Conclusions from the FSA's report into RBS's collapse
The FSA's long-awaited, gargantuan (at 500 pages) report into the collapse of RBS has finally been unveiled.
The causes of RBS's collapse, it concludes, are multiple. They include an over-reliance on risky short-term wholesale funding, substantial losses on its structured credit trading activities, over-extending itself with a poorly judged acquisition of ABN Amro, a weak capital position, concerns and uncertainties about RBS's underlying asset quality (which the FSA failed to spot) and, of course, all of this is framed within a systematic crisis in which the bank was worse positioned than most.
So, what conclusions can we draw about RBS's collapse and any potential consequences of this report?
Senior management WILL be punished if another RBS-style collapse happens
No legal action is being pursued against any of the key executives at RBS as a result of the FSA's investigation. However, one of the consequences of is that a tougher line will be toed in the future.
It will employ a "strict liability" model against executives and board members of failed banks, meaning that fines, banks and the clawback of remuneration will be enforced if a bank collapses.
On the pay aspect, the report says that: "Regulations of this form have already been introduced for executive directors: they could be strengthened by increasing both the proportion of pay deferred and the period of deferral."
There was next to no due diligence on the ABN Amro acquisition
RBS entered into its acquisition of ABN Amro "without appropriate heed to the risks involved and with inadequate due diligence", says the report.
Quite how little information RBS had on the situation is quite shocking, however. It had "two lever arch folders and a CD", says the report, and "RBS was largely unsuccessful in its attempts to obtain further non-publicly available information". It went ahead anyway…
No one is specifically blamed, but key people don't come off well
There are various stories of Fred Goodwin's megalomania during his time at the helm of RBS; from his supposed daily berating of a random member of the executive team during senior management meetings, to his outrage at the choice of a pink wafer biscuit.
The report concludes that there's "insufficient evidence" to specifically blame any key individuals, but questions whether "the CEO's management style discouraged robust and effective challenge" and if the board's way of operating "including challenge to the executive, was as effective as its composition and formal processes would suggest".
The FSA does, however, insist that it had previously raised concerns over Fred Goodwin's "robust and assertive" management style and "chief executive dominance" during meetings with RBS chairman Sir George Mathewson between 2003-2006.
Similarly, in its investment bank, while it says that "senior management on some occasions displayed flawed understanding of key aspects of the risks being taken", Johnny Cameron is not singled out for criticism.
He did "not lead GBM alone and had assistance from others with relevant expertise", says the report.
There are now nearly four times as many people supervising RBS
The FSA is reasonably critical of its own role, suggesting that had "insufficient resources" to oversee high impact banks and that it was operating in a "“backdrop of political pressures for a ‘light touch’ regulatory regime".
It is, however, careful to point out that it's now a "different organisation" with "more resources, better skills and a more intensive approach". This is illustrated by the number of people focused on supervising RBS – in August 2007, there were six people overseeing the Scottish bank, a team that has now increased in size to 23.
RBS's investment bank was worse than many of its peers
RBS's investment bank grew its assets by an average of 34% a year from the end of 2004 to 2007, as it looked to become a key investment banking player and it expanded into "multiple business sectors and geographies, including many where RBS did not have long established relationships or deep local presence".
In particular, the bank looked to expand its leveraged finance and structured credit functions aggressively from June 2006. When it became evident in 2007 that RBS's structured credit positions were on the decline, over the subsequent 18 months the bank was "less effective than some other banks in distributing or hedging its exposures".
It was, however, victim to market sentiment at the time, suggests the report: "Although with hindsight it would have been better for RBS to have closed out its positions earlier, crystallising losses and containing risks, the decisions not to do so were not, as viewed at the time, clearly unreasonable."