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     Nov 28, 2007
Page 3 of 3
PATHOLOGY OF DEBT
PART 2: Commercial paper and pesky SIVs
By Henry C K Liu

Rate by 50 basis points to 5.75% and change to the rules for access by banks to the Fed discount window, that its discount window was prepared to accept the new commercial paper backed by asset-backed securities as collateral from banks for loans with which to fund bank credit lines to otherwise distressed borrowers.

Fed data show the supply of ABCP slumped by a record US$77



billion in the week to August 22. Overnight yields on top-rated commercial paper dropped 5 basis points to 6.04 percent but still up 78 basis points in the past 30 days. As of August 22, Fed data show about 86% of all ABCP coming due within seven days, and about 50% maturing overnight. Yields on the US$1.2 trillion market for ABCP had been rising because the money market funds might have to liquidate assets quickly to pay back short-term debt. That could set off spiraling losses in the money market for other structured finance instruments even if synthetic ''mark-to-model'' face values had not yet been adjusted to ''mark-to market'' reality as the housing crisis deepens to further adversely affect the credit market.

Seasonally adjusted outstanding commercial paper fell US$90.2 billion to US$2.04 trillion in the week ended Wednesday August 24, after falling US$91.1 billion in the previous week. Most of the decline came in ABCP. In August, ABCP fell more than US$170 billion from the level at the end of July. The previous monthly record was a decline of US$78 billion in January 2001 that signaled the ''Early 2000s'' recession identified by the National Bureau of Economic Research (NBER).

About US$125 billion in ABCP was withdrawn from the market in September, a sign that banks were stepping in under their liquidity agreements to make good on their customers' maturing debt in the commercial paper market. As of the week of October 17, outstanding commercial paper was US$1.88 trillion, down US$300 billion from US$2.18 trillion in the first week of August.

Pesky structured investment vehicles
About 43% of the assets in structured investment vehicles (SIVs) - which hold mainly highly rated asset-backed securities and fund themselves using the short-term commercial paper market - is financial institution debt. If the SIVs were forced to make fire sales to raise cash, it would drive down prices and lift funding costs for banks, which could respond by tightening the supply of credit. Investors are demanding much higher yields on bank debt because of concern over the effect on their balance sheets of the subprime mortgage meltdown.

Citigroup, with another US$11 billion of writedowns on its holdings of subprime-related investments, was forced to pay 1.9 percentage points more than US Treasuries in the second week of November, 0.7 point more than a similar sale three months ago, before the August liquidity crisis, on a 10-year US$4 billion bond issue. Yields on financial bonds are on average 1.49 percentage points more than Treasuries, while the premium on industrial bonds is 1.34 points.

For the first time since the beginning of the liquidity boom several years ago, credit default swaps on financial companies are now trading in line with, or even wider than, industrial companies, costing more to insure financial debt against default.

After the August liquidity crisis, Citigroup paid US$25 million more in annual borrowing charges to raise US$4 billion in 10-year fixed rate bonds compared with a similarly structured deal in February. It also paid US$5 million more in annual interest rate fees than a similarly structured bond in August, showing the outlook for the largest US bank had deteriorated further from the height of the crisis at the end of the summer. In a further sign of falling confidence in the bank, insurance for Citigroup bonds against default in credit derivatives now costs more than for emerging market countries such as Mexico and Malaysia.

Troubled bond insurer ACA Capital Holdings is reportedly facing credit rating cuts, which would set off a chain reaction requiring banks to put an estimated additional US$60 billion of CDO obligations on their balance sheets. S&P reviewed ACA’s ''A'' rating in early November when the company reported a US$1.04 billion third-quarter loss. ACA noted in an SEC filing in the third week of November that it would not meet collateral obligation requirements if its rating should fall below ''A-''.

ACA is one of nine key bond insurers threatened with a credit rating downgrade. Together, the nine are responsible for insuring about US$2.4 trillion of debt. Bear Stearns’ private equity group bought a 29% stake in ACA for US$100 million in 2004. Market capitalization of ACA fell to US$29 million after its stock fell more than 90 per cent from year-end December 2006 to mid-November 2007. If ACA defaults, Merrill Lynch may have to take an additional US$3 billion writedown from CDO exposure. Shares of ACA fell another 22.7% to US$0.85 on November 21, while Merrill Lynch traded down 3.5% to US$51.81 and Bear Stearns dropped 2.8% to US$91.28.

PART 3: Credit guns heard around the world

Henry C K Liu is chairman of a New York-based private investment group. His website is at http://www.henryckliu.com.

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