better regulatory governance in the Indian financial sector is in the report of the Financial Sector Legislative Reforms Commission (FSLRC), headed by Justice Shri B. N. Srikrishna. The FSLRC has proposed the Indian Financial Code (IFC), a consolidated draft law for the financial sector. Non-legislative elements of the draft Code have been culled out into the Handbook on adoption of governance enhancing and non-legislative elements of the draft IFC (Handbook). The Handbook lays down international best practices on regulatory governance and lists the procedures that the Indian regulators should follow to achieve better governance in regulation making.

As part of the Financial Sector Development Council (FSDC) Resolution dated October 24, 2013, all financial sector regulators agreed to comply with the Handbook procedures on framing regulations for :
  • All regulations from 31st October, 2013, and
  • All subordinate legislation -- which includes circulars, notices, guidelines, letters -- from 31st December 2014.
In this article, we examine whether the regulation making procedures followed by RBI and SEBI comply with the standards defined in the Handbook.

Handbook procedure for "Regulation Framing"


The Handbook lays out the following procedure for regulation making:

  1. All regulation making should start with a proposal to the Board of the regulator. The Board must assess the necessity of the proposed regulation and initiate the process.
  2. The draft regulation must be accompanied by a jurisdiction clause, defining the legal provision under which the regulation is being proposed, a statement of objectives, the problem it seeks to solve and a cost benefit analysis of the proposed solution.
  3. The draft regulation must be made available to the public, inviting comments for a reasonable period of time. This can be done by publishing the draft regulation on the regulator's website.
  4. All comments should be published on the regulator's website.
  5. The Board of the regulator should take into account all reasonable comments received when approving the regulation.
  6. Once the Board approves, the regulation will become effective from the date of its notification.

Of the six steps in this list, numbers three to five are observable publicly. Information about Step 3 is available when the regulator places the draft regulation on its website for public comments. Information about Step 4 is available when public comments are published on the website, while information about Step 5 is available when the final regulation is notified or published on the website. From these, three things can be assessed:

  1. Whether a public consultation preceded regulation making,
  2. Whether the public consultation document had all the elements recommended by the Handbook, and,
  3. Whether the public consultation process caused any change in the final regulation.

We collected information for the three steps described above from the RBI and the SEBI website for the period June, 2014 to July 2015 to understand their respective compliance track record.

Regulatory instruments used by SEBI and RBI


An analysis of the collected information reveals the following facts.

  • SEBI uses several instruments for regulation making: regulations, circulars, general orders, rules and guidelines. However, regulations and circulars are the most frequently used.
    1. Regulations are issued under Section 30 of SEBI Act. Regulations need the approval of the SEBI Board. They are then placed before Parliament for sanction and subsequently notified in the Gazette. 27 regulations were issued during the analysis period.
    2. Circulars are issued under Section 11(1) of the SEBI Act. This Section allows SEBI broad powers to act in the interests of investors, promote market development and regulate securities' markets. Circulars do not need to be placed before Parliament and only require approval within SEBI. 23 circulars were issued during the analysis period.
    3. General orders, rules and guidelines are less used instruments. Only 1 guideline and 1 rule was issued in the analysis period. No general order was issued in this period.
  • RBI uses atleast three legal instruments for regulation-making: "circulars", "notifications" and "directions". The present state of transparency about law written by RBI makes it hard to analyse the laws written by RBI: citizens do not get access to a comprehensive statement of the law. In this article, we study some circulars. These are used for regulation making under a wide range of legal provisions: the Banking Regulation Act, 1949, the RBI Act, 1934, the Foreign Exchange Management Act, 1999, the Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002, the Prevention of Money laundering Act, 2002 and the Payment and Settlement Systems Act, 2007.

    Each year in July, the RBI issues master circulars which are compilations of all circulars in force for a particular area. During the selected period, we were able to identify 643 circulars and 221 master circulars. With the present state of transparency at RBI, we do not know whether this collection is exhaustive. For the present purposes, we treat this as a reasonable sample where we can study the attributes of the regulation-making process at RBI.

We focus our analysis on SEBI regulations and circulars and RBI circulars.

Compliance record on regulation making


The table below shows how well RBI and SEBI complied with the Handbook procedure for regulation framing in the one year period of analysis using two sets of two measures. The first measure captures in how many instances regulation was preceded by public consultation? The second measures capture the procedure followed for the public consultation. This includes understanding: (a) how many days were allowed for public comments, (b) whether public comments were published on the website, (c) whether the public consultation document had a cost-benefit analysis, and (d) what was the time lag between public consultation to the final regulation?

Table 1: Compliance summary

RBI SEBI


Circulars Regulations Circulars



Total issued 643 27 23
Public consultation done 21 12 4
Cost-benefit analysis done 0 1 0
Public comments published 0 0 0




Table 2: Time lags in regulation framing

Time taken (in days)

Consultation period allowed Consultation to regulation lag


Minimum Maximum Median Minimum Maximum Median






RBI Circulars 7 46 29 24 2,232 1,171
SEBI Regulations 10 43 23 55 1,709 331
SEBI Circulars 12 28 18 11 740 609



This data offers fascinating insights into the problems of regulation making in Indian finance:

  1. The regulatory track record of seeking public comments is poor. Public comments were sought only on 2.4% of RBI's circulars. SEBI sought public comments on 44.4% of its regulations and on 17.4% of its circulars.
  2. When they do seek public comments, there are gaps in the contents of the consultation document. RBI public consultation documents did not lay out the objective of the proposed regulation, the problem being addressed, the jurisdiction clause or the cost benefit analysis. These documents only proposed one solution. SEBI public consultation documents did present the objective of the regulation, the problem being addressed, a proposed solution and the jurisdiction clause. However, the cost benefit analysis was missing in all cases except one. The SEBI public consultation documents often carried sweeping statements of motivation such as in the interest of investors and to promote market development.
  3. Neither regulator allowed adequate time for receiving public comments. The median time allowed for public comments by RBI was 29 days and by SEBI was 23 days for regulations and 18 days for circulars. In the case of both regulators, there were cases where only 10 or 12 days were allowed.
  4. At both at RBI and SEBI, the time lag between the public consultation and the issue of final regulation is high. For RBI circulars the median lag is 3.2 years while for SEBI regulations and circulars it is 0.9 years and 1.7 years respectively. The relevance of the public comments or the regulatory intervention itself may be lost or altered if significant time elapses from the point of problem definition to implementation.

As part of our analysis, we also checked whether public comments had resulted in any changes in the proposed regulation. We do not find any case where there was a change in the final regulations in response to public comments.


More than eighteen months have elapsed since the FSDC resolution. RBI's compliance track record suggests an almost complete disregard for spirit of the resolution. Regulations continue to be issued unilaterally, without following the Handbook procedure. SEBI appears to be doing better, but it has a long way to go before its processes become state of the art.

An example of good regulatory governance in India: rule making at Airport Economic Regulatory Authority


The Ministry of Finance prides itself on having some of the best governance capabilities in India. However, better regulatory governance procedures are now found in some agencies outside the Ministry of Finance. As an example, consider the rule making process at the Airport Economic Regulatory Authority (AERA).

AERA, established in 2008, has been following a regulation making process that displays a level of transparency and organisation rarely seen in Indian financial sector regulators.

  • All orders issued by AERA are preceded by a two stage stakeholder process.
  • In the first stage a consultation paper is placed on the AERA's website seeking feedback, comments and suggestions. All feedback received, along with the names of parties giving the feedback and their detailed submission, is published on the regulator's website.
  • In the second stage, a consultation meeting is held, where stakeholders present and discuss their concerns and suggestions. The minutes of this meeting are also published on AERA's website.
  • If any subsequent communication takes place between AERA and any stakeholders, such as additional clarifications sought, these too are published on the website.
  • Only after the stakeholder process is completed, AERA issues the final order.

Further, the regulator's website transparently displays the list of consultation papers issued, the time given for public comments, the status of the stakeholder process and the status of the final order. The uniqueness of the AERA process is in the level of transparency and documentation that it provides. The entire process is available publicly, even those suggestions and comments that are contrary to the regulator's proposal. The volume of comments and level of detail contained in them, shows that the market participants are engaged in the regulatory process.

International best practices in regulation making


Financial sector regulators in jurisdictions such as the U.S. and Singapore define the standards of best practice in regulatory governance:

  • Monetary Authority of Singapore (MAS): For all proposed changes in regulations, a consultation paper is placed on the MAS website for public comments. The consultation document includes: (1) The rationale for the proposed regulation and the objectives of the measures being proposed, (2) A standard template for providing feedback, which allows respondents to indicate if they would like parts of their response to be kept confidential, and (3) The proposed regulation. A minimum of 30 days are allowed for public comments. After closure of the consultation process, MAS aggregates all public comments and responds to them. This document, published on MAS website, also indicates where MAS has agreed to change the proposed regulation based on public feedback or agreed to review it at a later date.

  • The U.S. Securities and Exchange Commission (SEC): The SEC rule making process starts with a public notice regarding its intent to consider regulatory proposals. This is followed by the release of the draft rules for public consultation. The proposed rule is accompanied by supplementary information which includes the rationale, the impact of the changes being proposed, an economic analysis and a compliance schedule. A minimum of 30 days are allowed for public comments, though, in most cases the period ranges from 60 to 75 days. All public comments and details of meetings held with SEC officials regarding the proposal are made available on the SEC website. The approval order for the proposed rule also shows SEC's consideration of the comments received, and an explanation, in plain and clear language, of what the rules would do.

Conclusion


There is a lot of interest in `good governance' that will `reduce the cost of doing business' in India. Where the rubber hits the road, in Indian finance, is the arbitrary power that is exercised by persons in financial agencies.

Good governance standards are critical to ensure confident participation in financial markets. When such standards are applied to the regulation making process, there is an overall increase in clarity and transparency. Participants become informed about the motivation and thinking at the regulatory agencies and also become prepared for the changes to come.

The process of seeking public comments engages the regulated entities, and the public at large in the regulatory process. It gives them a channel through which they can influence regulation framing. Publishing comments on regulators' website creates two way communication. It informs market participants whether their feedback is taken into account by regulators. Over time, if participant find that their comments are not considered, the volume of comments will decline. All these, over time, improve the effectiveness of the regulation making mechanisms. They place checks on the discretionary power in the hands of regulatory staff. They reduce regulatory mistakes, that may arise either through ignorance or corruption.

In adhering to good governance practices, the regulators also have an additional incentive to lead by example. Their adoption of such good governance standards improves their legitimacy when they seek similar compliance from their regulated entities.

In India, the lack of such regulatory governance practices is cited by both domestic and foreign participants as a reason for not increasing their use of the Indian financial system. The FSDC resolution was a first step where the regulators agreed, in principle, to adhere to good governance practices in regulation making. However, their actions over the last eighteen months belie their intent. In comparison to home grown entities like AERA, as well as in comparison to the Handbook and the international best practices for regulatory governance, both the RBI and SEBI fall short. Regulatory reform and capacity take time to develop and get fully entrenched, specially in an emerging economy such as ours. When both these regulators have fully built the capacity and systems to comply with sound procedures of regulatory governance, this will strengthen confidence and participation in the Indian financial system.


23 Sep 04:15

The trade-offs between networks and mega-cities

by noreply@blogger.com (Gulzar Natarajan)
Edward Glaeser and Co have a new paper which examines the trade-off between mega-cities (densified cities) and network of smaller cities linked together (by, say transportation and other networks) that enable exchange of goods, people, and ideas. In particular, they examine whether it is good public policy to pursue merging cities to form mega-cities (densification) or form large networks of smaller cities (consolidation)? The paper examines the trade-offs that happen at three levels - returns to scale in ideas creation, connection between urban size and amenities, and elasticities of housing supply - and which may vary across time horizons (short vs long-term), stage of economic development etc. It finds,
Even if there are global increasing returns, the returns to local scale in innovation may be decreasing, and that makes networks more appealing than mega-cities. Inelastic housing supply makes it harder to supply more space in dense confines, which perhaps explains why networks are more popular in regulated Europe than in the American Sunbelt. Larger cities can dominate networks because of amenities, as long as the benefits of scale overwhelm the downsides of density. In our framework, the skilled are more likely to prefer mega-cities than the less skilled, and the long-run benefits of either mega-cities or networks may be quite different from the short-run benefits.
In the authors view, mega-cities score over networks in terms of amenity spill-overs, idea creation (skilled workers prefer densified environments), mobility of less-skilled workers across employers, new enterprises prefer larger markets etc. However, networks have advantages of having more land (eg. the space between network nodes) and more elastic housing supply.  

It will be interesting to empirically validate the model in the context of urban development in India. But till then, a few observations

1. It is arguable that more than anything else, supply of affordable housing and large enough public transportation networks are central to the growth prospects of any large metropolitan area. 

2. The mega-cities in India are clearly facing a crisis in affordable housing. In the absence of policies that promote vertical development and greater densification, supplemented with investments to improve carrying capacity, cities like Mumbai may be better off pursuing a model involving network of one large core connected to smaller nodes with excellent transportation lines. 

But the risk with this is that the larger node generally gentrifies, displacing all but the richest and highest-level government employees to live in the nodes and commute for work. Even for those working in the ideas creating enterprises, housing may have become unaffordable for the vast majority of employees, enough to possibly offset the benefits from densification. Without massive investments in good public transit networks with large carrying capacity, this trend can potentially stifle the economic prospects of such regions. 

Of course, one could say that markets would respond by moving out some of the economic activities, especially those requiring larger land and more workers, out from the city center to the suburbs. And it surely is happening. But the value of land, even in the nodes of the largest cities may have become prohibitive enough to more than off-set the possible gains from relocation. Therefore, in any case, the current urban planning models may require radical makeover. 

3. In this context, the examples of Paris and Tokyo are instructive. Paris has a small and less dense central core, with the major part of the population located in the banlieue, whereas Tokyo has a very dense core, surrounded by a massive metropolitan area, extending finger-like around the core in all directions with high-density nodes along them. In both cases, the nodes are connected to the core area through excellent public transportation networks that mitigate the typical problems of daily commutes. 

In contrast, the largest Indian (and many developing country) cities, have a much larger core and with much higher density than these cities. But given the sheer size of the populations involved and the attraction of economic opportunities in these cities, the suburbs of these cities are rapidly becoming as big as the core itself and with increasing density. Further, these suburbs are emerging more as a continuum to the city and not so much as distinct nodes.  

4. A 2014 report by the MGI identified 49 metropolitan growth clusters covering 183 districts across India. It estimates that these clusters would contribute 77% of India's incremental GDP, 72% of consuming-class households, and 73% of its incremental income pool in the 2012-25 period. In terms of economic growth policy making, states should prioritize the long-term development of these areas, with the Government of India stepping in wherever they overlap across states. In terms of the long-term future of the state itself, leadership and policies in these clusters assume far greater significance than the remaining parts of the state. 

Outside of the largest metros, the vast majority of these clusters are still a constellation of nodes around a larger (but not mega) city. The potential here are immense. It is still possible to carefully guide the development of these areas through progressive and far-sighted urban planning policies. Strict enforcement of master plans, with limited tolerance for land-use conversions (especially in the smaller nodes), and policies to promotes densification (higher FAR etc) are non-negotiable imperatives. This should be supported with investments in public transportation systems that link the nodes. These systems could be financed through innovative value capture and land monetization strategies. 
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23 Sep 04:09

Three Truths for Finance..(and three lies of Harvard)

by Amol Agrawal
Mark Carney of BoE has a speech on the topic. He starts with three lies related to Harvard Univ: In Harvard Yard sits a statue of John Harvard, seated on a bronze throne, commemorating 1638, the year of the university’s founding.  Tour-guides relish in pointing out that, in fact: No-one knows what John Harvard looked like, […]
22 Sep 09:51

Nandan Denim Will Issue Warrants At Rs. 200 to an FII Fund When Its Current Price is 130

by Deepak Shenoy

Nandan Denim Limited will issue warrants worth Rs. 50 cr. to Polus Global Fund, which will have to convert it at Rs. 200 per share. This is a “warrant” for which Polus will pay Rs. 12.5 cr – or 25% – upfront. They pay the remaining on conversion anytime within 18 months. The stock shot up 12% in trade today to reverse a short term downtrend it was seeing. Note: This was a Capital Mind Premium portfolio stock (we were in at 108, out at 140 in our momentum portfolio)

image

The fund owns stakes in a couple of Zee companies, Radico Khaitan, Mandhana and ABG. (The press release also mentions Omaxe, Era infra, Gujarat Apollo, Tata Global and IDFC too)

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22 Sep 09:48

Indian Economy - The way forward?

by noreply@blogger.com (Gulzar Natarajan)
As the debate rages on what should be the most prudent strategy for the Indian economy, as it faces adverse global and structural headwinds, consider the following three views. First Dani Rodrik,
Compare China and India. China grew by building factories and filling them with peasants who had little education, which generated an instant boost in productivity. India’s comparative advantage lies in relatively skill-intensive services – such as information technology – which can absorb no more than a tiny slice of the country’s largely unskilled labor force. It will take many decades for the average skill level in India to rise to the point that it can pull the economy’s overall productivity significantly higher. So India’s medium-term growth potential lies well below that of China in recent decades. A significant boost in infrastructure spending and policy reforms can make a difference, but it cannot close the gap. On the other hand, being the tortoise rather than the hare in the growth race can be an advantage. Countries that rely on steady, economy-wide accumulation of skills and improved governance may not grow as fast, but they may be more stable, less prone to crises, and more likely to converge with advanced countries eventually.
So what should policymakers do in such uncertain times? The prudent course would be to hunker down and preserve stability, awaiting greater clarity. rather than turn to policy adventurism. With the sharp decline in India’s inflation, the pressure is on for interest rates to be cut further. The argument is that this would boost both consumption and investment. But money is fungible. The government can easily deliver the equivalent of several percentage points of rate cuts by passing on the decline in global crude to retail pump prices rather than taxing most of it away, as it has so far. This would be the safer option. Cutting domestic rates in the face of Fed tightening unnecessarily raises India’s external vulnerability. More importantly, if the already outsized decline in inflation and input costs hasn’t induced either households or corporations to raise consumption or investment, would a few more basis points of interest rate reduction or its equivalent change anything much?
And, finally, Raghuram Rajan,
Growth has to be obtained in the right way. It is possible to grow too fast with substantial stimulus, as we did in 2010 and 2011, only to pay the price in higher inflation, higher deficits, and lower growth in 2013 and 2014. Of course, India is not in the same situation today. But with the world being an inhospitable place, we have to work hard to strengthen our current recovery and put it on a more sustainable footing. And while monetary policy will accommodate to the extent there is room, we will expand sustainable growth potential only by continuing to implement reforms the government and regulators have announced. These are intended to strengthen the environment for doing business and to expand access to financing, and these will then in turn allow our companies to find and exploit their core competencies...



While we understand the difficulties industry has and will work as hard as we can on improving the environment, India must resist special interest pleas for targeted stimulus, additional tax breaks and protections, directed credit, subventions and subsidies, all of which have historically rendered industry uncompetitive, government over-extended, and the country incapable of regaining its rightful position amongst nations... Jugaad or “working around” difficulties by hook or by crook is a thoroughly Indian way of coping but it is predicated on a difficult or impossible business environment. And it encourages an attitude of short cuts and evasions, none of which help final product quality or sustainable economic growth... The current difficulties of emerging markets stem from a complicated set of reasons, but an important one is impatience to regain growth by overemphasizing old and ineffective methods of stimulus.
So here is my two-pence worth synthesis,

1. India today faces several internal and external structural headwinds and some of the traditional paths to sustainable high growth rates may no longer be open. Our structural transformation may not pan out as expected and may prove quite tortuous.

2. The prevailing global market conditions are adverse and compounds the challenge.

3. India's economy is simply not broad-based enough - consumer spending power, firm capacity, retail and other transactional chains, breadth and depth of credit markets, skilled labor supply, and infrastructure capacity - to sustain high growth rates for longer durations. The weak state capacity and various land, capital, and labor market distortions only exacerbate the problem.

4. So a more prudent strategy may be, as Dani Rodrik says, to be the "tortoise", or as Jahangir Aziz says, to "hunker down", and brace for 5-7% medium-term growth rates and expedite important long-term reforms in health, education, labor, credit markets, taxation, and most importantly, in improving state capability. Simultaneously keep investing in infrastructure so that the stock builds up and deficiency shrinks. If done as planned, hopefully, over 4-6 years, we can reach where China was in 2001 and then take-off in a more sustainable manner.

As a strategy, policy makers and political leaders may need to acknowledge this reality, while pursuing the strategy of talking up the markets. The latter is necessary not just to win elections, but also to signal to the financial market participants. But the former is where substantive action should take place. The "island of relative calm in an ocean of turmoil", as the RBI Governor described the relative state of Indian economy, and the window of opportunity that it presents may not last for too long. 
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22 Sep 09:02

Why manholes become potholes on Bangalore roads?

by Amol Agrawal
The stark contrast of India shining in pink papers and India clueless in white papers is just growing every day. We don’t have solutions for our potholed roads, piling garbage, errant electricity, declining water and so on. But enormous noise is created in pink papers how India is like a million roses in today’s world economy. […]
22 Sep 08:54

Good is more than bad

by Muthu

Joshua Brown has shared this excellent chart created by Virginia retirement system.

I want share some observations based on this chart.

They have studied US stocks (S&P 500 index) for a period from 1926 to 2014, 89 years.

Out of 89 years, there was a positive average return of 21.47% for 65 years, 73% of the time.

The balance 24 years, 27% of the time, there was a negative average return of -14.29%.

65 positive years are distributed as follows:

Return of 0% to 10%: 14 years

10% to 20%: 18 years

20% to 30%: 15 years

30% to 40%: 13 years

40% to 60%: 5 years

24 negative years are distributed as follows:

Return of -10% to 0%: 13 years

-20% to -10%: 5 years

-30% to -20%: 3 years

-40% to -30%: 2 years

-60% to -40%: 1 year

Out of 89 years, there has been loss of above 20% only in 6 years. Except for these 6 years (where the loss ranged above 20% to 60%); the other negative years were emotionally more manageable. Many, fearing these 6 years, let go the opportunity available in 65 years.

Please note that in stock markets, good years are always more than bad years.

As you are aware, from 1979-80 to 20014-15; for the last 36 financial years; Sensex had 25 positive years and only 11 negative years. In other words, 70% of the time Sensex has provided positive returns.

As long as earnings continue to grow, declines are temporary and upward trajectory is permanent.

Take next 10 years or 20 years; markets would be much higher than where it is now.

Both in real and nominal terms, markets generally tend to keep moving upwards over long run with lot of volatility in between. If you can be comfortable with volatility, equities would confer huge wealth for being patient and staying the course.


22 Sep 08:42

Are you liking what you are doing?

by subra
Ask yourself one very important question: Are you happy with what you are doing or are you a slave? the definition of a sudra was a person who was always told what to do..or he was like a slave. Consider this – if you have a lifestyle you do not like (I am moving from […]