From the Institutional Risk Analyst, one of the best blogs out there on banking risk:

As of Q1 2009, Ally was rated "F" by the IRA Bank Monitor, due to severe degradation in ROE. The Stress Index score for Ally was 21.2 driven by a score of 100 for the ROE subindex. Like the larger zombie banks, the other Stress Index factors for GMAC Bank/Ally for loan defaults, capital, lending capacity and efficiency are all currently below the industry averages (and indeed, below the 1995 benchmark levels of stress). But these "improved" measures are, in our view, a mirage created by the fact of government subsidies.

Without the billions of dollars in public funds already injected into GMAC Bank/Ally's parent, the bank arguably would already be in the hands of the FDIC. More, when you examine the profile for GMAC Bank/Ally on The IRA Bank Monitor (the legal name had not been changed at the end of Q1, so search for "GMAC"), here are some of the factors that jump out and bite you in the face:

** First, Ally has non-performing loans equal to almost 6% of loans and leases. Subtract those from the bank level TCE and you get closer to the cash reality of Ally's capital base, which puts it into the regulatory category of "undercapitalized."

** Second, while Ally's deposit base appears to be stable, due in large part to the above-market rates being offered in TV and print media across the country, one quarter of the bank's assets are funded off the FHLBs -- well above the regulatory limit of 15% established by regulators as "unsafe and unsound." The percentage has come down from 30% several quarter back, but is still too high. In The IRA Bank Monitor, banks with > 15% FHLB advances trigger a moral hazard flag.

** Third, the moral hazard of GMAC Bank is clearly illustrated by the fact that the bank has apparently decided to double down at the derivative roulette table. As of Q1 2009, OBS derivatives positions reported by the $30 billion asset GMAC Bank/Ally to the FDIC jumped from $13.3 billion at the end of Q4 2008 to over $40 billion as of Q1 2009. This dramatic increase in OBS derivatives positions NOT FOR TRADE suggests that GMAC is trying to hit a home run and thereby salvage their position.

But the real issue to us is why is this marginal lender being allowed to compete with solvent, well-run banking institutions? The answer obviously is the same politics behind the GM bailout. Give the recent decision by the FDIC to limit the interest rates offered on deposits by institutions that are less than well capitalized, we wonder: When is the OTS and the FDIC going to restrict the full-page advertisements by GMAC Bank/Ally that were running in newspapers around the US offering rates that are nearly 1.5% above the rates offered by sound institutions?

As in the case of Ford Motor (NYSE:F) competing with the two auto GSEs, Chrysler and GM, well-managed banks in the US now have to compete with an irrational, GSE bank in the form of GMAC Bank/Ally whose only apparent objective is to raise enough cash today to survive until the next bailout from the US Treasury. If you believe the statements by the Obama Administration that $30 billion will be the limit of US government assistance to GM, then you should feel less than confident in keeping your money in GMAC Bank/Ally.

Tags: IRA, bailout, gm, risk

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Replies to This Discussion

A few comments for what they are worth...

**First point - I wouldn't subtract out the entire 6% non-performing loans and leases from capital. You would first have to apply a loss severity factor to this 6%. If there is a 50% loss severity given that a loan defaults then the 6% non-performing loans would represent only 3% in losses. The next thing I would do is first subtract reserves from this amount (because that is what reserves are there for - to cover expected losses). The subtraction from capital would be max(6% x 50% loss severity - reserves, 0).

**Second point - Doesn't bother me. In this kind of credit environment I would max out borrowings from the FHLB.

**Third point - Derivatives can be used to reduce or eliminate risk so GMAC's increased use of derivatives might be a very good thing. Banks get into trouble when they use derivatives for speculation rather than hedging.

My two cents.

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